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{{#Wiki_filter:Safety Evaluation Report With Open Items Related to the License Renewal of Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 Carolina Power & Light Company United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation March 2008
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ABSTRACT This safety evaluation report (SER) documents the technical review of the Shearon Harris Nuclear Power Plant (HNP), Unit 1, license renewal application (LRA) by the United States (US)
Nuclear Regulatory Commission (NRC) staff (the staff). By letter dated November 14, 2006, Carolina Power & Light (CP&L) Company, doing business as Progress Energy Carolinas, Inc.,
submitted the LRA in accordance with Title 10, Part 54, of the Code of Federal Regulations, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. CP&L requests renewal of the Unit 1 operating license (Facility Operating License Number NPF-63) for a period of 20 years beyond the current expiration at midnight October 24, 2026, for Unit 1.
HNP is located approximately 16 miles southwest of Raleigh, NC., and 15 miles northeast of Sanford, NC. The NRC issued the construction permit for Unit 1 on January 27, 1978, and operating license on January 12, 1987. Unit 1 is of a dry ambient pressurized water reactor design. Westinghouse supplied the nuclear steam supply system and Daniel International originally designed and constructed the balance of the plant with the assistance of its agent, Ebasco. The Unit 1 licensed power output is 2900 megawatt thermal with a gross electrical output of approximately 900 megawatt electric.
This SER presents the status of the staffs review of information submitted through February 19, 2008, the cutoff date for consideration in the SER. The staff identified an open item and confirmatory items that must be resolved before any final determination on the LRA.
SER Sections 1.5 and 1.6 for open Items and confirmatory Items, respectively summarize these items. The staff will present its final conclusion on the LRA review in an update to this SER.
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TABLE OF CONTENTS Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiv Introduction and General Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                  1-1 1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .          1-1 1.2 License Renewal Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                          1-2 1.2.1 Safety Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                1-3 1.2.2 Environmental Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                      1-4 1.3 Principal Review Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                    1-5 1.4 Interim Staff Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                  1-6 1.5 Summary of Open Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                      1-7 1.6 Summary of Confirmatory Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                          1-8 1.7 Summary of Proposed License Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                                1-9 Structures and Components Subject to Aging Management Review . . . . . . . . . . . . . . . . . . . 2-1 2.1 Scoping and Screening Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1.2 Summary of Technical Information in the Application . . . . . . . . . . . . . . 2-1 2.1.3 Scoping and Screening Program Review . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.1.3.1 Implementation Procedures and Documentation Sources for Scoping and Screening . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2.1.3.2 Quality Controls Applied to LRA Development . . . . . . . . . . . . 2-5 2.1.3.3 Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 2.1.3.4 Conclusion of Scoping and Screening Program Review . . . . 2-7 2.1.4 Plant Systems, Structures, and Components Scoping Methodology . . 2-7 2.1.4.1 Application of the Scoping Criteria in 10 CFR 54.4(a)(1) . . . 2-8 2.1.4.2 Application of the Scoping Criteria in 10 CFR 54.4(a)(2) . . 2-10 2.1.4.3 Application of the Scoping Criteria in 10 CFR 54.4(a)(3) . . 2-17 2.1.4.4 Plant-Level Scoping of Systems and Structures . . . . . . . . . 2-20 2.1.4.5 Conclusion for Scoping Methodology . . . . . . . . . . . . . . . . . . 2-24 2.1.5 Screening Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-25 2.1.5.1 General Screening Methodology . . . . . . . . . . . . . . . . . . . . . 2-25 2.1.5.2 Mechanical Component Screening . . . . . . . . . . . . . . . . . . . 2-26 2.1.5.3 Structural Component Screening . . . . . . . . . . . . . . . . . . . . . 2-29 2.1.5.4 Electrical Component Screening . . . . . . . . . . . . . . . . . . . . . 2-31 2.1.5.5 Conclusion for Screening Methodology . . . . . . . . . . . . . . . . 2-32 2.1.6 Summary of Evaluation Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-32 2.2 Plant-Level Scoping Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-32 2.2.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-32 2.2.2 Summary of Technical Information in the Application . . . . . . . . . . . . . 2-33 2.2.3 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-33 2.2.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-36 2.3 Scoping and Screening Results - Mechanical Systems . . . . . . . . . . . . . . . . . . 2-36 v
 
2.3.1 Reactor Vessel, Internals, and Reactor Coolant System . . . . . . . . . . 2-41 2.3.1.1 Reactor Vessel and Internals . . . . . . . . . . . . . . . . . . . . . . . . 2-41 2.3.1.2 Incore Instrumentation System . . . . . . . . . . . . . . . . . . . . . . 2-44 2.3.1.3 Reactor Coolant System . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-45 2.3.1.4 Reactor Coolant Pump and Motor . . . . . . . . . . . . . . . . . . . . 2-47 2.3.1.5 Pressurizer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-48 2.3.1.6 Steam Generator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-50 2.3.2 Engineered Safety Features Systems . . . . . . . . . . . . . . . . . . . . . . . . 2-52 2.3.2.1 Containment Spray System . . . . . . . . . . . . . . . . . . . . . . . . . 2-52 2.3.2.2 Containment Isolation System . . . . . . . . . . . . . . . . . . . . . . . 2-55 2.3.2.3 High-Head Safety-Injection System . . . . . . . . . . . . . . . . . . . 2-56 2.3.2.4 Low-Head Safety-Injection / Residual Heat Removal System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-58 2.3.2.5 Passive Safety-Injection System . . . . . . . . . . . . . . . . . . . . . 2-59 2.3.2.6 Control Room Area Ventilation System . . . . . . . . . . . . . . . . 2-60 2.3.3 Auxiliary Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-62 2.3.3.1 Chemical and Volume Control System . . . . . . . . . . . . . . . . 2-63 2.3.3.2 Boron Thermal Regeneration System . . . . . . . . . . . . . . . . . 2-64 2.3.3.3 Primary Makeup System . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-66 2.3.3.4 Primary Sampling System . . . . . . . . . . . . . . . . . . . . . . . . . . 2-67 2.3.3.5 Post-Accident Sampling System . . . . . . . . . . . . . . . . . . . . . 2-68 2.3.3.6 Circulating Water System . . . . . . . . . . . . . . . . . . . . . . . . . . 2-69 2.3.3.7 Cooling Tower System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-71 2.3.3.8 Cooling Tower Make-Up System . . . . . . . . . . . . . . . . . . . . . 2-72 2.3.3.9 Screen Wash System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-73 2.3.3.10 Main Reservoir Auxiliary Equipment . . . . . . . . . . . . . . . . . 2-74 2.3.3.11 Auxiliary Reservoir Auxiliary Equipment . . . . . . . . . . . . . . . 2-75 2.3.3.12 Normal Service Water System . . . . . . . . . . . . . . . . . . . . . . 2-76 2.3.3.13 Emergency Service Water System . . . . . . . . . . . . . . . . . . 2-77 2.3.3.14 Component Cooling Water System . . . . . . . . . . . . . . . . . . 2-80 2.3.3.15 Waste Processing Building Cooling Water System . . . . . . 2-81 2.3.3.16 Essential Services Chilled Water System . . . . . . . . . . . . . 2-83 2.3.3.17 Nonessential Services Chilled Water System . . . . . . . . . . 2-85 2.3.3.18 Emergency Screen Wash System . . . . . . . . . . . . . . . . . . . 2-86 2.3.3.19 Generator Gas System . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-87 2.3.3.20 Hydrogen Seal Oil System . . . . . . . . . . . . . . . . . . . . . . . . . 2-88 2.3.3.21 Emergency Diesel Generator System . . . . . . . . . . . . . . . . 2-89 2.3.3.22 Diesel Generator Fuel Oil Storage and Transfer System . . 2-91 2.3.3.23 Diesel Generator Lubrication System . . . . . . . . . . . . . . . . 2-93 2.3.3.24 Diesel Generator Cooling Water System . . . . . . . . . . . . . . 2-94 2.3.3.25 Diesel Generator Air Starting System . . . . . . . . . . . . . . . . 2-96 2.3.3.26 Security Power System . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-97 2.3.3.27 Instrument Air System . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-98 2.3.3.28 Service Air System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-100 2.3.3.29 Bulk Nitrogen Storage System . . . . . . . . . . . . . . . . . . . . . 2-102 2.3.3.30 Hydrogen Gas System . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-103 2.3.3.32 Storm Drains System . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-128 2.3.3.33 Oily Drains System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-129 2.3.3.34 Radioactive Floor Drains System . . . . . . . . . . . . . . . . . . . 2-130 vi
 
2.3.3.35 Radioactive Equipment Drains System . . . . . . . . . . . . . .                    2-132 2.3.3.36 Secondary Waste System . . . . . . . . . . . . . . . . . . . . . . . .            2-133 2.3.3.37 Laundry and Hot Shower System . . . . . . . . . . . . . . . . . .                  2-134 2.3.3.38 Upflow Filter System . . . . . . . . . . . . . . . . . . . . . . . . . . . .      2-135 2.3.3.39 Potable and Sanitary Water System . . . . . . . . . . . . . . . .                  2-136 2.3.3.40 Demineralized Water System . . . . . . . . . . . . . . . . . . . . .              2-137 2.3.3.41 Filter Backwash System . . . . . . . . . . . . . . . . . . . . . . . . .          2-138 2.3.3.42 Radiation Monitoring System . . . . . . . . . . . . . . . . . . . . . .            2-139 2.3.3.43 Oily Waste Collection and Separation System . . . . . . . . .                      2-141 2.3.3.44 Liquid Waste Processing System . . . . . . . . . . . . . . . . . .                2-144 2.3.3.45 Secondary Waste Treatment System . . . . . . . . . . . . . . .                    2-145 2.3.3.46 Boron Recycle System . . . . . . . . . . . . . . . . . . . . . . . . . .          2-147 2.3.3.47 Gaseous Waste Processing System . . . . . . . . . . . . . . . .                    2-149 2.3.3.48 Radwaste Sampling System . . . . . . . . . . . . . . . . . . . . . .              2-150 2.3.3.49 Refueling System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      2-151 2.3.3.50 New Fuel Handling System . . . . . . . . . . . . . . . . . . . . . . .            2-153 2.3.3.51 Spent Fuel System . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        2-154 2.3.3.52 Spent Fuel Pool Cooling System . . . . . . . . . . . . . . . . . . .              2-155 2.3.3.53 Spent Fuel Pool Cleanup System . . . . . . . . . . . . . . . . . .                2-157 2.3.3.54 Spent Fuel Cask Decontamination and Spray System . . .                            2-158 2.3.3.55 Spent Resin Storage and Transfer System . . . . . . . . . . .                      2-159 2.3.3.56 Containment Auxiliary Equipment . . . . . . . . . . . . . . . . . .                2-160 2.3.3.57 Containment Liner Penetration Auxiliary Equipment . . . .                          2-161 2.3.3.58 Security Building HVAC System . . . . . . . . . . . . . . . . . . .                2-163 2.3.3.59 Containment Vacuum Relief System . . . . . . . . . . . . . . . .                  2-164 2.3.3.60 Bridge Crane Equipment . . . . . . . . . . . . . . . . . . . . . . . . .          2-165 2.3.3.61 Containment Pressurization System . . . . . . . . . . . . . . . .                  2-166 2.3.3.62 Penetration Pressurization System . . . . . . . . . . . . . . . . .                2-167 2.3.3.63 Containment Cooling System . . . . . . . . . . . . . . . . . . . . .              2-168 2.3.3.64 Airborne Radioactivity Removal System . . . . . . . . . . . . .                    2-172 2.3.3.65 Containment Atmosphere Purge Exhaust System . . . . . .                            2-173 2.3.3.66 Control Rod Drive Mechanism Ventilation System . . . . . .                        2-175 2.3.3.67 Primary Shield and Reactor Supports Cooling System . .                            2-176 2.3.3.68 Fuel Cask Handling Crane System . . . . . . . . . . . . . . . . .                  2-178 2.3.3.69 Reactor Auxiliary Building Ventilation System . . . . . . . . .                    2-178 2.3.3.70 Emergency Service Water Intake Structure Ventilation System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-181 2.3.3.71 Turbine Building Area Ventilation System . . . . . . . . . . . .                  2-183 2.3.3.72 Waste Processing Building HVAC System . . . . . . . . . . .                        2-185 2.3.3.73 Diesel Generator Building Ventilation System . . . . . . . . .                    2-187 2.3.3.74 Fuel Oil Transfer Pump House Ventilation System . . . . .                          2-189 2.3.3.75 Fuel Handling Building Auxiliary Equipment . . . . . . . . . . .                  2-190 2.3.3.76 Fuel Handling Building HVAC System . . . . . . . . . . . . . . .                  2-191 2.3.3.77 Turbine Building Health Physics Room Auxiliary Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-193 2.3.3.78 Polar Crane Auxiliary Equipment . . . . . . . . . . . . . . . . . . .              2-193 2.3.3.79 Elevator System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      2-194 2.3.3.80 Technical Support Center HVAC System . . . . . . . . . . . .                      2-195 2.3.3.81 Mechanical Components in Electrical Systems . . . . . . . .                        2-196 vii
 
2.3.3.82 Monorail Hoists Equipment . . . . . . . . . . . . . . . . . . . . . . . 2-197 2.3.3.83 Post-Accident Hydrogen System . . . . . . . . . . . . . . . . . . . 2-198 2.3.4 Steam and Power Conversion Systems . . . . . . . . . . . . . . . . . . . . . . 2-199 2.3.4.1 Steam Generator Blowdown System . . . . . . . . . . . . . . . . . 2-200 2.3.4.2 Steam Generator Chemical Addition System . . . . . . . . . . . 2-202 2.3.4.3 Main Steam Supply System . . . . . . . . . . . . . . . . . . . . . . . . 2-203 2.3.4.4 Steam Dump System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-205 2.3.4.5 Auxiliary Boiler/Steam System . . . . . . . . . . . . . . . . . . . . . . 2-206 2.3.4.6 Feedwater System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-207 2.3.4.7 Feedwater Heater Drains & Vents System . . . . . . . . . . . . 2-209 2.3.4.8 Auxiliary Feedwater System . . . . . . . . . . . . . . . . . . . . . . . 2-210 2.3.4.9 Auxiliary Steam Condensate System . . . . . . . . . . . . . . . . . 2-211 2.3.4.10 Condensate System . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-212 2.3.4.11 Condensate Storage System . . . . . . . . . . . . . . . . . . . . . . 2-214 2.3.4.12 Secondary Sampling System . . . . . . . . . . . . . . . . . . . . . . 2-215 2.3.4.13 Steam Generator Wet Lay Up System . . . . . . . . . . . . . . . 2-217 2.3.4.14 Turbine System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-218 2.3.4.15 Digital-Electric Hydraulic System . . . . . . . . . . . . . . . . . . . 2-219 2.3.4.16 Turbine-Generator Lube Oil System . . . . . . . . . . . . . . . . 2-220 2.4 Scoping and Screening Results - Structures . . . . . . . . . . . . . . . . . . . . . . . . . 2-221 2.4.1 Containment Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-221 2.4.1.1 Containment Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-222 2.4.1.2 Containment Internal Structures . . . . . . . . . . . . . . . . . . . . 2-225 2.4.1.3 Containment Building Functions . . . . . . . . . . . . . . . . . . . . 2-226 2.4.2 Other Class I and In-Scope Structures . . . . . . . . . . . . . . . . . . . . . . . 2-228 2.4.2.1 Reactor Auxiliary Building . . . . . . . . . . . . . . . . . . . . . . . . . 2-229 2.4.2.2 Auxiliary Reservoir Channel . . . . . . . . . . . . . . . . . . . . . . . . 2-232 2.4.2.3 Auxiliary Dam and Spillway . . . . . . . . . . . . . . . . . . . . . . . . 2-233 2.4.2.4 Auxiliary Reservoir . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-234 2.4.2.5 Auxiliary Reservoir Separating Dike . . . . . . . . . . . . . . . . . . 2-235 2.4.2.6 Cooling Tower . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-236 2.4.2.7 Cooling Tower Makeup Water Intake Channel . . . . . . . . . 2-238 2.4.2.8 Circulating Water Intake Structure . . . . . . . . . . . . . . . . . . . 2-239 2.4.2.9 Diesel Generator Building . . . . . . . . . . . . . . . . . . . . . . . . . 2-240 2.4.2.10 Main Dam and Spillway . . . . . . . . . . . . . . . . . . . . . . . . . . 2-242 2.4.2.11 Diesel Fuel Oil Storage Tank Building . . . . . . . . . . . . . . . 2-243 2.4.2.12 Emergency Service Water and Cooling Tower Makeup Intake Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-245 2.4.2.13 Emergency Service Water Discharge Channel . . . . . . . . 2-248 2.4.2.14 Emergency Service Water Discharge Structure . . . . . . . . 2-249 2.4.2.15 Emergency Service Water Intake Channel . . . . . . . . . . . 2-251 2.4.2.16 Fuel Handling Building . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-252 2.4.2.17 HVAC Equipment Room . . . . . . . . . . . . . . . . . . . . . . . . . 2-255 2.4.2.18 Outside the Power Block Structures . . . . . . . . . . . . . . . . 2-257 2.4.2.19 Main Reservoir . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-258 2.4.2.20 Security Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-259 2.4.2.21 Emergency Service Water Screening Structure . . . . . . . . 2-260 2.4.2.22 Normal Service Water Intake Structure . . . . . . . . . . . . . . 2-262 2.4.2.23 Switchyard Relay Building . . . . . . . . . . . . . . . . . . . . . . . . 2-263 viii
 
2.4.2.24 Transformer and Switchyard Structures . . . . . . . . . . . . . 2-265 2.4.2.25 Turbine Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-266 2.4.2.26 Tank Area/Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-268 2.4.2.27 Waste Processing Building . . . . . . . . . . . . . . . . . . . . . . . 2-270 2.4.2.28 Yard Structures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-271 2.5 Scoping and Screening Results - Electrical and Instrumentation and Controls (I&C)
Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-273 2.5.1 Electrical and I&C Component Commodity Groups . . . . . . . . . . . . . 2-274 2.5.1.1 Summary of Technical Information in the Application . . . . 2-274 2.5.1.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-276 2.5.1.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-277 2.6 Conclusion for Scoping and Screening . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-277 Aging Management Review Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3.0 Applicants Use of the Generic Aging Lessons Learned Report . . . . . . . . . . . . . 3-1 3.0.1 Format of the License Renewal Application . . . . . . . . . . . . . . . . . . . . . 3-2 3.0.1.1 Overview of Table 1s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 3.0.1.2 Overview of Table 2s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3 3.0.2 Staffs Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 3.0.2.1 Review of AMPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 3.0.2.2 Review of AMR Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6 3.0.2.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6 3.0.2.4 Documentation and Documents Reviewed . . . . . . . . . . . . . . 3-6 3.0.3 Aging Management Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6 3.0.3.1 AMPs Consistent with the GALL Report . . . . . . . . . . . . . . . 3-12 3.0.3.2 AMPs Consistent with the GALL Report with Exceptions or Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-53 3.0.3.3 AMPs Not Consistent with or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-161 3.0.4 QA Program Attributes Integral to Aging Management Programs . . 3-166 3.0.4.1 Summary of Technical Information in the Application . . . . 3-167 3.0.4.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-167 3.0.4.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-169 3.1 Aging Management of Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-169 3.1.1 Summary of Technical Information in the Application . . . . . . . . . . . . 3-169 3.1.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-169 3.1.2.1 AMR Results Consistent with the GALL Report . . . . . . . . . 3-195 3.1.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended . . . . . . . . . . . . . . . . . 3-204 3.1.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-229 3.1.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-243 3.2 Aging Management of Engineered Safety Features System . . . . . . . . . . . . . . 3-243 3.2.1 Summary of Technical Information in the Application . . . . . . . . . . . . 3-243 3.2.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-243 3.2.2.1 AMR Results Consistent with the GALL Report . . . . . . . . . 3-256 3.2.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended . . . . . . . . . . . . . . . . . 3-258 ix
 
3.2.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .          3-273 3.2.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-278 3.3 Aging Management of Auxiliary Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . .                3-278 3.3.1 Summary of Technical Information in the Application . . . . . . . . . . . .                          3-280 3.3.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-280 3.3.2.1 AMR Results Consistent with the GALL Report . . . . . . . . .                            3-305 3.3.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended . . . . . . . . . . . . . . . . .                      3-330 3.3.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        3-349 3.3.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-420 3.4 Aging Management of Steam and Power Conversion Systems . . . . . . . . . . .                                  3-420 3.4.1 Summary of Technical Information in the Application . . . . . . . . . . . .                          3-420 3.4.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-421 3.4.2.1 AMR Results Consistent with the GALL Report . . . . . . . . .                            3-430 3.4.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended . . . . . . . . . . . . . . . . .                      3-432 3.4.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-477 3.5 Aging Management of Containments, Structures, and Component Supports .                                        3-478 3.5.1 Summary of Technical Information in the Application . . . . . . . . . . . .                          3-478 3.5.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-479 3.5.2.1 AMR Results Consistent with the GALL Report . . . . . . . . .                            3-495 3.5.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended . . . . . . . . . . . . . . . . .                      3-516 3.5.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        3-539 3.5.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-570 3.6 Aging Management of Electrical and Instrumentation and Controls System . .                                    3-570 3.6.1 Summary of Technical Information in the Application . . . . . . . . . . . .                          3-571 3.6.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-571 3.6.2.1 AMR Results Consistent with the GALL Report . . . . . . . . .                            3-576 3.6.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended . . . . . . . . . . . . . . . . .                      3-578 3.6.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        3-584 3.6.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-589 3.7 Conclusion for Aging Management Review Results . . . . . . . . . . . . . . . . . . . .                        3-589 Time-Limited Aging Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.1 Identification of Time-Limited Aging Analyses . . . . . . . . . . . . . . . . . . . . . . . . . .                4-1 4.1.1 Summary of Technical Information in the Application . . . . . . . . . . . . . .                        4-1 4.1.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 4.1.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3 4.2 Reactor Vessel Neutron Embrittlement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .            4-3 4.2.1 Neutron Fluence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      4-4 4.2.1.1 Summary of Technical Information in the Application . . . . . .                              4-4 4.2.1.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      4-5 4.2.1.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .            4-5 x
 
4.2.1.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 4.2.2 Upper Shelf Energy Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 4.2.2.1 Summary of Technical Information in the Application . . . . . . 4-6 4.2.2.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 4.2.2.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8 4.2.2.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8 4.2.3 Pressurized Thermal Shock Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8 4.2.3.1 Summary of Technical Information in the Application . . . . . . 4-8 4.2.3.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-9 4.2.3.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11 4.2.3.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11 4.2.4 Operating Pressure-Temperature Limits Analysis . . . . . . . . . . . . . . . 4-11 4.2.4.1 Summary of Technical Information in the Application . . . . . 4-11 4.2.4.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12 4.2.4.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14 4.2.4.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14 4.2.5 Low-Temperature Overpressure Limits Analysis . . . . . . . . . . . . . . . . 4-14 4.2.5.1 Summary of Technical Information in the Application . . . . . 4-14 4.2.5.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-15 4.2.5.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16 4.2.5.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16 4.3 Metal Fatigue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16 4.3.1 Explicit Fatigue Analyses (NSSS Components) . . . . . . . . . . . . . . . . . 4-17 4.3.1.1 Reactor Vessel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17 4.3.1.2 Reactor Vessel Internals . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20 4.3.1.3 Control Rod Drive Mechanism . . . . . . . . . . . . . . . . . . . . . . . 4-20 4.3.1.4 Reactor Coolant Pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21 4.3.1.5 Steam Generators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-22 4.3.1.6 Pressurizer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25 4.3.1.7 Reactor Coolant Pressure Boundary Piping (ASME Class 1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-28 4.3.2 Implicit Fatigue Analysis (ASME Class 2, Class 3, and ANSI B31.1 Piping) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31 4.3.2.1 ASME Class 2 and 3 Piping . . . . . . . . . . . . . . . . . . . . . . . . . 4-31 4.3.2.2 ANSI B31.1 Piping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-33 4.3.3 Environmentally-Assisted Fatigue Analysis . . . . . . . . . . . . . . . . . . . . 4-38 4.3.3.1 Summary of Technical Information in the Application . . . . . 4-38 4.3.3.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-39 4.3.3.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-41 4.3.3.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-42 4.3.4 RCS Loop Piping Leak-Before-Break Analysis . . . . . . . . . . . . . . . . . . 4-42 4.3.4.1 Summary of Technical Information in the Application . . . . . 4-42 4.3.4.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-43 4.3.4.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-44 4.3.4.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-44 4.3.5 Cyclic Loads That Do Not Relate to RCS Transients . . . . . . . . . . . . . 4-44 4.3.5.1 Primary Sample Lines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-44 4.3.5.2 Steam Generator Blowdown Lines . . . . . . . . . . . . . . . . . . . 4-46 4.4 Environmental Qualification of Electrical Equipment . . . . . . . . . . . . . . . . . . . . . 4-48 xi
 
4.4.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 4-48 4.4.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-49 4.4.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-49 4.4.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-49 4.5  Concrete Containment Tendon Prestress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50 4.5.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 4-50 4.5.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50 4.5.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50 4.5.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50 4.6  Containment Liner Plate, Metal, Metal Containments, and Penetrations Fatigue Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-50 4.6.1 Containment Mechanical Penetration Bellows Fatigue . . . . . . . . . . . . 4-50 4.6.1.1 Mechanical Penetration Bellows - Valve Chambers . . . . . . . 4-50 4.6.1.2 Mechanical Penetration Bellows - Fuel Transfer Tube Bellows Expansion Joint . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-52 4.7  Other Plant-Specific Time-Limited Aging Analyses . . . . . . . . . . . . . . . . . . . . . . 4-53 4.7.1 Turbine Rotor Missile Generation Analysis . . . . . . . . . . . . . . . . . . . . . 4-53 4.7.1.1 Summary of Technical Information in the Application . . . . . 4-53 4.7.1.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-54 4.7.1.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-55 4.7.1.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-55 4.7.2 Crane Cyclic Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-55 4.7.2.1 Polar Crane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-56 4.7.2.2 Jib Cranes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-58 4.7.2.3 Reactor Cavity Manipulator Crane . . . . . . . . . . . . . . . . . . . . 4-59 4.7.2.4 Fuel Cask Handling Crane . . . . . . . . . . . . . . . . . . . . . . . . . . 4-61 4.7.2.5 Fuel Handling Bridge Crane . . . . . . . . . . . . . . . . . . . . . . . . 4-63 4.7.2.6 Fuel Handling Building Auxiliary Crane . . . . . . . . . . . . . . . . 4-65 4.7.3 Main and Auxiliary Reservoir Sedimentation Analyses . . . . . . . . . . . 4-66 4.7.3.1 Summary of Technical Information in the Application . . . . . 4-66 4.7.3.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-67 4.7.3.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-67 4.7.3.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-68 4.7.4 High-Energy Line Break Location Postulation Based on Fatigue Cumulative Usage Factor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-68 4.7.4.1 Summary of Technical Information in the Application . . . . . 4-68 4.7.4.2 Staff Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-69 4.7.4.3 FSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-71 4.7.4.4 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-71 4.8  Conclusion for TLAAs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-71 Review by the Advisory Committee on Reactor Safeguards . . . . . . . . . . . . . . . . . . . . . . . . 5-73 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 Appendices Appendix A: Commitments for License Renewal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 xii
 
Appendix B: Chronology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1 Appendix C: Principal Contributors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1 Appendix D: References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1 Tables Table 1.4-1 Current Interim Staff Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-7 Table 2.3.3.31-1 Component/Commodity Locations in License Renewal Application . . . . 2-107 Table 2.3.3.31-2 Component/Commodity Locations in License Renewal Application . . . . 2-115 Table 2.3.3.31-6 Component/Commodity Justification for Exclusion . . . . . . . . . . . . . . . . 2-123 Table 3.0.3-1 HNP Aging Management Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7 Table 3.0.3.1.5-1 Aging Effects and Inspection Methods Within the Scope of the One-Time Inspection Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-25 Table 3.1-1 Staff Evaluation for Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System Components in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . 3-170 Table 3.2-1 Staff Evaluation for Engineered Safety Features System Components in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-244 Table 3.3-1 Staff Evaluation for Auxiliary System Components in the GALL Report . . . . 3-281 Table 3.4-1 Staff Evaluation for Steam and Power Conversion Systems Components in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-422 Table 3.5-1 Staff Evaluation for Containments, Structures, and Supports Components in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-480 Table 3.6-1 Staff Evaluation for Electrical and Instrumentation and Controls in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-570 xiii
 
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ABBREVIATIONS ACI          American Concrete Institute ACRS        Advisory Committee on Reactor Safeguards ADAMS        Agencywide Document Access and Management System AERM        aging effect requiring management AFW          auxiliary feedwater AMP          aging management program AMR          aging management review AMSAC        ATWS mitigating system actuation circuitry ANSI        American National Standards Institute ART          adjusted reference temperature ASCE        American Society of Civil Engineers ASME        American Society of Mechanical Engineers ASTM        American Society for Testing and Materials ATWS        anticipated transient without scram BMV          bare metal visual BOP          balance of plant BTP          Branch Technical Position BTRS        boron thermal regeneration system BWR          boiling water reactor CASS        cast austenitic stainless steel CCW          component cooling water CFR          Code of Federal Regulations CI          confirmatory item CIV          containment isolation valve CLB          current licensing basis CMAA        Crane Manufacturers Association of America CP&L        Carolina Power & Light Company, a Progress Energy Company CRDM control rod drive mechanism CSI          charging and safety injection CSIP        charging and safety injection pump CSS          containment spray system CST          condensate storage tank CTMU        cooling tower makeup CUF          cumulative usage factor CVCS        chemical and volume control system CVUSE        upper shelf energy determined by charpy v-notch test results CWS          circulating water system DBA          design basis accident DBD          design basis document DBE          design basis event DEH          digital-electric hydraulic xv
 
ECCS  emergency core cooling system EDB  (PassPort) equipment database EDG  emergency diesel generator EFPY  effective full-power year EOL  end of life EPRI  Electric Power Research Institute EQ    environmental qualification EQML  environmental qualification master list ESF  engineered safety feature ESW  emergency service water FAC  flow-accelerated corrosion FERC  Federal Energy Regulatory Commission FHB  fuel handling building FR    Federal Register FSAR  final safety analysis report ft. foot, feet GALL  Generic Aging Lessons Learned Report GDC  general design criteria or general design criterion GEIS  Generic Environmental Impact Statement GL    generic letter GSI  generic safety issue HEPA  high efficiency particulate air HHSI  high head safety injection HNP  Shearon Harris Nuclear Power Plant HVAC  heating, ventilation, and air conditioning I&C  instrumentation and controls IASCC irradiation assisted stress corrosion cracking IEEE  Institute of Electrical and Electronics Engineers IGSCC intergranular stress corrosion cracking IN    Information Notice INPO  Institute of Nuclear Power Operations IPA  integrated plant assessment ISG  interim staff guidance ISI  inservice inspection KV    kilovolt LBB  leak-before-break LHSI  low head safety injection LOCA  loss of coolant accident LRA  license renewal application LRBD  license renewal boundary drawing LTOP  low-temperature over-pressure protection xvi
 
MEB  metal enclosed bus MeV  million electron volts MFIV  main feedwater isolation valve MIC  microbiologically influenced corrosion MSLB  main steam line break MSR  moisture separator reheater N/A  not applicable NCR  nuclear condition reports NDE  nondestructive examination NEI  Nuclear Energy Institute NESC  National Electrical Safety Code NFPA  National Fire Protection Association NPS  nominal pipe size NRC  Nuclear Regulatory Commission NSSS  nuclear steam supply system NSW  normal service water NUREG designation of publications prepared by the NRC staff OI    open item OM    operation and maintenance OPB  outside the power block PASS  post-accident sampling system pH    concentration of hydrogen ions PMID  preventive maintenance identification number PORV  power-operated relief valve PRT  pressurizer relief tank PSI  passive safety injection PSS  primary sampling system P-T  pressure-temperature PTS  pressurized thermal shock PVC  polyvinyl chloride PWR  pressurized water reactor PWSCC primary water stress corrosion cracking QA    quality assurance RAB  reactor auxiliary building RAI  request for additional information RCCA  rod cluster control assembly RCDT  reactor coolant drain tank RCP  reactor coolant pump RCPB  reactor coolant pressure boundary RCS  reactor coolant system RFO  refueling outage RG    Regulatory Guide RHR  residual heat removal xvii
 
RPV    reactor pressure vessel RPVH  reactor pressure vessel head RTNDT  reference temperature nil ductility transition RTPTS  reference temperature for pressurized thermal shock RVI    reactor vessel internals RVLIS  reactor vessel level indicating system RWST  refueling water storage tank SBO    station blackout SC    structure and component SCC    stress-corrosion cracking SER    safety evaluation report SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants SSC    system, structure, and component SSE    safe-shutdown earthquake SUT    startup transformer TAC    technical assignment control (internal NRC work management tool)
TLAA  time-limited aging analysis TS    technical specification UHS    ultimate heat sink US    United States USE    upper-shelf energy UT    ultrasonic testing VCT    volume control tank VHP    vessel head penetration WCAP  Westinghouse Commercial Atomic Power WOG    Westinghouse Owners Group WPB    waste processing building WPS    waste processing system xviii
 
SECTION 1 INTRODUCTION AND GENERAL DISCUSSION 1.1 Introduction This document is a safety evaluation report (SER) on the license renewal application (LRA) for Shearon Harris Nuclear Power Plant (HNP), Unit 1, as filed by the Carolina Power & Light Company (CP&L or the applicant). By letter dated November 16, 2006, CP&L submitted its application to the US Nuclear Regulatory Commission (NRC) for renewal of the HNP operating license for an additional 20 years. The NRC staff (the staff) prepared this report to summarize the results of its safety review of the LRA for compliance with Title 10, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, of the Code of Federal Regulations (10 CFR Part 54). The NRC project manager for the license renewal review is Maurice Heath. Mr. Heath may be contacted by telephone at 301-415-3137 or by electronic mail at MLH5@nrc.gov. Alternatively, written correspondence may be sent to the following address:
Division of License Renewal US Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Maurice Heath, Mail Stop 011-F1 In its November 14, 2006, submission letter, the applicant requested renewal of the operating license issued under Section 103 (Operating License No. NPF-63) of the Atomic Energy Act of 1954, as amended, for Unit 1 for a period of 20 years beyond the current expiration at midnight October 24, 2026, for Unit 1. HNP is located approximately 16 miles southwest of Raleigh, NC.,
and 15 miles northeast of Sanford, NC. The NRC issued the construction permit for Unit 1 on January 27, 1978, and operating license on January 12, 1987. Unit 1 is of a dry ambient pressurized water reactor design. Westinghouse Three-Loop supplied the nuclear steam supply system and Daniel International originally designed and constructed the balance of the plant with the assistance of its agent, Ebasco. The Unit 1 licensed power output is 2900 megawatt thermal with a gross electrical output of approximately 900 megawatt electric. The final safety analysis report (FSAR) shows details of the plant and the site.
The license renewal process consists of two concurrent reviews, a technical review of safety issues and an environmental review. The NRC regulations in 10 CFR Part 54 and 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, respectively, set forth requirements for these reviews. The safety review for the HNP license renewal is based on the applicants LRA and on its responses to the staffs requests for additional information. The applicant supplemented the LRA and provided clarifications through its responses to the staffs requests for additional information (RAIs) in audits, meetings, and docketed correspondence. Unless otherwise noted, the staff reviewed and considered information submitted through February 19, 2008. The staff reviewed information received after that date depending on the stage of the safety review and the volume and complexity of the information. The public may view the LRA and all pertinent information and materials, including the FSAR, at the NRC Public Document Room, located on the first floor 1-1
 
of One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738 (301-415-4737 / 800-397-4209), at Eva. H. Perry Library, 2100 Shepherd's Vineyard Drive, Apex, NC 27502, and at West Regional Library, 4000 Louis Stephens Rd, Cary, NC 27519. In addition, the public may find the LRA, as well as materials related to the license renewal review, on the NRC Web site at http://www.nrc.gov.
This SER summarizes the results of the staffs safety review of the LRA and describes the technical details considered in evaluating the safety aspects of the units proposed operation for an additional 20 years beyond the term of the current operating license. The staff reviewed the LRA in accordance with NRC regulations and the guidance in the US NRC NUREG-1800, Revision 1, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated September 2005.
SER Sections 2 through 4 address the staffs evaluation of license renewal issues considered during the review of the application. SER Section 5 is reserved for the report of the Advisory Committee on Reactor Safeguards (ACRS). The conclusions of this SER are in Section 6.
SER Appendix A is a table showing the applicants commitments for renewal of the operating license. SER Appendix B is a chronology of the principal correspondence between the staff and the applicant regarding the LRA review. SER Appendix C is a list of principal contributors to the SER and Appendix D is a bibliography of the references in support of the staffs review.
In accordance with 10 CFR Part 51, the staff prepared a draft plant-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS). This supplement discusses the environmental considerations for license renewal for Unit 1. The staff issued draft, plant-specific GEIS Supplement 33, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 3 Regarding Shearon Harris Nuclear Power Plant, Unit 1, Draft Report for Comment, on December 11, 2007.
1.2 License Renewal Background Pursuant to the Atomic Energy Act of 1954, as amended, and NRC regulations, operating licenses for commercial power reactors are issued for 40 years and can be renewed for up to 20 additional years. The original 40-year license term was selected based on economic and antitrust considerations rather than on technical limitations; however, some individual plant and equipment designs may have been engineered for an expected 40-year service life.
In 1982, the staff anticipated interest in license renewal and held a workshop on nuclear power plant aging. This workshop led the NRC to establish a comprehensive program plan for nuclear plant aging research. From the results of that research, a technical review group concluded that many aging phenomena are readily manageable and pose no technical issues precluding life extension for nuclear power plants. In 1986, the staff published a request for comment on a policy statement that would address major policy, technical, and procedural issues related to license renewal for nuclear power plants.
In 1991, the staff published 10 CFR Part 54, the License Renewal Rule (Volume 56, page 64943, of the Federal Register (56 FR 64943), dated December 13, 1991). The staff 1-2
 
participated in an industry-sponsored demonstration program to apply 10 CFR Part 54 to a pilot plant and to gain the experience necessary to develop implementation guidance. To establish a scope of review for license renewal, 10 CFR Part 54 defined age-related degradation unique to license renewal; however, during the demonstration program, the staff found that adverse aging effects on plant systems and components are managed during the period of initial license and that the scope of the review did not allow sufficient credit for management programs, particularly the implementation of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, which regulates management of plant-aging phenomena. As a result of this finding, the staff amended 10 CFR Part 54 in 1995.
As published May 8, 1995, in 60 FR 22461, amended 10 CFR Part 54 establishes a regulatory process that is simpler, more stable, and more predictable than the previous 10 CFR Part 54. In particular, as amended, 10 CFR Part 54 focuses on the management of adverse aging effects rather than on the identification of age-related degradation unique to license renewal. The staff made these rule changes to ensure that important systems, structures, and components (SSCs) will continue to perform their intended functions during the period of extended operation. In addition, the amended 10 CFR Part 54 clarifies and simplifies the integrated plant assessment process to be consistent with the revised focus on passive, long-lived structures and components (SCs).
Concurrent with these initiatives, the staff pursued a separate rulemaking effort (61 FR 28467, June 5, 1996) and amended 10 CFR Part 51 to focus the scope of the review of environmental impacts of license renewal in order to fulfill NRC responsibilities under the National Environmental Policy Act of 1969.
1.2.1 Safety Review License renewal requirements for power reactors are based on two key principles:
(1)  The regulatory process is adequate to ensure that the licensing bases of all currently operating plants maintain an acceptable level of safety with the possible exceptions of the detrimental aging effects on the functions of certain SSCs, as well as a few other safety-related issues, during the period of extended operation.
(2)  The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.
In implementing these two principles, 10 CFR 54.4, Scope, defines the scope of license renewal as including those SSCs that (1) are safety-related, (2) whose failure could affect safety-related functions, or (3) are relied on to demonstrate compliance with the NRCs regulations for fire protection, environmental qualification (EQ), pressurized thermal shock (PTS), anticipated transient without scram (ATWS), and station blackout (SBO).
Pursuant to 10 CFR 54.21(a), a license renewal applicant must review all SSCs within the scope of 10 CFR Part 54 to identify SCs subject to an aging management review (AMR). Those SCs subject to an AMR perform an intended function without moving parts or without change in configuration or properties and are not subject to replacement based on a qualified life or specified time period. Pursuant to 10 CFR 54.21(a), a license renewal applicant must demonstrate that the aging effects will be managed such that the intended function(s) of those SCs will be maintained consistent with the current licensing basis (CLB) for the period of 1-3
 
extended operation. However, active equipment is considered to be adequately monitored and maintained by existing programs. In other words, detrimental aging effects that may affect active equipment can be readily identified and corrected through routine surveillance, performance monitoring, and maintenance. Surveillance and maintenance programs for active equipment, as well as other maintenance aspects of plant design and licensing basis, are required throughout the period of extended operation.
Pursuant to 10 CFR 54.21(d), the LRA is required to include a FSAR supplement with a summary description of the applicants programs and activities for managing aging effects and an evaluation of time-limited aging analyses (TLAAs) for the period of extended operation.
License renewal also requires TLAA identification and updating. During the plant design phase, certain assumptions about the length of time the plant can operate are incorporated into design calculations for several plant SSCs. In accordance with 10 CFR 54.21(c)(1), the applicant must either show that these calculations will remain valid for the period of extended operation, project the analyses to the end of the period of extended operation, or demonstrate that the aging effects on these SSCs will be adequately managed for the period of extended operation.
In 2005, the NRC revised Regulatory Guide (RG) 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses. This RG endorses Nuclear Energy Institute (NEI) 95-10, Revision 6, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, issued in June 2005. NEI 95-10 details an acceptable method of implementing 10 CFR Part 54. The staff also used the SRP-LR to review the LRA.
In the LRA, the applicant fully utilized the process defined in NUREG-1801, Revision 1, Generic Aging Lessons Learned (GALL) Report, dated September 2005. The GALL Report summarizes staff-approved aging management programs (AMPs) for many SCs subject to an AMR. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources for LRA review can be greatly reduced, improving the efficiency and effectiveness of the license renewal review process. The GALL Report summarizes the aging management evaluations, programs, and activities credited for managing aging for most of the SCs used throughout the industry. The report is also a quick reference for both applicants and staff reviewers to AMPs and activities that can manage aging adequately during the period of extended operation.
1.2.2 Environmental Review Part 51 of 10 CFR contains regulations on environmental protection regulations. In December 1996, the staff revised the environmental protection regulations to facilitate the environmental review for license renewal. The staff prepared the GEIS to document its evaluation of possible environmental impacts associated with nuclear power plant license renewals. For certain types of environmental impacts, the GEIS contains generic findings that apply to all nuclear power plants and are codified in Appendix B, Environmental Effect of Renewing the Operating License of a Nuclear Power Plant, to Subpart A, National Environmental Policy Act - Regulations Implementing Section 102(2), of 10 CFR Part 51.
Pursuant to 10 CFR 51.53(c)(3)(i), a license renewal applicant may incorporate these generic findings in its environmental report. In accordance with 10 CFR 51.53(c)(3)(ii), an environmental 1-4
 
report also must include analyses of environmental impacts that must be evaluated on a plant-specific basis (i.e., Category 2 issues).
In accordance with the National Environmental Policy Act of 1969 and 10 CFR Part 51, the staff reviewed the plant-specific environmental impacts of license renewal, including whether there was new and significant information not considered in the GEIS. As part of its scoping process, the staff held a public meeting on April 18, 2007, in Apex, NC, to identify plant-specific environmental issues. The draft, plant-specific GEIS Supplement 33 documents the results of the environmental review and makes a preliminary recommendation as to the license renewal action. The staff held another public meeting on January 30, 2008, in Apex, NC, to discuss draft, plant-specific GEIS Supplement 33. After considering comments on the draft, the staff will prepare and publish a final plant-specific supplement separately from this report.
1.3 Principal Review Matters Part 54 of 10 CFR describes the requirements for renewal of operating licenses for nuclear power plants. The staffs technical review of the LRA was in accordance with NRC guidance and 10 CFR Part 54 requirements. Section 54.29, Standards for Issuance of a Renewed License, of 10 CFR sets forth the license renewal standards. This SER describes the results of the staffs safety review.
Pursuant to 10 CFR 54.19(a), the NRC requires a license renewal applicant to submit general information, which the applicant provided in LRA Section 1. The staff reviewed LRA Section 1 and finds that the applicant has submitted the required information.
Pursuant to 10 CFR 54.19(b), the NRC requires that the LRA include conforming changes to the standard indemnity agreement, 10 CFR 140.92, Appendix B, to account for the expiration term of the proposed renewed license. On this issue, the applicant stated in the LRA:
The agreement shall terminate at the time of expiration of that license specified in Item 3 of the Attachment to the agreement. Item 3 of the Attachment to the indemnity agreement, as amended, lists operating license NPF-63. The Company requests that conforming changes be made to the indemnity agreement, and/or the Attachment to the agreement, as required, to specify the extension of the agreement until the expiration date of the renewed HNP operating license as sought in this application.
The staff intends to maintain the original license number upon issuance of the renewed license, if approved. Therefore, conforming changes to the indemnity agreement need not be made and the 10 CFR 54.19(b) requirements have been met.
Pursuant to 10 CFR 54.21, Contents of Application - Technical Information, the NRC requires that the LRA contain (a) an integrated plant assessment, (b) a description of any CLB changes during the staffs review of the LRA, (c) an evaluation of TLAAs, and (d) an FSAR supplement.
LRA Sections 3 and 4 and Appendix B address the license renewal requirements of 10 CFR 54.21(a), (b), and (c). LRA Appendix A satisfies the license renewal requirements of 10 CFR 54.21(d).
Pursuant to 10 CFR 54.21(b), the NRC requires that, each year following submission of the 1-5
 
LRA and at least three months before the scheduled completion of the staffs review, the applicant submit an LRA amendment identifying any CLB changes to the facility that affect the contents of the LRA, including the FSAR supplement. By letter dated November 5, 2007, the applicant submitted an LRA update which summarizes the CLB changes that have occurred during the staffs review of the LRA. This submission satisfies 10 CFR 54.21(b) requirements and is still under staff review.
Pursuant to 10 CFR 54.22, Contents of Application - Technical Specifications, the NRC requires that the LRA include changes or additions to the technical specifications (TSs) that are necessary to manage aging effects during the period of extended operation. In LRA Appendix D, the applicant stated that it had not identified any TS changes necessary for issuance of the renewed HNP operating license. This statement adequately addresses the 10 CFR 54.22 requirement.
The staff evaluated the technical information required by 10 CFR 54.21 and 10 CFR 54.22 in accordance with NRC regulations and SRP-LR guidance. SER Sections 2, 3, and 4 document the staffs evaluation of the LRA technical information.
As required by 10 CFR 54.25, Report of the Advisory Committee on Reactor Safeguards, the ACRS will issue a report documenting its evaluation of the staffs LRA review and SER. SER Section 5 is reserved for the ACRS report when it is issued. SER Section 6 documents the findings required by 10 CFR 54.29.
1.4 Interim Staff Guidance License renewal is a living program. The staff, industry, and other interested stakeholders gain experience and develop lessons learned with each renewed license. The lessons learned address the staffs performance goals of maintaining safety, improving effectiveness and efficiency, reducing regulatory burden, and increasing public confidence. Interim staff guidance (ISG) is documented for use by the staff, industry, and other interested stakeholders until incorporated into such license renewal guidance documents as the SRP-LR and GALL Report.
Table 1.4-1 shows the current set of ISGs, as well as the SER sections in which the staff addresses them.
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Table 1.4-1 Current Interim Staff Guidance ISG Issue                            Purpose                          SER Section (Approved ISG Number)
Nickel-alloy components in the      Cracking of nickel-alloy            3.0.3.2.3 reactor coolant pressure boundary    components in the reactor pressure (LR-ISG-19B)                        boundary.
ISG under development. NEI and EPRI-MRP will develop an augmented inspection program for GALL AMP XI.M11-B. This AMP will not be completed until the NRC approves an augmented inspection program for nickel-alloy base metal components and welds as proposed by EPRI-MRP.
Corrosion of drywell shell in Mark I To address concerns related to      N/A containments                        corrosion of drywell shell in Mark I (LR-ISG-2006-01)                    containments.
1.5 Summary of Open Items As a result of its review of the LRA, including additional information submitted through February 19, 2008, the staff identified the following open item (OI). An item is considered open if, in the staffs judgement, it does not meet all applicable regulatory requirements at the time of the issuance of this SER. The staff has assigned a unique identifying number to each OI OI-2.2: (Section 2.2 Plant Level Scoping Results)
In LRA Section 2.3.4.6, Feedwater System, the applicant did not identify the feedwater isolation function in scope for license renewal under 10 CFR 54.4 (a)(1). In Section 15.1.5 of the applicants FSAR, it states that the feedwater isolation valves and regulating valves provide a safety-related function, isolation of feedwater in the event of a main steam line break. The staffs position is that the FSAR description of the feedwater isolation and regulating valves meet the criteria defined by 10 CFR 54.4(a)(1). In response to RAI 2.1.1.2-1, the applicant stated that based on their evaluation the feedwater regulating and bypass valves, these valves do not meet the license renewal definition of safety-related as stated in 10 CFR 54.4(a)(1);
however, the components are included within the scope of license renewal for 10 CFR 54.4(a)(2). The staff found the applicants answer to RAI response 2.1.1.2-1 inconsistent with 10 CFR 54.4 (a)(1).
In RAI 2.3.4.6-2 the staff asked the applicant to further evaluate the classification of this equipment and justify their position. The applicants response, dated January 22, 2008, maintains that these valves are important to safety, but are not safety-related; therefore, they only meet the criteria of 10 CFR 54.4(a)(2). The staffs position remains that the main feedwater regulating and bypass valves, by definition, fulfill a safety-related function; therefore, they should be included in scope under 10 CFR 54.4(a)(1). In addition, the function to provide main feedwater isolation should be included in scope under 10 CFR 54.4(a)(1) for Section 2.3.4.6, to include the main feedwater isolation valves and the regulating and bypass valves.
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This is open item (OI) 2.2. This is OI 2.2.
1.6 Summary of Confirmatory Items As a result of its review of the LRA, including additional information submitted through February 19, 2008, the staff identified the following confirmatory items (CIs). An item is considered confirmatory if the staff and the applicant have reached a satisfactory resolution but the applicant has not yet formally submitted the resolution. The staff has assigned a unique identifying number to each CI.
CI-3.4-1: (SER Section3.4 - Steam and Power Conversion Systems)
In LRA Section 3.4, the applicant has credited its External Surfaces Monitoring Program, in conjunction with the program enhancement in LRA Commitment No. 18, to manage changes in materials and cracking for elastomeric piping, piping components and piping elements, as well as thermoplastic piping, piping components and piping elements.
The staff has determined that this enhancement in Commitment No. 18: (1) does not specifically reference elastomeric or thermoplastic materials, (2) is made on a matter that is not specifically addressed within the scope of GALL AMP XI.M36, "External Surfaces Monitoring,"
and (3) does not provide any provision that the specific inspection method and acceptance criteria for future inspections of elastomeric and thermoplastic components under the External Surfaces Monitoring Program would be submitted for NRC review and approval. The staff raised these issues in a RAI letter dated January 7, 2008.
The staff reviewed the applicant's responses dated January 17, 2008 and found that the responses did not address all elastomeric and thermoplastic components. The staff was not satisfied with the applicants response. The staff discussed the issue with the applicant on a conference call and it was agreed that the elastomeric and thermoplastic (with the exception of the condensate storage tank diaphram) components will be placed in a Preventive Maintenance Program with periodic replacement. The condensate storage tank diaphram will be added to the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The applicant agreed to provide this in a docketed correspondence. This is CI 3.4-1.
CI-4.3: (SER Section 4.3 - Metal Fatigue)
The staff requested the applicant to clarify the apparent discrepancy with two different CUF values for the pressurizer lower head. The staff reviewed the applicant's response dated January 17, 2008, and found that the applicant clarified how the design basis transients for the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle were redefined based on changes that were made to the plant design. The applicant also stated that, although the plant operational transients had been redefined, the design specification had not been updated. The staff position is that an ASME design report should follow the design specification and that if design conditions change, an updated design specification should reflect the change(s).
Also, the staff requests that FSAR supplement Section A.1.2.2.10 be updated to reflect that the applicant is crediting its Reactor Coolant Pressure Boundary Metal Fatigue Program as the 1-8
 
basis for accepting its TLAA on environmentally-assisted metal fatigue, as assessed relative to the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle, in accordance with 10 CFR 54.21(c)(1)(iii), in that the effects of aging will be managed for the period of extended operation.
The staff discussed the issue with the applicant on a teleconference and it was agreed that the applicant will add a new commitment to update, prior to the period of extended operation, the piping design specifications to reflect design basis transients and provide an FSAR supplement to address the HNP surge line, charging nozzle, and pressurizer lower head and surge nozzle, in accordance with 10 CFR 54.21(c)(1)(iii). This is CI 4.3.
1.7 Summary of Proposed License Conditions Following the staffs review of the LRA, including subsequent information and clarifications from the applicant, the staff identified three proposed license conditions.
The first license condition requires the applicant to include the FSAR supplement required by 10 CFR 54.21(d) in the next FSAR update required by 10 CFR 50.71(e) following the issuance of the renewed license.
The second license condition requires future activities described in the FSAR supplement to be completed prior to the period of extended operation.
The third license condition requires that all capsules in the reactor vessel that are removed and tested meet the requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the staff prior to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the staff, as required by 10 CFR Part 50, Appendix H.
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SECTION 2 STRUCTURES AND COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW 2.1 Scoping and Screening Methodology 2.1.1 Introduction Title 10, Section 54.21, Contents of Application Technical Information, of the Code of Federal Regulations (10 CFR Part 54.21) requires for each license renewal application (LRA) an integrated plant assessment (IPA) listing those structures and components (SCs) subject to an aging management review (AMR) from all of the systems, structures, and components (SSCs) within the scope of license renewal.
LRA Section 2.1, Scoping and Screening Methodology, describes the methodology for identifying SSCs at the Shearon Harris Nuclear Power Plant (HNP) Unit 1 within the scope of license renewal and SCs subject to an AMR. The staff reviewed the Carolina Power & Light Company (CP&L or the applicant) scoping and screening methodology to determine whether it meets the scoping requirements of 10 CFR 54.4(a) and the screening requirements of 10 CFR 54.21.
In developing the scoping and screening methodology for the LRA, the applicant considered the requirements of 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants (the Rule), statements of consideration on the Rule, and the guidance of Nuclear Energy Institute (NEI) 95-10, Revision 6, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, dated June 2005. The applicant also considered the correspondence between the staff, other applicants.
2.1.2 Summary of Technical Information in the Application LRA Sections 2 and 3 state the technical information required by 10 CFR 54.4 and 54.21(a).
LRA Section 2.1 describes the process for identifying SSCs meeting the license renewal scoping criteria of 10 CFR 54.4(a) and the process for identifying SCs subject to an AMR, as required by 10 CFR 54.21(a)(1). The applicant provided the results of the process for identifying such SCs in the following LRA sections:
* Section 2.2, Plant Level Scoping Results
* Section 2.3, Scoping and Screening Results: Mechanical
* Section 2.4, Scoping and Screening Results: Structures
* Section 2.5, Scoping and Screening Results: Electrical Components 2-1
 
LRA Section 3, Aging Management Review Results, states the applicants aging management results in the following LRA sections:
* Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant Systems
* Section 3.2, Aging Management of Engineered Safety Features
* Section 3.3, Aging Management of Auxiliary Systems
* Section 3.4, Aging Management of Steam and Power Conversion System
* Section 3.5, Aging Management of Containment, Structures, and Component Supports
* Section 3.6, Aging Management of Electrical and Instrumentation and Controls LRA Section 4, Time-Limited Aging Analyses, states the applicants evaluation of time-limited aging analyses.
2.1.3 Scoping and Screening Program Review The staff evaluated the LRA scoping and screening methodology in accordance with the guidance in Section 2.1, Scoping and Screening Methodology, of United States (US) Nuclear Regulatory Commission (NRC) NUREG-1800, Revision 1, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated September 2005.
The following regulations form the basis for the acceptance criteria for the scoping and screening methodology review:
* 10 CFR 54.4(a) as to identification of plant SSCs within the scope of the Rule
* 10 CFR 54.4(b), as to identification of the intended functions of plant systems and structures within the scope of the Rule
* 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(2) as to the methods utilized by the applicant to identify plant SCs subject to an AMR With the guidance of the corresponding SRP-LR sections, the staff reviewed, as part of the applicants scoping and screening methodology, the activities described in the following sections of the LRA:
* Section 2.1 to ensure that the applicant described a process for identifying SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a).
* Section 2.2 to ensure that the applicant described a process for identifying SCs subject to an AMR in accordance with 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(2).
The staff conducted a scoping and screening methodology audit at HNP in North Carolina during the week of April 23-27, 2007. The audit focused on whether the applicant had developed and implemented adequate guidance for the scoping and screening of SSCs by the methodologies in the LRA and the requirements of the Rule. The staff reviewed implementation of the applicants corporate level license renewal guidelines and procedures, and also HNP project level license renewal basis documents (calculations) describing the applicants scoping 2-2
 
and screening methodology. The staff discussed with the applicant details of the implementation and control of the license renewal program and reviewed administrative control documentation and selected design documentation used by the applicant during the scoping and screening process. The staff reviewed the applicants processes for quality assurance (QA) for development of the LRA. The staff reviewed the quality attributes of the applicants aging management program (AMP) activities described in LRA Appendix A, Final Safety Analysis Report Supplement, and LRA Appendix B, Aging Management Programs and the training and qualification of the LRA development team. The staff reviewed scoping and screening results reports for the auxiliary feedwater (AFW) system and post-accident sampling system (PASS) and emergency service water (ESW) and cooling tower makeup (CTMU) intake structure for the applicant's appropriate implementation of methodology outlined in the administrative controls and for results consistent with the current licensing basis (CLB) documentation.
2.1.3.1 Implementation Procedures and Documentation Sources for Scoping and Screening The staff reviewed the applicant's scoping and screening implementation procedures as documented in the Audit Report, dated July 17, 2007, to verify whether the process for identifying SCs subject to an AMR was consistent with the LRA and the SRP-LR. Additionally, the staff reviewed the scope of CLB documentation sources and the applicant's process for appropriate consideration of CLB commitments and for adequate implementation of the procedural guidance during the scoping and screening process.
2.1.3.1.1 Summary of Technical Information in the Application In LRA Section 2.1.1, the applicant addressed the following information sources for the license renewal scoping and screening process:
* CLB documents
* final safety analysis report (FSAR)
* design basis documents (DBDs)
* docketed correspondence
* PassPort equipment database (PassPort EDB)
* maintenance rule database
* plant operating procedures
* system descriptions
* walkdowns
* safety evaluation reports (SERs)
* technical specifications
* topical evaluation reports (calculations) for 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3).
* plant piping & instrumentation diagrams (P&IDs)
The license renewal boundary drawings (LRBDs) show the systems within the scope of license renewal highlighted in color.
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2.1.3.1.2 Staff Evaluation Scoping and Screening Implementation Procedures. The staff reviewed the following scoping and screening methodology implementation procedures:
The staff reviewed the applicants scoping and screening corporate level license renewal implementing guidelines and procedures, including the HNP license renewal project scoping and screening calculations, technical evaluation reports, AMR reports, LRBDs, and other reference documents as documented in the Audit Report, to ensure the guidance was consistent with the requirements of the license renewal rule, 10 CFR 54.4.
The staff found the overall process for implementing 10 CFR Part 54 requirements included in the applicants license renewal implementing procedures and calculations. The staff found guidance for identifying plant SSCs within the scope of the Rule, including guidelines for identifying SC component types within the scope of license renewal subject to an AMR, in the HNP project scoping and screening calculations. The review of these procedures focused on the consistency of the detailed procedural guidance with information in the LRA reflecting implementation of staff positions in the SRP-LR, interim staff guidance documents, and responses to requests for additional information (RAI) dated July 10, 2007.
After reviewing the LRA and supporting documentation, the staff finds LRA Section 2.1 consistent with the scoping and screening methodology instructions. The applicants methodology has sufficiently detailed guidance for the scoping and screening implementation process followed in the LRA.
Sources of Current Licensing Basis Information.
For HNP, system safety functions are stated in the FSAR, system descriptions, DBDs, the maintenance rule SSC basis documents for each system, and technical specifications. The staff considered the safety objectives in the FSAR system descriptions and identified objectives meeting the safety-related criteria of 10 CFR 54.4(a)(1) as system intended functions.
The staff reviewed the scope and depth of the applicant's CLB information to verify whether the applicants methodology had identified all SSCs within the scope of license renewal as well as component types requiring AMRs. As defined in 10 CFR 54.3(a), the CLB applies NRC requirements, written applicant commitments for compliance with, and operation within, applicable NRC requirements, and plant-specific design bases docketed and in effect. The CLB includes NRC regulations, orders, license conditions, exemptions, technical specifications, design-basis information in the most recent FSAR, and applicant commitments made in docketed correspondence like applicant responses to NRC bulletins, generic letters, and enforcement actions as well as commitments in NRC safety evaluations or applicant event reports.
During the audit, the staff reviewed the applicant's information sources and samples of such information, including the FSAR, PassPort EDB database, DBDs, technical evaluation reports, and LRBDs that were utilized when determining whether a system, structure or component falls within the scope of 10 CFR 54.4(a)(1), (a)(2), and (a)(3) criteria. The applicants license renewal project procedures and calculations stipulate the use of the above referenced CLB documents for scoping determination. Other reference documents that were utilized in scoping 2-4
 
determination included; the site technical specifications, safety evaluation reports, NRC orders, maintenance rule database, bases and calculations. The reference documents or databases which are not official CLB documents were used for scoping determination; however, their scoping information was confirmed by reference to CLB documents.
In addition, the staff reviewed the applicants calculations utilized to support identification of SSCs relied upon to demonstrate compliance with the safety-related (a)(1) criteria, nonsafety-related (a)(2) criteria, and the five regulated events referenced in 10 CFR 54.4(a)(3) criteria. The intended functions for criterion (a)(1) referenced the appropriate FSAR sections.
The bases documents identified the HNP systems and structures that comply with the (a)(2) and (a)(3)criteria. The applicants license renewal program guidelines provided a comprehensive listing of documents used to support scoping and screening evaluations. The staff found these design documentation sources to be useful for ensuring that the scope of SSCs identified by the applicant was consistent with the plant's CLB. The staff determined that LRA Section 2.1 provided a description of the CLB and related documents used during the scoping and screening process that is consistent with the requirements of 10 CFR 54.4.
The staff found the overall process for implementing 10 CFR Part 54 requirements described in the applicants project level guidelines and procedures, calculations, and AMRs was consistent with the Rule and industry guidance.
2.1.3.1.3 Conclusion Based on its review of LRA Section 2.1, the detailed scoping and screening implementation procedures, and the results from the scoping and screening audit, the staff concludes that the applicant's scoping and screening methodology considers CLB information consistently with SRP-LR and NEI 95-10 guidance and, therefore, is acceptable.
2.1.3.2 Quality Controls Applied to LRA Development 2.1.3.2.1 Staff Evaluation The staff reviewed the applicants quality controls used to ensure adequate implementation of the scoping and screening methodology described in the LRA. Although the applicant did not develop its LRA under a 10 CFR Part 50, Appendix B, QA program, it did develop its license renewal scoping and screening guidance and implementing procedures under such a program.
The staff reviewed the applicants quality control measures which include the previous experience of the applicants license renewal project personnel, evolution of the corporate level license renewal procedures, the applicants self-assessments related to license renewal, an industry peer review of the LRA, and a review of the LRA by an internal plant safety sub-committee. While developing the LRA, the applicants personnel actively participated in the NEI Task Force and on NEI License Renewal Working Groups in the civil, electrical, implementation, and mechanical areas. Other personnel experience included peer reviews of LRAs prepared by other applicants.
The applicant also evolved its corporate level license renewal procedures to enhance quality control. These procedures formed the bases for preparing the plant-specific implementing procedures used in developing the LRA. The applicant developed the procedures in 2000 and has subsequently revised them several times.
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The applicant also performed several self-assessments on its license renewal efforts from 2000 though 2006. One such assessment dated April 4, 2006, evaluated the effectiveness of the scoping and screening process for systems and structures. The staff reviewed the executive summary for this report and found that the applicant considered the assessment to be comprehensive and critical of the assessed areas. In addition, the applicant identified numerous areas for improvement and determined an appropriate scope.
As another means of quality control, the applicant subjected its LRA to review by other utilities and organizations in the nuclear power industry. The results of this review yielded numerous comments and suggestions for improving the LRA. The applicant held group discussions with the reviewers to adequately understand the nature of the comments. The applicant then used the comments and subsequent discussions to improve the quality and content of the LRA.
Additionally, the applicant subjected its LRA to an extensive review by its internal Plant Nuclear Safety Subcommittee. The members of the committee were plant personnel with expertise in the areas of engineering, maintenance, the environment, regulatory affairs, and plant operations. The staff reviewed the applicants implementing procedures used in developing the license renewal drawings submitted with the LRA. The staff found that this procedure detailed a process and established conventions sufficient to ensure consistency and quality in preparing the drawings, and for appropriately identifying the components within the scope of license renewal.
2.1.3.2.2 Conclusion Based on its review of pertinent LRA development guidance, discussion with the applicant's license renewal personnel, and review of the quality Audit Reports, the staff concludes that these QA activities add assurance that LRA development activities have been according to LRA descriptions.
2.1.3.3 Training 2.1.3.3.1 Staff Evaluation The staff reviewed the applicants training process for consistent and appropriate guidelines and methodology for the scoping and screening activities. The applicant required training for all personnel participating in the LRA development and used only sufficiently trained personnel to prepare the scoping and screening implementing procedures. Prior to participating in the scoping and screening activities, the applicant required that its personnel complete two qualification paths; one for license renewal engineering and the other for preparing and design-verifying license renewal implementing procedures.
Qualification as a license renewal engineer required completion of a corporate level program which the applicant documented in its License Renewal Engineering Training Guide. This training program requires each trainee to review and complete a number of self-study guides.
Some of the topics covered by these study guides include corporate guides and procedures, plant-specific procedures and documents, engineering support personnel qualification guides, and a license renewal study list based on previous LRA developed by the applicant. After completing each self-study guide, the trainee discussed the topic with his supervisor. The supervisor then assessed the trainees knowledge and approved of the trainees competency in 2-6
 
the particular area. The applicant documented the qualification of all its license renewal project personnel on qualification cards which required a supervisors signature for final approval.
The applicant also required personnel to complete another area of training for preparing and design-verifying license renewal implementing procedures. The applicant formed its license renewal project team in 2000. The majority of this team fulfilled this training requirement by completing the Institute of Nuclear Power Operations (INPO) accredited engineering support personnel training program. The applicant documented this training process in its Program Training Guide master document. The INPO training covered topics such as engineering, nuclear information technology, licensing and regulatory programs, license renewal, and materials and contract services. After completing the INPO training, the trainee received engineering support personnel qualification in areas such as reactor engineering, materials engineering, or the maintenance rule. In 2003, the applicant replaced the required INPO training with consolidated training requirements established at the corporate level. During LRA development, the applicants engineering support personnel also participated in ongoing training.
The staff reviewed completed qualification and training records of several of the applicant's license renewal personnel and also reviewed completed check lists. The staff made no adverse findings. Additionally, after discussions with the applicant's license renewal personnel during the audit, the staff confirmed that the applicant's personnel were knowledgeable about the license renewal process requirements and specific technical issues within their areas of responsibility.
2.1.3.3.2 Conclusion Based on discussions with the applicants license renewal personnel responsible for the scoping and screening process and review of selected documentation supporting the process, the staff concludes that the applicants personnel understood the requirements and adequately implemented the scoping and screening methodology documented in the LRA. The staff concludes that the license renewal personnel were adequately trained and qualified for license renewal activities.
2.1.3.4 Conclusion of Scoping and Screening Program Review Based on its review of LRA Section 2.1, review of the applicants detailed scoping and screening implementation procedures, discussions with the applicants LRA personnel, and review of the scoping and screening audit results, the staff concludes that the applicants scoping and screening program is consistent with SRP-LR guidance and, therefore, acceptable.
2.1.4 Plant Systems, Structures, and Components Scoping Methodology LRA Section 2.1.1, describes the methodology for scoping SSCs as required by 10 CFR 54.4(a) and the plant scoping process for systems and structures. The applicant identified SSCs within the scope of license renewal for HNP at the system and structure level, developed a list of plant systems and structures, and identified their intended functions. Intended functions are those that form the basis for including a system or structure within the scope of license renewal as required by 10 CFR 54.4(b) and are identified by comparing the system or structure function with the requirements of 10 CFR 54.4(a). An initial listing of all plant systems and structures 2-7
 
was developed from the HNP PassPort EDB.
After developing the initial list of the plant systems and structures, the applicant reviewed the FSAR and other documents containing descriptive and functional information to determine which systems and structures are within the scope of license renewal. The information from the FSAR was used in conjunction with other CLB information and plant documents, such as DBDs, docketed correspondence, PassPort EDB, maintenance rule database, and site walk-down results, to identify system and structure intended functions. These intended functions were aligned with the requirements of 10 CFR 54.4(a)(1), (a)(2), and (a)(3) to determine if a particular system or structure is within the scope of license renewal. Those systems and structures whose intended functions support the above requirements are included within the scope of license renewal. In addition, the applicant used license renewal calculations for anticipated transient without scram (ATWS), fire protection, pressurized thermal shock (PTS),
station blackout (SBO), and 10 CFR 54.4(a)(2) scoping requirements to identify additional systems within the scope of license renewal. Also, the applicant reconciled the PassPort EDB component-level information against the scoping criteria of the Rule and in addition, reviewed component-level intended functions derived from PassPort EDB classifications to ensure that a complete set of system and structure intended functions were captured. The results from these reviews were compiled and evaluated by the applicant to identify SSCs within the scope of license renewal at HNP.
Based on the results of the above scoping process, system and structure descriptions and intended functions were identified; and the systems and structures were aligned with one or more of the scoping requirements of 10 CFR 54.4(a). License renewal scoping drawings were developed to facilitate the staffs review by depicting the mechanical components that support system intended functions and; therefore, within the scope of license renewal.
2.1.4.1 Application of the Scoping Criteria in 10 CFR 54.4(a)(1) 2.1.4.1.1 Summary of Technical Information in the Application LRA Section 2.1.1.1 describes the scoping requirements for safety-related criteria in accordance with 10 CFR 54.4(a)(1). In reference to the safety-related criteria at HNP, the SSCs are identified by quality classifications which are documented in the PassPort EDB. The applicant stated that the administrative controls used to determine PassPort EDB quality classifications apply the Quality Class A designation to the SSCs that are necessary, either actively or passively, to assure the accomplishment of the safety-related functions required by 10 CFR 54.4(a)(1). In addition, the items that do not perform a safety-related function but whose failure could prevent the satisfactory accomplishment of a safety-related function during or following design basis accidents (DBAs) and transients were also classified as Quality Class A, unless a nonsafety-related classification had been justified. A comparison of HNPs definition of Quality Class A against the requirements of 10 CFR 54.4(a)(1) finds that these criteria are consistent, with the exception that the Rule includes references pursuant to 10 CFR 50.34(a)(1) and 10 CFR 100.11. At HNP, 10 CFR 50.67 requirements are applicable under the CLB; therefore, components credited with preventing and mitigating offsite exposure to less than are required by 10 CFR 50.67(b)(2) are designated Quality Class A. The applicant further stated that for the purpose of license renewal, any system (including support systems) or structure that contains one or more safety-related components was considered as a 2-8
 
safety-related system or structure. Therefore, PassPort EDB Quality Class A is determined to be consistent for scoping of HNP SSCs pursuant to 10 CFR 54.4(a)(1).
Based on the above, the scoping process used to identify safety-related SSCs for HNP license renewal satisfies the requirements of 10 CFR 54.4(a)(1).
2.1.4.1.2 Staff Evaluation Pursuant to 10 CFR 54.4(a)(1), the applicant must consider all safety-related SSCs relied upon to remain functional during and following a design-basis event (DBE) to ensure (a) the integrity of the reactor coolant pressure boundary, (b) the ability to shut down the reactor and maintain it in a safe shutdown condition, or (c) the ability to prevent or mitigate the consequences of accidents that could cause offsite exposures comparable to those of 10 CFR 50.34(a)(1),
10 CFR 50.67(b)(2), or 10 CFR 100.11.
As to identification of DBEs, SRP-LR Section 2.1.3 states:
The set of DBEs as defined in the Rule is not limited to Chapter 15 (or equivalent) of the FSAR. Examples of DBEs that may not be described in this chapter include external events, such as floods, storms, earthquakes, tornadoes, or hurricanes, and internal events, such as a high energy line break. Information regarding DBEs as defined in 10 CFR 50.49(b)(1) may be found in any chapter of the facility FSAR, the Commission's regulations, NRC orders, exemptions, or license conditions within the CLB. These sources should also be reviewed to identify SSCs relied upon to remain functional during and following DBEs (as defined in 10 CFR 50.49(b)(1)) to ensure the functions described in 10 CFR 54.4(a)(1).
During the audit, the staff confirmed that HNP is a General Design Criteria (GDC) plant, and that DBEs were accordingly factored into the original design of the plant in compliance with the GDCs. Equipment required to comply with DBEs is safety-related and included in the PassPort EDB as Qualification Class A in compliance with the safety-related definition. FSAR Section 3 contains sufficiently detailed information relating to the DBEs. The applicant stated that the DBEs considered are those addressed in the FSAR. The DBEs addressed in FSAR Section 3 include: earth quake, wind and tornado, flooding, missiles, pipe ruptures, design transients, seismic and dynamic qualification of mechanical and electrical equipment, and environmental design of mechanical and electrical equipment.
During the audit, through discussions with the HNP license renewal project personnel, the staff verified that the FSAR was reviewed to identify SSCs that are relied upon to remain functional during and following the DBEs pursuant to10 CFR 50.49(b)(1) to ensure the functions as required by 10 CFR 54.4(a)(1) are successfully accomplished. Also during the audit, the staff verified that in addition to the FSAR, other CLB sources such as DBDs, system descriptions, HNP license renewal calculations, NRC regulations, SERs, plant operating manuals and calculations, P&IDs and plant layout drawings, and documents referenced by the FSAR were considered and reviewed for license renewal scoping in accordance with 10 CFR 54.4(a)(1).
The applicant performed scoping of SSCs pursuant to 10 CFR 54.4(a)(1) in accordance with the HNP license renewal project scoping calculation, which provided guidance for the 2-9
 
preparation, review, verification, and approval of the scoping evaluations to assure the results of the scoping process were adequate. The staff reviewed these guidance documents governing the applicants evaluation of safety-related SSCs and sampled the applicants scoping results reports to ensure the methodology was implemented in accordance with those written instructions. In addition, during the audit, the staff discussed the methodology and the scoping results with the applicant's license renewal personnel responsible for these evaluations.
The methodology described in the LRA is consistent with the methodology in license renewal procedure.
In addition, the staff reviewed a sample of the license renewal scoping results for the AFW system, the PASS, and the auxiliary building structure to provide additional assurance that the applicant adequately implemented their scoping methodology as required by 10 CFR 54.4(a)(1). The staff confirmed that the scoping results for each of the sampled systems and the structure were developed consistent with the methodology, the SSCs credited for performing intended functions were identified, and the basis for the results as well as the intended functions were adequately described. The staff also verified that the applicant used pertinent engineering and licensing information to identify the SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) criteria. Specifically, during the audit, the staff reviewed HNP license renewal project scoping calculations and compared the applicants definition of Quality Class A to the definition contained in the license renewal rule and found that the HNP definition of safety-related complies with 10 CFR 54.4(a)(1).
2.1.4.1.3 Conclusion Based on this sample review, discussion with the applicant, and review of the applicant's scoping process, the staff determines that the applicant's methodology for identifying systems and structures meets 10 CFR 54.4(a)(1) scoping criteria and, therefore, is acceptable.
2.1.4.2 Application of the Scoping Criteria in 10 CFR 54.4(a)(2) 2.1.4.2.1 Summary of Technical Information in the Application LRA Section 2.1.1.2 describes the scoping methodology as it relates to the nonsafety-related criterion in accordance with 10 CFR 54.4(a)(2).
The applicant evaluated the SSCs that complied with 10 CFR 54.4(a)(2) using several categories. A summary description of these categories is provided below.
Scoping Based on Quality Classification. The applicant stated that the extensive use of quality classifications was made by HNP to identify SSCs that have functional or physical interactions with safety-related SSCs. These quality classifications have been assigned to nonsafety-related components and documented in the PassPort EDB. The PassPort EDB quality classification designations have been reconciled with license renewal scoping criteria to provide a means for scoping of license renewal components and associated systems and structures.
Scoping Based on CLB. The applicant stated that it performed a review to identify additional candidates for inclusion based on the CLB and operating experience. Three categories of SSCs were eliminated from the scope of license renewal pursuant to 10 CFR 54.4(a)(2), consistent 2-10
 
with regulatory guidance, including: (1) consideration of hypothetical failures that could result from system interdependencies that are not part of the plant CLB or that have not been previously experienced, (2) the function of nonsafety-related equipment to establish initial conditions for equipment operation or accident assumptions, and (3) malfunctions of nonsafety-related equipment that result in an actuation of safety-related equipment.
After eliminating the above categories of SSCs, the HNP design and licensing basis information was reviewed to identify nonsafety-related systems that function in direct support a safety-related system and whose failure could prevent the performance of a required intended function. The specific function and/or interaction required of the nonsafety-related system was also identified. The HNP design and licensing basis information was also reviewed to identify nonsafety-related SSC interactions with safety-related SSCs that could prevent the performance of a required intended function. Specific interactions that may affect the function of safety-related SSCs were identified. The HNP scoping review also considered the relevant requirements of 10 CFR 54.4(a)(2) from other LRAs as well as HNP-specific plant documentation, including docketed correspondence and licensee event reports. Review of industry and HNP operating experience did not identify additional systems that fall within the scope of license renewal as required by 10 CFR 54.4(a)(2).
Scoping Based on NRC Scoping Guidance for Spatial Interactions. The applicant stated that HNP took an expansive approach for determining where spatial relationships might exist between nonsafety-related and safety-related SSCs. HNP used the preventive option, which requires that non-connected, nonsafety-related systems be brought within the scope of license renewal to protect safety-related SSCs from the consequences of failures of the nonsafety-related systems. The mitigative option of protecting safety-related systems was not used. Except for air/gas-filled systems, piping and heating ventilation and air conditioning (HVAC) systems with nonsafety-related components located within a safety-related structure were included within the scope of license renewal, unless a specific evaluation was performed and concluded a spatial interaction was not credible. HNP performed a site-specific review to verify that there are no credible aging mechanisms for air/gas systems with dry internal environments.
Based on this review, leakage and spray are not a consideration for compliance with 10 CFR 54.4(a)(2) scoping for air/gas systems. However, structural supports for air and gas systems located in Seismic Category I structures have been included within the scope of license renewal to prevent physical impacts on safety-related equipment during a seismic event.
For the purposes of identifying potential spatial interactions, if a structure houses safety-related SSCs only in a limited area, then nonsafety-related spatial interactions may be limited to only that area. Area-specific analyses were performed to eliminate plant buildings or areas from consideration in the evaluation of spatial interactions. These analyses are summarized in the following paragraphs.
Scoping Based on NRC Scoping Guidance for Seismic-Connected Piping. Nonsafety-related systems relied upon to provide seismic support for safety-related SSCs were evaluated using the following rationale:
* Safety-related piping is within the scope of license renewal as required by 10 CFR 54.4(a)(1) 2-11
* Safety-related piping is located in Seismic Category I structures at HNP
* The nonsafety-related/safety-related boundary is located in a Seismic Category I structure
* All piping systems in Seismic Category I structures are within the scope of license renewal as discussed with respect to spatial interactions above.
Thus, it follows that nonsafety-related, seismically-connected piping is within the scope of license renewal and enveloped by the HNP scoping methodology.
Certain air/gas piping systems have nonsafety-related piping connected to safety-related piping.
These air/gas piping systems with seismically-connected piping include the instrument air system, service air system, bulk nitrogen storage system, hydrogen gas system, and penetration pressurization system. These systems were evaluated by reviewing stress calculations, the PassPort EDB quality class designation, the FSAR, and system drawings. This ensured that nonsafety-related piping connected to safety-related piping in these air/gas systems was included within the scope of license renewal up to the first seismic anchor or equivalent anchor, beyond the safety/nonsafety interface.
2.1.4.2.2 Staff Evaluation Pursuant to 10 CFR 54.4(a)(2), the applicant must consider all nonsafety-related SSCs the failure of which could prevent satisfactory performance of safety-related SSCs relied upon to remain functional during and following a DBE to ensure (a) the integrity of the reactor coolant pressure boundary, (b) the ability to shut down the reactor and maintain it in a safe shutdown condition, or (c) the ability to prevent or mitigate the consequences of accidents that could cause offsite exposures comparable to those of 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11.
NRC Regulatory Guide (RG) 1.188, Revision 1, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, Revision 1, dated September 2005, endorses the use of NEI 95-10, Revision 6, for methods the staff considers acceptable for compliance with 10 CFR Part 54 in preparing license renewal applications. NEI 95-10, Revision 6, addresses the staff positions on 10 CFR 54.4(a)(2) scoping criteria, nonsafety-related SSCs typically identified in the CLB, consideration of missiles, cranes, flooding, high-energy line breaks, nonsafety-related SSCs connected to safety-related SSCs, nonsafety-related SSCs in proximity of safety-related SSCs, and the mitigative and preventive options related to nonsafety-related and safety-related SSCs interactions.
The staff states that applicants should not consider hypothetical failures, but rather base their evaluation on the plants CLB, engineering judgement and analyses, and relevant operating experience, describing operating experience as all documented plant-specific and industry-wide experience useful in determining the plausibility of a failure. Documentation would include NRC generic communications and event reports, plant-specific condition reports, such industry reports as safety operational event reports, and engineering evaluations.
The staff reviewed LRA Section 2.1.1.2. In the LRA, the applicant describes the scoping methodology as it relates to the nonsafety-related criteria pursuant to 10 CFR 54.4(a)(2). The applicant evaluated the SSCs that met 10 CFR 54.4(a)(2) requirements using four categories:
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(1) CLB, (2) nonsafety-related SSCs required to support or that could prevent performance of safety-related SSCs, (3) nonsafety-related SSCs with the potential for spatial interaction with safety-related SSCs, and (4) nonsafety-related SSCs directly connected to safety-related SSCs.
In addition, the staff reviewed the applicants license renewal scoping calculation as required by 10 CFR 54.4(a)(2), which describes the scoping process used by the applicant to review nonsafety-related systems and structures considered to satisfy the requirements of 10 CFR 54.4(a)(2). The applicants evaluation was performed in accordance with the guidance contained in NEI 95-10, Revision 6, for the identification and treatment of SSCs which meet 10 CFR 54.4(a)(2) requirements.
The applicant evaluated 10 CFR 54.4(a)(2) SSCs with the four categories from the NRC guidance to the industry on identification and treatment of such SSCs:
(1)  Nonsafety-Related SSCs Required for Functions that Support Safety-Related SSCs.
The applicant began the nonsafety-related scoping evaluation by reviewing the PassPort EDB quality classifications to identify SSCs that have functional or physical interactions with safety-related SSCs. PassPort EDB quality classification designations were reconciled with license renewal scoping criteria to provide a means for scoping of components and associated systems and/or structures. Components with quality classifications that correspond to 10 CFR 54.4(a)(2) scoping requirements include: (1) components that are nonsafety-related but are essential to the functioning of a safety-related system, (2) components that are seismically designed in accordance with RG 1.29, Position C.2, to prevent adverse interactions with safety-related equipment during an earthquake, and (3) components in those portions of systems whose failure may have an adverse effect on a nearby safety-related component and are; therefore, seismically supported and seismically designed.
The applicant also reviewed design and licensing basis information, including DBDs, plant drawings, and the FSAR, to identify nonsafety-related systems that function to directly support a safety-related system and whose failure could prevent the performance of a required intended function. The specific function and/or interaction required of the nonsafety-related system was also identified. The HNP design and licensing basis information was also reviewed to identify nonsafety-related SSC interactions with safety-related SSCs that could prevent the performance of a required intended function. Specific interactions that may affect the function of safety-related SSCs were identified. These evaluation criteria were discussed in the applicants license renewal scoping calculation pursuant to 10 CFR 54.4(a)(2). The staff found that the applicant implemented an acceptable method for scoping of nonsafety-related systems that perform a function that supports a safety-related intended function.
(2)  Nonsafety-Related Systems Connected to and Structurally Supporting Safety-Related SSCs. The staff reviewed the applicants license renewal scoping calculation pursuant to 10 CFR 54.4(a)(2) for the evaluation of nonsafety-related systems directly connected and structurally supporting safety-related SSCs. Additionally, the staff reviewed the LRA and the FSAR. The interaction of other piping with Seismic Category I piping is discussed in FSAR Section 3.7.3.13. The applicant cites the following quotes from that LRA discussion:
In the case of non-Seismic Category I piping systems attached to 2-13
 
Seismic Category I piping systems, the dynamic effects were included in the modeling of the Seismic Category I piping up to the first anchor or system of restraints which decouples the piping.
It should be noted that all seismic/non-seismic interface restraints are located in seismically analyzed structures thereby assuring that collapse of the restraint structure will not occur.
The staff determined that the latter of the statements above presumed that a seismically qualified anchor or equivalent is located in a seismically analyzed structure. The applicant was unable to state with certainty that there is no case where a seismic anchor was not within a seismically analyzed structure.
In RAI 2.1-1 dated June 11, 2007, the staff asked the applicant to provide the basis and further discussion to support the determination that all nonsafety-related piping systems attached to safety-related SSCs contain a seismic anchor at a location beyond the nonsafety to safety interface and prior to nonsafety-related piping exiting the structure and, that by extending the in-scope portion of the nonsafety-related piping system to the room boundary, there is assurance that an acceptable license renewal bounding point has been encompassed in accordance with 10 CFR 54.4(a)(2). Additionally, the staff asked the applicant to discuss the methods used to identify the specific seismic anchors for the attached nonsafety-related piping systems and the methods used to ensure that there are no exceptions to this determination.
In its response dated July 10, 2007, the applicant provided the history of its methodology to account for the seismic motion of non-Category I piping systems in the design of Category I piping (excluding the main steam and feedwater interface restraints). This issue was first identified when the plant was initially licensed as Draft SER Open Item 275. The applicant provided additional information related to Draft SER Open Item 275. Subsequently, the NRC identified the ongoing issue as a confirmatory item in an SER dated November 1983.
In response to the confirmatory item, the applicant stated that it had completed its review of seismic and/or non-seismic interface anchors. This process included a review of 1141 piping stress isometrics that identified 220 anchors. Of the anchors identified, 104 were found to be acceptable as is. The remaining anchors were reviewed in accordance with the previously agreed criteria in NUREG-1038. The issued was closed in NRC Inspection Report 50-400/85-28 dated August 21, 1985.
The applicant also stated that NEI 95-10, Revision 6 (Appendix F, Section 4.4 on page F-8) states that there may be isolated cases where an equivalent anchor point for a particular piping segment is not clearly described within the existing CLB information or original design basis. In those instances, the applicant may use a combination of restraints or supports such that the nonsafety-related piping and associated SCs attached to safety-related piping is included within the scope of license renewal up to a boundary point that encompasses at least two supports in each of the three orthogonal directions.
Since HNP has specific criteria in its CLB regarding the evaluation of nonsafety-related 2-14
 
piping connected to safety-related piping and associated support requirements, the definition of an equivalent anchor in NEI 95-10 need not be used. HNP's methodology described in the LRA is based on logic provided by the previously agreed upon criteria in NUREG-1038.
Based on its review, the staff finds the applicants response to RAI 2.1-1 acceptable because the applicant had a documented review which indicated that all nonsafety-related piping systems attached to safety-related SSCs contain a seismic anchor at a location beyond the nonsafety to safety interface, and prior to nonsafety-related piping exiting the structure that the applicant had included the portion of the nonsafety-related piping, attached to safety-related piping, up to and including a seismic anchor.
(3) Nonsafety-Related SSCs Not Directly Connected to Safety-Related SSCs. The staff reviewed the applicants license renewal scoping calculation pursuant to 10 CFR 54.4(a)(2) for the evaluation of nonsafety-related systems not directly connected to safety-related SSCs. Additionally, the staff reviewed the LRA and the FSAR.
LRA Section 2.1.1.2 states, for purposes of identifying potential spatial interactions, if a structure houses safety-related SSCs only in a limited area, then nonsafety-related spatial interactions may be limited to only that area. Area-specific analyses were performed to eliminate plant buildings or areas from consideration in the evaluation of spatial interactions.
The specific structures and/or areas evaluated for the purpose above included:
* A portion of the fuel handling building designated as outside the power block (OPB) structures
* Diesel generator service water pipe tunnel, and attached Class I electrical cable area located above the pipe tunnel which is located in the turbine building
* Room W262 in the waste processing building
* Yard structures containing components not specifically located in a defined building, such as, safety-related manholes, duct banks, and protective concrete mats containing or protecting buried safety-related cable
* ESW and CTMU intake structure
* Areas within the reactor auxiliary building including the kitchen associated with the main control room, the hot machine shop, three PASS rooms, and elevator areas The staff reviewed the applicants license renewal calculation which documents the results of the evaluations and held discussions with cognizant license renewal team members. The applicants evaluations included a review of the classifications in the PassPort EDB, information in the CLB, and walkdowns. The staff reviewed the relevant information contained in the calculation and reviewed associated drawings.
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The staff found that the applicant performed a site-specific review to verify that there are no credible aging mechanisms for air/gas systems with dry internal environments.
Based on this review, leakage and spray are not a consideration for compliance with 10 CFR 54.4(a)(2) scoping for air/gas systems. This approach is consistent with the guidance in NEI 95-10, Revision 6, Appendix F. The staff found that the applicant implemented an acceptable method for scoping of nonsafety-related systems not directly connected to safety-related SSCs.
(4)  Certain Nonsafety-Related Mitigative Plant Design Features in the CLB. The staff reviewed the applicants license renewal scoping calculation pursuant to 10 CFR 54.4(a)(2) for the evaluation of nonsafety-related SSCs that are typically identified in the CLB. The staff also reviewed applicable portions of the FSAR.
For high energy line breaks, the applicant used FSAR Section 3.6.1.2.1 which defines high energy as a system which during normal operating conditions operates greater than 200 EF and/or greater than 275 psig. The applicant included all nonsafety-related high energy piping located within a safety-related structure within the scope of license renewal as required by 10 CFR 54.4(a)(2), unless specific evaluations were performed.
This approach is consistent with the guidance in NEI 95-10, Revision 6, Appendix F.
With regard to flooding, the applicant used the definition of Seismic Category I SSCs as given in FSAR Section 3.4.1. Seismic Category I SSCs are protected from the effects of the design basis flood levels or flood conditions. The FSAR also describes evaluations of flooding resulting from a postulated failure of piping components and states that flooding breaks will not prevent safety-related equipment from performing their intended design functions. As stated in the LRA, all piping and HVAC systems with nonsafety-related components located within a Seismic Category I structure have been included within the scope of license renewal, unless a specific evaluation was performed that concludes a spatial interaction is not credible.
The applicant evaluated the potential interactions of cranes and/or overhead handling equipment. The applicant included those structures which house or support overhead handling systems from which a load drop could be hypothesized to result in damage to any system that in turn could prevent the accomplishment of a safety-related function within the scope of license renewal, as required by 10 CFR 54.4(a)(2).
Nonsafety-related overhead handling devices are commodities considered part of the structure and are evaluated in LRA Section 2.4.
Based on its review, the staff found that the applicant implemented an acceptable method for scoping of nonsafety-related mitigative plant design features in the CLB.
2.1.4.2.3 Conclusion Based on its review, the staff determines that the applicant's methodology for identifying systems and structures meets 10 CFR 54.4(a)(2) scoping criteria and, therefore, is acceptable.
This determination is based on a review of sample systems, discussions with the applicant, and review of the applicant's scoping process.
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2.1.4.3 Application of the Scoping Criteria in 10 CFR 54.4(a)(3) 2.1.4.3.1 Summary of Technical Information in the Application The LRA, in accordance with10 CFR 54.4(a)(3), states that SSCs relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the NRC's regulations for fire protection (10 CFR 50.48), environmental qualification (EQ (10 CFR 50.49)),
PTS (10 CFR 50.61), ATWS (10 CFR 50.62), and SBO (10 CFR 50.63) are within the scope of license renewal. CLB evaluations were performed to identify and document the SSCs credited for compliance with each of these regulations. Systems or structures that have one or more components credited for demonstrating compliance with one of the regulated events are within the scope of license renewal in accordance with 10 CFR 54.4(a)(3). Scoping based on each of the regulated events is described in the following paragraphs.
Fire Protection. The SSCs at HNP that support compliance with 10 CFR 50.48 are within the scope of license renewal. Any system with components classified as supporting fire protection in the PassPort EDB was considered within the scope of license renewal. Also, any systems with components credited in plant documents required to support safe shutdown following a fire were considered within the scope of license renewal. Additionally, the structures that house systems within the scope of fire protection are themselves within the scope of fire protection.
The steps to identify SSCs relied on for fire protection to meet the requirements of 10 CFR 54.4(a)(3) are:
(1)  PassPort EDB classification criteria identifying systems required to detect and mitigate fires and to achieve post-fire safe shutdown were reviewed to identify systems credited for compliance with 10 CFR 50.48. In addition, structures that house the components of these systems were identified.
(2)  PassPort EDB information was supplemented by a review of the FSAR and docketed information pertaining to compliance with 10 CFR 50.48, including: (a) HNP responses to Branch Technical Position (BTP) CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," criteria; (b) the staffs SER for HNP; (c) the Fire Protection Program manual; (d) the safe shutdown analysis in case of fire, including the fire hazards analysis; (e) the safe shutdown separation analysis; (f) the fire protection equipment q-list; (g) safe shutdown flow diagrams; (h) DBDs; and (i) related plant procedures.
(3)  Based on the above, license renewal intended functions for fire protection as required by 10 CFR 54.4(a)(3) were identified for each system and structure and were determined to meet those requirements. The scoping process to identify SSCs relied upon and/or specifically committed to for fire protection for HNP is consistent with and satisfies the requirements of 10 CFR 54.4(a)(3).
Environmental Qualification. Section 50.49(b) of 10 CFR requires that electric equipment important to safety be environmentally qualified to mitigate certain accidents that result in harsh environmental conditions in the plant. The steps to identify SSCs relied on for EQ to comply with 10 CFR 54.4(a)(3) are:
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(1)  The PassPort EDB identifies components that are on the HNP EQML in accordance with 10 CFR 50.49. The PassPort EDB was used as an input document for scoping of SSCs.
Any system that contained one or more components designated as EQ-related in the EDB was considered within the scope of license renewal due to EQ. Also, structures that house the components of the EQML were identified.
(2)  Based on the above, a license renewal intended function was identified for each system and structure determined to meet the EQ requirements of 10 CFR 54.4(a)(3). The HNP scoping process to identify systems and structures relied upon and/or specifically committed to for EQ is consistent with and satisfies the requirements of 10 CFR 54.4(a)(3). Note that qualified life analysis of EQ components may meet the requirements for time-limited aging analyses (TLAAs). EQ-related TLAAs are discussed in Section 4.4.
Pressurized Thermal Shock. Section 50.61 of 10 CFR, "Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," requires that licensees evaluate the reactor vessel beltline materials against specific criteria to ensure protection against brittle fracture. Since the analysis relies only on reactor vessel beltline materials, there are no SSCs, other than the reactor vessel, that are within the scope of license renewal pursuant to 10 CFR 50.61. Therefore, the reactor vessel is within the scope of license renewal based on compliance with 10 CFR 50.61.
Based on the above, a license renewal intended function for postulated PTS was identified for the reactor vessel in accordance with 10 CFR 54.4(a)(3). Note that PTS is related to reactor pressure vessel embrittlement, which is a TLAA. The TLAA analysis associated with PTS is discussed in Section 4.2.
Anticipated Transient Without Scram. Design features at HNP related to ATWS are within the scope of license renewal because they are relied on to meet the requirements of 10 CFR 50.62.
Section 50.62 of 10 CFR requires each Pressurized Water Reactor (PWR) to have equipment from the sensor output to final actuation device, that is diverse from the reactor trip system, to automatically initiate the AFW system and initiate a turbine trip under conditions indicative of an ATWS. The steps to identify SSCs at HNP relied upon for ATWS mitigation to meet the requirements of 10 CFR 54.4(a)(3) are outlined below:
(1)  A review was performed to identify the SSCs credited with mitigating a postulated ATWS event. The systems that interface with and the structures that house these SSCs were the focus of the review.
(2)  Based on the above, a license renewal intended function was identified for each system and structure determined to meet the ATWS events requirements of 10 CFR 54.4(a)(3).
The scoping process to identify SSCs relied upon and/or specifically committed to for a postulated ATWS event for HNP is consistent with and satisfies the requirements of 10 CFR 54.4(a)(3).
Station Blackout. PassPort EDB quality classifications that have been assigned to components credited with compliance with SBO requirements were used to identify the applicable equipment. The steps to identify systems and structures at HNP relied upon for SBO to meet the requirements of 10 CFR 54.4(a)(3) are outlined below:
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(1)    The PassPort EDB, FSAR, SBO Coping Analysis Report, safe shutdown flow diagrams, plant procedures, and scoping guidance regarding additional equipment required to recover from an SBO were reviewed to determine the scope of systems and structures required for SBO.
(2)    Based on the above, a license renewal intended function was identified for each system and structure determined to meet the postulated SBO requirements of 10 CFR 54.4(a)(3).
2.1.4.3.2 Staff Evaluation Fire Protection. The applicant developed a calculation which summarized and documented the results of a detailed review performed on the Fire Protection Program documents for HNP, demonstrating compliance with the requirements of 10 CFR 50.48. The applicant reviewed the applicable CLB sources such as the FSAR and used the CLB source information to develop a list of the required equipment for the event and any applicable recovery path. The position paper provided a list of systems and structures credited in the Fire Protection Program documents and the applicable CLB sources. The PassPort EDB contained information which assigned a specific quality classification to those SSCs required to meet 10 CFR 50.48. All SSCs determined to meet the fire protection requirements of 10 CFR 54.4(a)(3) were identified as within the scope of license renewal. The staff reviewed FSAR Section 9.5.1, the HNP fire protection calculation, and selected results and concluded that the method for identifying SSCs within the scope of license renewal that satisfy the fire protection requirement of 10 CFR 54.4(a)(3) was adequate.
Environmental Qualification. The HNP EQML was used as the basis to create a list of SSCs within the scope of license renewal. The information in the EQML is contained in the PassPort EDB and those components were used to identify the parent systems which were included within the scope of license renewal pursuant to 10 CFR 54.4 (a)(3). In addition, structures housing EQ components were also included within the scope of license renewal in accordance with 10 CFR 54.4 (a)(3).
The staff reviewed the applicable portion of the FSAR, the HNP bases calculations documenting the scoping activities, the EQML and corresponding PassPort EDB entries, and selected results. The staff concluded that the method for identifying SSCs within the scope of license renewal that satisfy the EQ requirement of 10 CFR 54.4(a)(3) was adequate.
Anticipated Transient Without Scram. The applicant determined that SSCs in numerous systems were required to address ATWS pursuant to 10 CFR 50.62. The applicant reviewed the original plant modification, plant drawings and wiring diagrams. The applicant reviewed the applicable portions of the FSAR and system DBDs and identified 60 components residing in 20 systems resulting in the inclusion of 17 systems within the scope of license renewal for ATWS support. The applicant also included three structures which house the 17 systems within the scope of license renewal for ATWS. The applicant documented the ATWS scoping activities in a HNP calculation. The staff reviewed the applicable portions of the FSAR, DBDs, drawings and the HNP calculation and concluded that the method for identifying SSCs within the scope of license renewal that satisfy the ATWS requirement of 10 CFR 54.4(a)(3) was adequate.
Station Blackout. The applicant reviewed the FSAR, DBDs, site coping analysis, and the safe 2-19
 
shut down flow diagram to identify the SSCs required to address SBO pursuant to 10 CFR 50.62. The PassPort EDB contained information which assigned a specific quality classification to those SSCs required to meet 10 CFR 50.62. The applicant documented the review activities and results in a HNP calculation. The applicant also included three structures which house the 17 systems within the scope of license renewal for SBO. The staff reviewed the selected portions of the FSAR, DBDs, drawings, the SBO coping analysis, the safe shutdown flow diagrams and the HNP calculation and concluded that the method for identifying SSCs within the scope of license renewal that satisfy the SBO requirement of 10 CFR 54.4(a)(3) was adequate.
Pressurized Thermal Shock. The applicant reviewed the CLB information related to PTS, including the regulations and guidance, the FSAR and correspondence with the NRC, and documented the review in a HNP calculation. The staff reviewed the CLB information and selected results and concluded that the method for identifying SSCs within the scope of license renewal that satisfy the PTS requirement of 10 CFR 54.4(a)(3) was adequate.
2.1.4.3.3 Conclusion On the basis of the sample review, discussions with the applicant, and review of the applicant's scoping process, the staff determined that the applicant's methodology for identifying systems and structures meets the scoping requirements of 10 CFR 54.4(a)(3), and is therefore acceptable.
2.1.4.4 Plant-Level Scoping of Systems and Structures 2.1.4.4.1 Summary of Technical Information in the Application System and Structure Level Scoping. At HNP, identification of SSCs that are within the scope of license renewal is performed at the system or structure level. In LRA Section 2.1.1, the applicant described the scoping methodology for systems and structures that are safety-related, nonsafety-related, and equipment relied upon to perform a function for applicable regulated events pursuant to 10 CFR 54.4(a)(3). The scoping methodology is consistent with the requirements of 10 CFR 54.4 and the industry in NEI 95-10. In LRA Section 2.2, the applicant evaluated systems and structures to determine whether they were within the scope of license renewal, using the methodology described in LRA Section 2.1.1. The results of plant level scoping are provided in LRA Tables 2.2-1, 2.2-2 and 2.2-3 for mechanical systems, structures, and electrical and instrumentation and control (I&C) systems, respectively. If a system or structure, in whole or in part, meets one or more of the license renewal scoping criteria, the system or structure is considered to be within the scope of license renewal. Also, included in the tables are references to the sections in the LRA that discuss screening results for systems and structures within the scope of license renewal. Additionally, these scoping result tables also provide the systems and structures that do not meet the requirements of 10 CFR 54.4(a), and therefore indicated as not within the scope of license renewal.
Component Level Scoping. LRA Section 2.1.1, Scoping, describes the component scoping as part of the system and structure level scoping. Initially in the license renewal review, PassPort EDB component-level information was reconciled against the scoping criteria of the Rule.
Components with the appropriate classification were correlated to corresponding scoping 2-20
 
criteria from the Rule, based on which component scoping results were derived. Further, the component-level scoping results derived from the use of the PassPort EDB are augmented or modified by the review of the FSAR, other plant documentation that constitute the CLB, and the topical evaluations. The result is a comprehensive scoping process that bounds the requirements of 10 CFR 54.4 and is consistent with industry and regulatory guidance.
The PassPort EDB functions as the component-level Q-list for HNP and identifies the items to which the Quality Assurance program applies. The EDB contains component-level quality classifications that were derived from system and structure design and functional data required to meet CLB commitments. Component quality classification determinations typically involve a functional evaluation of the parent system by reviewing the system-level Q-list, FSAR, other CLB documents, and operating procedures. Control and revision of component quality classification information within the PassPort EDB is governed by procedure. Therefore, it was concluded that the component-level information could be used to identify SSCs within the scope of license renewal.
The HNP civil/structural scoping process included additional scoping activities. Any structure or component that houses or provides physical or functional support for components within the scope of license renewal is itself within the scope of license renewal. Component location information in the PassPort EDB was used to identify structures which house or support license renewal components. Structure intended functions were then associated with the intended functions of the components located in the structure.
Consumables. LRA Section 2.1.2.1 discusses consumables. Consumable parts of a component may be passive, long-lived, and necessary to fulfill an intended function. In accordance with NRC screening guidance of SRP-LR Table 2.1-3, consumables may be divided into four basic categories for the purpose of license renewal. Screening of consumables was either done as part of the component AMR or the item was excluded based on NRC screening guidance.
Group (a) subcomponents are not relied upon to form a pressure-retaining function and, therefore, not subject to an AMR. Group (b) subcomponents are structural sealants for structures within the scope of license renewal that require an AMR. Group (c) subcomponents are periodically replaced according to plant procedures and, therefore, not subject to an AMR.
Group (d) consumables are subject to replacement based on National Fire Protection Association standards according to plant procedures and, therefore, not subject to an AMR.
2.1.4.4.2 Staff Evaluation System and Structure Level Scoping. The staff reviewed the applicants methodology for performing the scoping of plant systems and structures to ensure it was consistent with the requirements of 10 CFR 54.4(a). The methodology used to determine the systems and structures within the scope of license renewal was documented in HNP license renewal project scoping calculations referenced in the Audit Report. The applicant's approach to system and structure scoping is provided in these documents, and is consistent with the methodology described in LRA Section 2.1.1. The process of determining which systems and structures are within the scope of license renewal involved a review of the FSAR, DBDs, technical evaluation reports, the PassPort EDB, the maintenance rule database, and other documents containing descriptive and functional information. This information was used to determine if a particular system or structure aligns with the requirements of 10 CFR 54.4(a), (a)(2), and (a)(3).
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During the scoping methodology audit, the staff conducted detailed discussions with the applicant's license renewal project personnel and reviewed documentation pertinent to the scoping process and scoping results. The applicant documented the results of the plant level scoping in the systems and structures scoping calculations, on an individual system and structure basis. The scoping calculations contained information including a description of the system or structure, function summary, identification of major components and their description, identification of safety-related intended functions, CLB documents, FSAR, DBDs, and license renewal boundary diagrams. The staff performed a sampling of scoping results and concluded that the applicant's scoping reports contained an appropriate level of detail to document the scoping process.
The staff assessed whether the applicant had appropriately applied the scoping methodology outlined in the LRA and implementation procedures, and also evaluated whether the scoping results were consistent with the CLB requirements. Additionally, the staff performed a sampling of scoping evaluation results for AFW and PASS systems to verify proper implementation of the scoping process.
On the basis of a review of the LRA, the scoping and screening implementation procedures, and a sampling review of system and structure scoping results during the methodology audit, the staff concludes that the applicant's scoping methodology for systems and structures was consistent with the description provided in LRA Section 2.1 and the requirements of 10 CFR 54.4, and was adequately implemented.
Component Level Scoping. Following the identification of systems and structures within the scope of license renewal, a review of mechanical systems and structures was performed to determine the intended functions of the components within the scope of each system and structure. The structural and mechanical components supporting intended functions were considered within the scope of license renewal and screened to determine if an AMR was required. All electrical and I&C components found within the evaluation boundary of mechanical systems within the scope of license renewal were included within the scope of license renewal.
The applicant performed component level scoping by using the LRBDs in conjunction with the PassPort EDB. The EDB was utilized to search for the components shown on the LRBDs and to determine their intended functions. All mechanical, structural, and electrical and I&C components that perform or support an intended function, as required by 10 CFR 54.4, for all the systems and structures within the scope of license renewal were included within the scope of license renewal. The components within the scope of license renewal were further evaluated during the screening process to determine whether they were subject to an AMR. The results of the applicants scoping review were documented in license renewal scoping and screening reports.
During its audit, the staff confirmed that mechanical and structural drawings were evaluated to create license renewal boundaries for each system or structure within the scope of license renewal and also to show the corresponding components within the scope of license renewal.
Each LRBD was evaluated to identify the components that perform safety-related intended functions or a regulated event and were further evaluated during the screening process to determine if the component should be subject to an AMR. Nonsafety-related components that are connected to safety-related components and provide structural support at the safety/nonsafety interface, or components whose failure could prevent satisfactory 2-22
 
accomplishment of a safety-related function due to spatial interaction with safety-related SSCs are included within the scope of license renewal and individually identified in the AMR pursuant to 10 CFR 54.4(a)(2).
On the basis of a review of LRA Sections 2.1.1 and 2.1.2, the scoping and screening implementation procedures, and a sampling review of systems and structure scoping results during the methodology audit, the staff concludes that the applicant's scoping methodology for SSCs was consistent with the description provided in LRA Section 2.1 and the requirements of 10 CFR 54.4 and was adequately implemented.
Insulation. The staff reviewed the applicants evaluation of plant insulation as documented in the applicants license renewal calculation for mechanical system screening methodology.
Thermal insulation is considered part of the parent system. The determination as to whether an insulation commodity group is required to support a system intended function was made during the screening process.
The applicant reviewed all plant insulation specifications to identify all types of insulation installed at HNP. Then the applicant reviewed the operating experience database to identify if there were any instances of insulation falling down, or degradation or failures that led to physical interactions (10 CFR 54.4(a)(2)). The applicant reviewed the FSAR for insight into the various uses of insulation, such as insulation used to mitigate heat loads. The applicant also reviewed DBDs including calculations to determine if any insulation was credited. The above sources were also reviewed to determine if any insulation was required to support any system intended functions pursuant to 10 CFR 54.4(a)(3). Based on the applicants review, insulation was identified as being credited for room cooler evaluations, environmental control (minimize plateout, freeze protection), to preserve the qualification temperature of certain solenoid valves, and to maintain the temperature of concrete surrounding hot pipe penetrations.
As identified above, certain insulation was included within the scope of license renewal and subject to an AMR. The staff concludes that the applicants methods and conclusions regarding insulation are acceptable.
Consumables. The staff reviewed the applicants evaluation of consumables as documented in the LRA and the applicants license renewal calculation for mechanical system screening methodology. Group (a) subcomponents are not credited with maintaining the integrity of the pressure boundary function of valve, pump and similar component housings and; therefore, are not subject to an AMR. Group (b) subcomponents are structural sealants associated with structures within the scope of license renewal that require an AMR. The structural sealants are within the scope of license renewal and are subject to an AMR. Group (c) subcomponents are short lived consumables that are periodically replaced, and; therefore, are not subject to an AMR. Group (d) consumables are typically replaced based on condition and may be excluded from an AMR, if justified. The applicant identified preventive maintenance identification numbers that governed the replacement of system filters. Preventative maintenance identification numbers associated with filters are identified in the PassPort EDB. The applicants screening results calculation lists those components that are excluded from an AMR and provides a reference to the preventative maintenance identification number that replaces the filter. The staff reviewed the results and confirmed that a preventative maintenance identification number is listed. If a preventative maintenance identification number could not be identified, or it was determined that a procedure was not in place, the applicant entered the information into its 2-23
 
Nuclear Management Tracking System indicating that a preventative maintenance identification number or equivalent needs to be developed. The applicant stated that all such Nuclear Management Tracking System entries will be resolved prior to entering the period of extended operation. Fire extinguishers, fire hoses and air packs are periodically inspected and tested per the requirements of applicable National Fire Protection Association (NFPA) guidelines and; therefore, are not subject to an AMR.
Based on its review, the staff finds that the applicant followed the process described in the SRP-LR, and appropriately identified and categorized the various consumables in accordance with the guidance.
2.1.4.4.3 Conclusion Based on its review of the LRA, scoping and screening implementation procedures, and a sampling of system scoping results during the audit, the staff concludes that the applicants scoping methodology for plant SSCs, commodity groups, insulation, and consumables is acceptable. In particular, the staff determines that the applicants methodology reasonably identifies systems, structures, component types, and commodity groups within the scope of license renewal and their intended functions.
2.1.4.5 Conclusion for Scoping Methodology Based on its review of the LRA and the scoping implementation procedures, the staff determines that the applicant's scoping methodology is consistent with SRP-LR guidance and has identified SSCs within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1), (a)(2), (a)(3). Therefore, the staff concludes that the applicants methodology meets 10 CFR 54.4(a) requirements.
2.1.5 Screening Methodology 2.1.5.1 General Screening Methodology After identifying systems and structures within the scope of license renewal, the applicant implemented a process for identifying SCs subject to an AMR, in accordance with 10 CFR 54.21.
2.1.5.1.1 Summary of Technical Information in the Application In LRA Section 2.1.2, the applicant described the method of identifying SCs from in-scope systems and structures that are subject to an AMR, and justifies the process with respect to requirements of an IPA pursuant to 10 CFR 54. 21(a). In the HNP IPA, the process of identifying the SCs subject to an AMR is referred to as screening and; therefore, the applicants screening process consisted of identifying and listing the SCs that are subject to an AMR. All SSCs listed in the HNP license renewal EDB database were scoped in accordance with 10 CFR 54.4(a). All SCs categorized as within the scope of the license renewal were screened against the requirements of 10 CFR 54.21(a)(1)(I) and (a)(1)(ii) to determine whether they are subject to an AMR. The applicants SC screening was performed by mechanical, civil/structural, and electrical/I&C disciplines, following an initial screening based on generic equipment types.
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During the screening process, the applicant incorporated some SCs into commodity groups based on similarity of their design or material of construction. The use of commodity groups made it possible to address an entire group of SCs with a single evaluation.
2.1.5.1.2 Staff Evaluation Pursuant to 10 CFR 54.21, the NRC requires that each LRA contain an IPA that identifies SCs within the scope of license renewal that are subject to an AMR. The IPA must identify components that perform an intended function without moving parts or a change in configuration or properties (passive), as well as components that are not subject to periodic replacement based on a qualified life or specified time period (long-lived). The IPA includes a description and justification of the methodology used to determine the passive and long-lived SCs, and a demonstration that the effects of aging on those SCs will be adequately managed so that the intended functions will be maintained under all design conditions imposed by the plant-specific CLB for the period of extended operation.
The staff reviewed the methodology used by the applicant to determine if mechanical, electrical and structural component types within the scope of license renewal should be subject to an AMR. The applicant implemented a process for determining which SCs were subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). In LRA Section 2.1.2, the applicant discussed these screening activities as they related to the component types and commodity groups within the scope of license renewal. The screening process evaluated these component types within the scope of license renewal to determine which ones were long-lived and passive and; therefore, subject to an AMR. Active components were screened out and; therefore, did not require AMR. The screening process also identified short-lived components and consumables. The short-lived components are not subject to an AMR. Also, in its screening process, the applicant incorporated the industry guidance provided in NEI 95-10, Appendix B, Typical Structure, Component and Commodity Groupings and Active/Passive Determinations for the Integrated Plant Assessment. The screening of system SCs was performed using the HNP PassPort EDB database. The staff reviewed LRA Sections 2.3, 2.4 and 2.5 that provided the results of the process used to identify component types and subject to an AMR.
During the audit, the applicant provided the staff with detailed discussion and demonstrations of the screening processes used for each discipline and provided documentation that described the screening methodology and screening results. Also as part of the audit, the staff performed a sampling of the screening results reports for the AFW and PASS systems and auxiliary building structure. Specific methodology for mechanical, electrical, and structural component screening is discussed below.
2.1.5.1.3 Conclusion Based on its review of the LRA, the screening implementation procedures, and a sampling of screening results, the staff determines that the applicants screening methodology is consistent with SRP-LR guidance and capable of identifying passive, long-lived components within the scope of license renewal and subject to an AMR. The staff determines that the applicants process for identifying component types and commodity groups subject to an AMR meets 10 CFR 54.21 requirements and, therefore, is acceptable.
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2.1.5.2 Mechanical Component Screening 2.1.5.2.1 Summary of Technical Information in the Application LRA Section 2.1.2.1 describes the screening methodology for identifying passive and long-lived mechanical components that are subject to an AMR. After the mechanical systems components were determined to be within the scope of license renewal, the applicant initiated the screening process for the mechanical SCs components. The process used at HNP to identify mechanical components subject to an AMR is as follows:
* Mechanical components and commodities within systems credited with intended functions were identified
* Components and commodities which perform mechanical component intended functions were identified
* Components determined to be not subject to an AMR were screened out. These include components that are: (a) active, short-lived or replaced on qualified life or specific time period, (b) not credited with performance of a mechanical intended function, and (c) excluded by NRC regulations for license renewal.
Each system identified during scoping as being within the scope of license renewal is reviewed to identify passive mechanical components that support the system intended function. The classification as an active or passive component was determined based on evaluation of the component description and type. In its determination of passive components subject to an AMR, the applicant used the guidance provided in NEI 95-10, Appendix B and the requirements of 10 CFR 54.21(a)(1)(I). At HNP, electrical and I&C components that are within the scope of license renewal solely because they perform a system pressure boundary function are treated as mechanical component and/or commodities for the purposes of mechanical screening.
The intended functions for a system are used as input to the screening process. The system intended functions, together with component information in the PassPort EDB, the scoping evaluation pursuant to 10 CFR 54.4(a)(2), the regulated event scoping evaluations pursuant to 10 CFR 54.4(a)(3), and applicable system drawings were used to identify the passive components requiring AMR.
Additionally, the applicant utilized a set of screening filters to determine which mechanical components are subject to an AMR and meet the requirements of 10 CFR 54.21(a)(1). The application of these filters and determination of the mechanical components subject to an AMR consisted of:
* component active or passive function
* components constituting a complex assembly
* components subject to periodic replacement 2-26
* Evaluation of consumable items based on the staff guidance provided in SRP-LR, Table 2.1-3, which included: (a) packing, gaskets, component seals and o-rings; (b) structural sealants; (c) oil, greases, and component filters; and (d) system filters, fire extinguishers, fire hoses, and air packs, and
* Component intended functions identification. Each component subject to an AMR was evaluated to determine component-level mechanical function performed without moving parts or change in configuration, in fulfilling and supporting system intended functions.
LRA Section 2.3 summarizes the screening results of the mechanical components. The mechanical component screening methodology and results are recorded in HNP screening calculations identified in the Audit Report. Components that were determined to be short-lived were eliminated from the AMR process and the basis for the classification as short-lived was recorded in the license renewal database.
2.1.5.2.2 Staff Evaluation The staff evaluated the applicants mechanical screening methodology described in LRA Section 2.1.2.1. In addition, during its audit, the staff reviewed the applicants corporate-level implementing procedures and HNP license renewal mechanical screening calculations, which provide detailed implementation guidance on the applicants process for identifying and screening mechanical components that are subject to an AMR. The screening calculations delineate all mechanical components that perform or support an intended function and are passive and long-lived are subject to an AMR. Also during the audit, the staff discussed, in detail, the HNP screening process and the AMR results with the applicants license renewal team who performed these screening evaluations. Based on its review and evaluation of applicants documentation and discussions with its license renewal personnel, the staff identified the following screening process for mechanical components.
The mechanical component screening process began with the results from the scoping process. For each mechanical system within the scope of license renewal, the screening process was initiated with a review of the EDB database, system license renewal boundary drawings, and bulk screening of the components. To identify system components required to perform a system intended function, the applicant initially generated a listing of mechanical system components based on information derived from the EDB equipment type and system CLB documents, the FSAR, DBDs, system description, vendor manuals, and walkdowns. By applying the screening filter criteria, the active and passive/long-lived components were identified. The active and short-lived components were screened-out, and those components that support the system intended functions and that are passive and long-lived were identified as items requiring an AMR. In addition, the screening results for each mechanical system within the scope of license renewal were formulated into tables, such as, items requiring an AMR and items eliminated by individual evaluation, and these tables were incorporated into license renewal mechanical screening calculations as attachments. The components that are within the scope of license renewal for 10 CFR 54.4(a)(1) and (a)(3) are highlighted in green on the boundary drawings. The components within the scope of license renewal for 10 CFR 54.4(a)(2) are not highlighted.
PassPort EDB uses an equipment type designation which corresponds to the component types presented in NEI 95-10, Appendix B. Items that are not subject to replacement based on a 2-27
 
qualified life or specified time period per 10 CFR 54.21(a)(1)(i) are subject to an AMR. Also, the housings for active components (e.g., pump casings, valve bodies, fan and damper housings) that support the component intended function in a passive manner are subject to an AMR.
Detailed screening is performed for major components within mechanical systems by dividing into subcomponents and screened to a higher level of detail.
The staff verified that the applicant performed the screening review in accordance with the implementing procedures and captured pertinent component information such as materials, environments, equipment/component type, intended function(s), and reason for AMR requirement. The staff also verified that the applicant has implemented the guidance in the staffs SRP and industry standard NEI 95-10 and had followed that guidance in performing the screening effort. In addition, during its audit, the staff confirmed that the applicant developed sufficiently detailed procedures for the screening of mechanical systems, implemented those procedures, and adequately documented the results in the associated AMR reports.
Additionally, during the audit, the staff reviewed the screening activities associated with the AFW and the PASS systems. The staff reviewed the system intended functions and associated source documents identified for these systems, the P&IDs, and the associated screening documented in the screening results and AMR reports. The staff did not identify any discrepancies with the evaluation, and determined that the applicant has adequately followed the process documented in the license renewal project instruction, and adequately documented the results in the screening and AMR reports of the above systems.
2.1.5.2.3 Conclusion Based on its review of the LRA, the screening implementation procedures, and a sample of AFW and PASS system screening results, the staff determines that the applicant's mechanical component screening methodology is consistent with SRP-LR guidance. The staff concludes that the applicants methodology for identification of passive, long-lived mechanical components within the scope of license renewal and subject to an AMR meets 10 CFR 54.21(a)(1) requirements.
2.1.5.3 Structural Component Screening 2.1.5.3.1 Summary of Technical Information in the Application LRA Section 2.1.2 describes the process for identifying the in-scope SCs that require an AMR and justifies the process with respect to requirements of an IPA pursuant to 10 CFR 54.21(a).
The screening process was performed on each structure identified to be within the scope of license renewal. This method evaluated the individual SCs included within in-scope structures to identify specific SCs or SC commodity groups that require an AMR.
A bulk screening process was employed which consisted of grouping together typical components and screening them as a single commodity. Implementation of a bulk screening process requires components be grouped by similarity of both construction and function. An active or passive determination was performed on the commodity groups based on whether the commodity supports its intended function without moving parts or without a change in 2-28
 
configuration or properties. A determination of commodity replacement based on a qualified life or specified time period was performed for each commodity type.
Civil/structural screening was performed for HNP structures on a structure basis; commodities located within the specific structure being screened were addressed as part of the structure.
Civil/structural commodities associated with all systems were addressed as part of the structure in which they are located, whether or not they are part of a mechanical or electrical system. The identification of commodities for a specific structure was performed using the PassPort EDB location data, design drawings, general arrangement drawings, penetration drawings, plant modifications, the FSAR, DBDs, system descriptions, and plant walkdowns.
The commodity specific intended functions were developed based on comparison of the potential intended functions from the generic commodity groups to the specific intended functions of the structure and the PassPort EDB component quality classification. The screening process reviewed the PassPort EDB equipment types, design drawings, general arrangement drawings, plant modifications, the FSAR, DBDs, system descriptions, and plant walkdown results within each structure and developed a list of commodities within that structure requiring an AMR. Mechanical and electrical components located in the structure were considered in the assignment of intended functions to the structure. Those SCs that have a component or commodity intended function that supports a structure intended function are subject to an AMR.
2.1.5.3.2 Staff Evaluation The staff reviewed the applicants methodology for identifying structural components that are subject to an AMR as required in 10 CFR 54.21(a)(1). As part of this review, the staff discussed the methodology with the applicant, reviewed the documentation developed to support the activity, and evaluated the screening results for several structures that were identified to be within the scope of license renewal.
The applicants license renewal civil screening calculations describe the applicants process for identifying and screening structural components that are subject to an AMR. The calculations stated that structural components that perform an intended function and are passive and long-lived are subject to an AMR. The screening results for structures within the scope of license renewal were described in attachments to the calculation.
The applicant used a bulk screening approach which identified the grouping of civil/structural components by similarity of construction and function, and established a list of typical civil/structural commodity types along with the potential intended functions. The civil commodities were identified through a review of industry experience (e.g., NEI 95-10, Revision 6 and previous LRAs), NRC guidance (e.g., SRP-LR and GALL Report), as well as the plants CLB documents. The applicant then performed an active or passive determination based on whether the commodity supports its intended function with or without moving parts or a change in configuration or properties. The long-lived determination was performed for each commodity type depending on whether the commodity was replaced based on qualified life or specified time.
The applicant performed the screening review in accordance with its license renewal calculations and included the structure description, intended functions, evaluation boundary, 2-29
 
seismic interaction areas, the screening process, the screening results, the identification of systems in the structure, and references. The staff verified that the applicant used the lists of passive SCs embodied in the regulatory guidance and supplemented that list with additional items unique to the site or for which a direct match to the generic lists did not exist (i.e.,
material/environment combinations). The applicant determined that components which support or interface with electrical components (e.g., cable trays, conduits, instrument racks, panels and enclosures) were assessed as structural components.
The boundary for a structure was the entire building including base slabs, foundations, walls, beams, slabs, and steel superstructure. The license renewal calculations identified each the appropriate civil/structural commodities and indicated if the commodity is subject to an AMR.
The applicant provided the staff with a detailed discussion that described the screening methodology, as well as the screening results.
The staff also examined the applicants results from the implementation of this methodology by reviewing several of the plant structures identified as being within the scope of license renewal.
As part of this review, the staff reviewed the license renewal calculations to verify that the applicant performed a comprehensive evaluation and identified the relevant structural components as part of the applicants evaluation. The review included the evaluation of commodities within the scope of license renewal, the corresponding intended functions, and the resulting list of commodities subject to an AMR. The staff did not identify any discrepancies between the methodology documented and the implementation results.
2.1.5.3.3 Conclusion Based on its review of the LRA, the applicant's detailed screening implementation procedures, and a sampling of structural screening results, the staff concludes that the applicant's methodology for identification of passive, long-lived structural component types within the scope of license renewal and subject to an AMR meets 10 CFR 54.21(a)(1) requirements.
2.1.5.4 Electrical Component Screening 2.1.5.4.1 Summary of Technical Information in the Application The applicants method used determine which electrical and I&C components were subject to an AMR was based on the component commodity group approach, consistent with the guidance of NEI 95-10. The applicant used PassPort EDB information to develop a comprehensive list of electrical component types present in the systems and structures within the scope of license renewal. In addition, the applicant used the Electrical Power Research Institute (EPRI) License Renewal Electrical Handbook and plant design documentation to identify electrical equipment and component types within the electrical/I&C and mechanical systems and structures determined to be within the scope of license renewal. The applicant reviewed plant-specific documentation including drawings, technical manuals, and plant modification packages.
The component types associated with the electrical and I&C systems within the scope of license renewal were organized into commodity groupings using the guidance contained in NEI 95-10, Appendix B, regarding grouping of components based on similar design and functional 2-30
 
characteristics. The electrical and I&C component commodity groups that perform an intended function without moving parts or without a change in configuration or properties, were identified.
Commodity groups that have passive functions may be subject to an AMR and were identified by this step.
For the passive electrical and I&C component commodity groups, component commodity groups that are not subject to replacement based on a qualified life or specified time period, were identified as requiring an AMR. Commodity group components that are replaced based on qualified life or specified time period (i.e., short-lived components) are not subject to an AMR.
The electrical screening process identified the intended functions of the electrical commodity groups subject to an AMR using information contained in the SRP-LR and industry experience.
Electrical and I&C components that were determined to be within the scope of license renewal and passive and long-lived were subject to an AMR.
2.1.5.4.2 Staff Evaluation The staff reviewed the applicants methodology used for electrical screening in LRA Section 2.1.2.3 and the applicants guidance, implementation procedures, and reports. The applicant assembled a table of commodities which were determined to meet the passive criteria and which were grouped in accordance with the guidance contained in NEI 95-10. The applicant evaluated the identified, passive commodities to determine whether they were subject to replacement based on a qualified life or specified time period (short-lived), or not subject to replacement based on a qualified life or specified time period (long-lived). The remaining passive, long-lived components were determined to be subject to an AMR. The staff reviewed the screening of selected components to verify the correct implementation of the applicants implementing procedures and reports.
The applicant performed a review of fuses and fuseholders which were not part of a panel or assembly and identified approximately ten fuseholders which met the criteria and were subsequently included within the scope of license renewal. The applicant determined that the fuses would not be removed from the fuseholder during operation or maintenance (not required for isolation) and were located in an environment such that the fuseholders were not subject to an AMR.
The applicant performed a review of tie wraps and determined that tie wraps were not required for HNP seismic qualification, were not taken credit for any purpose in the CLB, and were determined to have potential effect on the performance of safety-related intended functions. No tie wraps were determined to be within the scope of license renewal.
2.1.5.4.3 Conclusion The staff reviewed the LRA, procedures, electrical drawings, and a sample of the results of the screening methodology. The staff determines that the applicants methodology was consistent with the description provided in the LRA and the applicants implementing procedures. On the basis of a review of information contained in the LRA, the applicants screening implementation procedures, and a sampling review of electrical screening results, the staff concludes that the applicants methodology for identification of electrical commodity groups subject to an AMR is consistent with the requirements of 10 CFR 54.21(a)(1), and is therefore acceptable.
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2.1.5.5 Conclusion for Screening Methodology Based on its review of the LRA and the screening implementation procedures, discussions with the applicants staff, and a sample review of screening results, the staff determines that the applicant's screening methodology is consistent with the guidance of the SRP-LR and has identified passive, long-lived components within the scope of license renewal and subject to an AMR. The staff concludes that the applicants methodology is consistent with the requirements of 10 CFR 54.21(a)(1), and, therefore, acceptable.
2.1.6 Summary of Evaluation Findings The information in LRA Section 2.1, the supporting information in the scoping and screening implementation procedures and reports, and the information presented during the scoping and screening methodology audit formed the basis of the staffs determination that the applicants scoping and screening methodology was consistent with the requirements of the Rule. Based on this determination, the staff concludes that the applicants methodology for identifying SSCs within the scope of license renewal and SCs requiring an AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1), and, therefore, acceptable.
2.2 Plant-Level Scoping Results 2.2.1 Introduction In LRA Section 2.1, the applicant described the methodology for identifying SSCs within the scope of license renewal. In LRA Section 2.2, the applicant used the scoping methodology to determine which SSCs must be included within the scope of license renewal. The staff reviewed the plant-level scoping results to determine whether the applicant has properly identified all systems and structures relied upon to mitigate DBEs, as required by 10 CFR 54.4(a)(1),
systems and structures the failure of which could prevent satisfactory accomplishment of any safety-related functions, as required by 10 CFR 54.4(a)(2), and systems and structures relied on in safety analyses or plant evaluations to perform functions required by regulations referenced in 10 CFR 54.4(a)(3).
2.2.2 Summary of Technical Information in the Application In LRA Table 2.2-1, the applicant listed three aspects of each plant mechanical system: system name, whether it was within the scope of license renewal, and a screening result application subsection (if determined to be in-scope). Likewise, in LRA Table 2.2-2, the applicant provided a list of the plant structures that are within the scope of license renewal and their applicable subsection. Based on the DBE considered in: the plant's CLB, other CLB information relating to nonsafety-related systems and structures, and regulated events identified in 10 CFR 54.4 (a)(3), the applicant identified plant level systems and structures within the scope of license renewal.
In LRA Section 2.1.1.2, the applicant described the license renewal scoping methodology used in identifying applicable SSCs for spatial interactions. The applicant evaluated non-connected, nonsafety-related systems for their potential to adversely affect safety-related SSCs. The applicant then included nonsafety-related systems with the potential to adversely affect 2-32
 
safety-related SSCs within the scope of license renewal to protect safety-related SSCs from the consequences of failures of the nonsafety-related systems.
2.2.3 Staff Evaluation In LRA Section 2.1, the applicant described its methodology for identifying systems and structures within the scope of license renewal and subject to an AMR. The staff reviewed the scoping and screening methodology and provided its evaluation in SER Section 2.1. To verify that the applicant properly implemented its methodology, the staff focused its review on the implementation results shown in LRA Tables 2.2-1, 2.2-2, and 2.2-3.
The staff determined whether the applicant properly identified the systems and structures within the scope of license renewal in accordance with 10 CFR 54.4. The staff reviewed selected systems and structures that the applicant did not identify as within the scope of license renewal to verify whether the systems and structures have any intended functions requiring their inclusion within the scope of license renewal. The staff's review of the applicant's implementation was conducted in accordance with the guidance in SRP-LR Section 2.2, Plant Level Scoping Results.
The staff reviewed LRA Section 2.1.1.2 Nonsafety-related Criteria Pursuant to 10 CFR 54.4(a)(2) and the UFSAR using the evaluation methodology described in SER Section 2.1 and the guidance in SRP- LR Section 2.1. The staff reviewed sections of the UFSAR, based on the systems and structures listed in LRA Tables 2.2-1, 2.2-2, and 2.2-3, to determine if there were any systems or structures that may have intended functions within the scope of license renewal, as defined by 10 CFR 54.4, but were omitted from the scope of license renewal. The staff did not identify any omissions.
During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant did not omit any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In its review of LRA Section 2.1.1.2, the staff identified areas in which additional information was necessary to complete the review of the applicants scoping and screening results. The staff noted that the LRA stated that the turbine building and the waste processing building contain components designated as safety-related according to the plants EDB. In the LRA, the applicant concluded that no safety-related systems, in the turbine building and waste processing building, are brought into scope of license renewal based on their potential to adversely affect safety-related systems. In RAI 2.1.1.2-1, dated August 20, 2007, the staff asked the applicant to provide details of the evaluation performed that allowed the exclusion of the safety-related SSCs within the turbine building and within the waste processing building from the 10 CFR 54.4(a)(2) criterion for spatial interactions.
In their response, dated September 18, 2007, the applicant stated that system scoping relied heavily on reviews of the plant UFSAR, CLB, and EDB for component quality classifications.
The applicant further stated that these plant information sources contributed to a determination 2-33
 
of whether a system met the license renewal definition of 10 CFR 54.4(a)(1). The applicant further explained that results of the evaluation indicated that occasionally the plant information sources are more conservative in assigning the quality classification than is intended in 10 CFR 54.4. The applicant described the diesel generator service water pipe tunnel and the attached Class 1 electrical cable area above the pipe tunnel. The applicant stated that the tunnel contains safety-related components and is part of the turbine building. This area was designed and constructed to seismic Category I requirements and is completely enclosed, with a door at each end. The applicant supported its exclusion of this equipment from 10 CFR 54.4(a)(2) for nonsafety-related system spatial interactions, based upon the premise that the safety-related components are completely enclosed within a robust structure, designed and constructed for that purpose as stated in the plant CLB. NRC staff inspected the diesel generator service water pipe tunnel and Class 1 electrical cable area above the pipe tunnel to verify that this area is completely enclosed, and there is no potential for nonsafety-related system interactions. The staff found that the subject area was completely enclosed with a door at each end and documented its finding in the NRC Inspection Report 05000400/2007007 dated September 10, 2007 (ML072530894). This structure containing the diesel generator service water piping and the attached Class 1 electrical cable area above it are part of the turbine building structure and are included in scope of license renewal.
The applicant performed an evaluation of other equipment in the turbine building identified as safety-related, (i.e., feedwater system flow transmitters, feedwater regulating valves, and associated bypass valves). Their evaluation determined that this equipment did not meet the license renewal definition of safety-related; therefore, the equipment was not included within the scope of 10 CFR 54.4(a)(1). Similarly, the applicant identified equipment in the waste processing building, (e.g., waste gas decay tanks, associated piping and valves and radiation monitor) did not meet the license renewal definition of safety-related; therefore, they did not include them in scope under 10 CFR 54.4(a)(1).
The applicant stated that the LRA will be revised to document that the feedwater system components in the turbine building and the waste processing system components in the waste processing building, described above are not safety-related in accordance with 10 CFR 54.4(a)(1). The applicant concluded that even though the components described above are not safety-related, the LRA will be revised to conservatively include them within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Further, the applicant will reflect in the LRA that since there are no safety-related components in the turbine building and waste processing building, 10 CFR 54.4(a)(2) for spatial interactions is not applicable and will not be discussed further.
However, based on its review, the NRC staff finds that the applicant did not properly implement the LRA scoping methodology described in LRA Section 2.1.1, Further, the applicants response to RAI 2.1.1.2-1 is in conflict with the current licensing basis for the feedwater regulating valves. In Section 15.1.5, the UFSAR states that the feedwater regulating valves do provide a safety-related function, which is redundant isolation of feedwater in the event of a main steam line break, to mitigate the consequences of an accident in accordance with 10 CFR 54.4(a)(1)(iii). Furthermore, in Section 10.4.7, the UFSAR states that the valves are designed to ASME Section III, Class 3, Seismic Category I. Therefore, the staff concludes that the feedwater regulating and bypass valves meet the definition and functional description for components classified as (a)(1); hence, they should be included in the scope of license renewal and subject to aging management based upon criterion 10 CFR 54.4(a)(1).
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By letter dated January 14, 2008, the NRC staff sent RAIs to the applicant to further evaluate the disposition of this equipment and justify their position. The applicants response, dated January 22, 2008, maintains that these valves are important to safety, but are not safety-related and therefore, they meet the criteria of 10 CFR 54.4(a)(2). The BOP staff position remains that the main feedwater regulating and bypass valves are not currently correctly categorized in the application. By definition, these valves fulfill a safety-related function; therefore, they should be included in scope under 10CFR54.4(a)(1). This issue has been identified as an open item requiring dispositioning prior to final approval of this safety evaluation.
In its review of LRA Section 2.1.1.2, the staff noted the applicant describes their methodology in identifying seismic-connected piping when nonsafety-related portions of a system connect to safety-related portions the system. This section identifies the instrument air system, service air system, bulk nitrogen storage system, hydrogen gas system, and penetration pressurization system as those with nonsafety-related portions to seismically-connected piping. The staff also noted that in LRA Table 2.0-1, Intended Function Abbreviations and Definitions, the applicant defines the intended functions assigned to systems within the scope of license renewal, and in LRA Table 2.0-1, the applicant identifies M-4" as Structural Support which provides structural support/seismic integrity. The staff reviewed the intended functions for the identified systems and noted that M-4" was not identified; however, M-1" for Pressure Boundary was assigned.
In RAI 2.1.1.2-2 dated August 20, 2007, the staff asked the applicant to explain why the Intended Function M-4" was not assigned to these systems in accordance with the methodology in LRA Section 2.1.1.2.
In its response dated September 18, 2007, the applicant stated that under the methodology used to evaluate systems for scoping, the M-1" pressure boundary function envelops the structural/seismic support function for nonsafety-related connected piping described above. In addition, the applicant identified this methodology is contained in license renewal project procedures and that M-1" would be used for connected piping. Further, the applicant explained that the systems identified above all have the M-1" intended function.
Based on its review, the staff finds the applicants response to RAI 2.1.1.2-2 acceptable because it adequately explained that for the systems identified above, the M-1" intended function was assigned and that the license renewal project procedures identified that nonsafety-related piping connected to safety-related systems are enveloped by this intended function.
Therefore the staffs concern described in RAI 2.1.1.2-2 is resolved.
In its review of LRA Section 2.1.2.1, the staff identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. In RAI 2.1.2.1-1 dated August 20, 2007, the staff noted that in LRA Section 2.1.2.1, the applicant describes the process used to identify mechanical components subject to AMR. The applicant states in LRA Section 2.1.2.1, that in-scope mechanical components with no mechanical intended function are assigned a screening result of "no mechanical intended function," and are not subject to AMR. Further, the staff noted that the LRA states that in a limited number of cases, there are in-scope mechanical components that do not support a mechanical system intended function but are in the scope of license renewal because of their potential to damage safety-related components through direct impact during a seismic event. The staff asked the applicant to identify the in-scope mechanical components with "no mechanical intended function" that are not subject to an AMR and describe why they are not subject to an AMR.
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In its response dated September 18, 2007, the applicant stated that under the methodology described in license renewal project procedures used to evaluate components for screening in accordance with 10 CFR 54.21(a), three general cases were identified where components were assigned "no mechanical function." The applicant stated that the three cases with example are:
: 1.      Not Used/Temporary/Not Installed - this case accounts for tools and equipment that have unique EDB identifiers, but are no longer in the plant, are portable, or not used during normal plant operation (e.g.,
reactor head guide studs, service water booster pump suction startup strainer elements, containment integrated leak rate test equipment, and fuel transfer components).
: 2.      No Impacts from Failure - the impacts of failure were evaluated and the failure of the component type or in some cases subcomponent type would have no adverse effect on system intended function, e.g., selected RCP oil spill protection system components inside the oil spill enclosure, solenoid operated valves that upon failure would have no impact on safety, such as those used for venting air from air operated containment isolation valve operators, auto stop trip solenoid valves that upon failure would result in closure of steam turbine valves.
: 3.      Covered by Civil or Electrical Function - the component type that was typically mechanical was later found to have a civil or electrical function e.g., reactor head seismic tie rods, pressurizer electric heaters, HVAC electric heaters, lightning arrester straps.
Based on its review, the staff finds the applicant's response to RAI 2.1.2.1-1 acceptable because it adequately explains that for the components within the scope of license renewal as identified in cases above have been evaluated using methodology in license renewal project procedures. In the first case, components that are not permanently installed or are designated as tools can be excluded from an AMR if evaluated. In the second case, components that fail without impeding system intended functions can be excluded from an AMR if evaluated. In the third case, license renewal project procedures can evaluate a component's function and identify its correct classification, such as a heater performing no pressure boundary function in addition to its electrical active function. Therefore the staff's concern described in RAI 2.1.2.1-1 is resolved.
2.2.4 Conclusion The staff reviewed LRA Section 2.2, the RAI response, and the FSAR supporting information to determine whether the applicant failed to properly identify any systems and structures within the scope of license renewal. Except for the open item regarding the feedwater regulatory and bypass valves, the staff finds no other omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified in accordance with 10 CFR 54.4 the systems and structures within the scope of license renewal.
2.3 Scoping and Screening Results - Mechanical Systems 2-36
 
This section documents the staffs review of the applicants scoping and screening results for mechanical systems. Specifically, this section discusses:
* reactor vessel, internals, and reactor coolant system
* engineered safety features (ESF) systems
* auxiliary systems In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive, long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its methodology, the staffs review focused on the implementation results. This focus allowed the staff to confirm that there were no omissions of mechanical system components that meet the scoping criteria and are subject to an AMR.
The staffs evaluation of the information in the LRA was the same for all mechanical systems.
The objective was to determine whether the applicant has identified, in accordance with 10 CFR 54.4, components and supporting structures for mechanical systems that appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicants screening results to verify that all passive, long-lived components were subject to an AMR in accordance with 10 CFR 54.21(a)(1).
In its scoping evaluation, the staff reviewed the applicable LRA sections and drawings, focusing on components that have not been identified as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the FSAR, for each mechanical system to determine whether the applicant has omitted from the scope of license renewal components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed the licensing basis documents to determine whether the LRA specified all intended functions delineated under 10 CFR 54.4(a). The staff requested additional information to resolve any omissions or discrepancies identified.
After its review of the scoping results, the staff evaluated the applicants screening results. For those SCs with intended functions, the staff sought to determine whether (1) the functions are performed with moving parts or a change in configuration or properties or (2) the SCs are subject to replacement after a qualified life or specified time period, as described in 10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that these SCs were subject to an AMR, as required by 10 CFR 54.21(a)(1). The staff requested additional information to resolve any omissions or discrepancies identified.
Two-Tier Scoping Review Process for Balance of Plant Systems. In the LRA, the applicant identified 110 mechanical systems among which 72 are balance of plant (BOP) systems, excluding fire protection, HVAC, and containment systems. These BOP systems include most of the auxiliary systems in LRA Section 2.3.3 and all of the steam and power conversion systems in LRA Section 2.3.4. The staff performed a two-tier scoping review for the 72 BOP systems.
In the two-tier scoping review, the staff reviewed the LRA and FSAR descriptions focusing on the system intended function to screen all the BOP systems into two types of review, Tier-2 (detailed) and Tier-1 (other), based on the following screening criteria:
* safety importance and/or risk significance 2-37
* potential for system failure to cause failure of redundant safety system trains
* operating experience indicating likely passive failures
* systems subject to omissions based on previous LRA reviews Examples of the safety important/risk significant systems are the emergency diesel generator (EDG) and support systems, the AFW, and the essential service water system based on the results of an individual plant examination for NHP. An example of a system whose failure could result in common cause failure of redundant trains is a drain system providing flood protection.
Examples of systems with identified omissions in previous LRA reviews include the fuel pool cooling and fuel handling and storage system, and makeup water sources to safety systems.
From the 72 BOP systems, the staff selected 31 systems for a detailed, Tier-2, scoping review as described above. Tier-2 requires the review of detailed boundary drawings in accordance with SRP-LR NUREG-1800, Section 2.3. The staff performed a Tier-2 review of the following 31 systems:
* Circulating Water System
* Normal Service Water System
* Emergency Service Water System
* Component Cooling Water System
* Essential Services Chilled Water System
* Emergency Screen Wash System
* Emergency Diesel Generator System
* Diesel Generator Fuel Oil Storage and Transfer System
* Diesel Generator Lubrication System
* Diesel Generator Cooling Water System
* Diesel Generator Air Starting System
* Instrument Air System
* Service Air System
* Storm Drains System
* Radioactive Floor Drains System
* Radioactive Equipment Drains System
* Demineralized Water System
* Oily Waste Collection and Separation System
* Liquid Waste Processing System
* Radwaste Sampling System
* Refueling System
* Spent Fuel Pool Cooling System
* Spent Fuel Pool Cleanup System
* Containment Cooling System
* Steam Generator Blowdown System
* Main Steam Supply System
* Steam Dump System
* Feedwater System
* Auxiliary Feedwater System
* Condensate Storage System
* Secondary Sampling System For the remaining 41 BOP systems, the staff performed a Tier-1 review of the LRA (that do not 2-38
 
require detailed boundary drawings) and the FSAR to identify apparent missing components that are subject to an AMR. The staff performed a Tier-1 review of the following 41 systems:
* Cooling Tower System
* Cooling Tower Makeup System
* Screen Wash System
* Main Reservoir Auxiliary Equipment
* Auxiliary Reservoir Auxiliary Equipment
* Waste Processing Building Cooling Water System
* Non-essential Services Chilled Water System
* Generator Gas System
* Hydrogen Seal Oil System
* Security Power System
* Bulk Nitrogen Storage System
* Hydrogen Gas System
* Oily Drains System
* Secondary Waste System
* Laundry and Hot Shower System
* Upflow Filter System
* Potable and Sanitary Water System
* Filter Backwash System
* Secondary Waste Treatment System
* Gaseous Waste Processing System
* New Fuel Handling System
* Spent Fuel System
* Spent Fuel Cask Decontamination and Spray System
* Spent Resin Storage and Transfer System
* Bridge Crane Equipment
* Fuel Cask Handling Crane System
* Fuel Handling Building Auxiliary Equipment
* Turbine Building Health Physics Room Auxiliary Equipment
* Polar Crane Auxiliary Equipment
* Elevator System
* Mechanical Components in Electrical Systems (Classified as an Electrical System)
* Monorail Hoists Equipment
* Steam Generator Chemical Addition System
* Auxiliary Boiler/steam System
* Feedwater Heater Drains and Vents System
* Auxiliary Steam Condensate System
* Condensate System
* Steam Generator Wet Lay up System
* Turbine System
* Digital-electric Hydraulic System
* Turbine-generator Lube Oil System The staff verified that there is no risk significant system in the above list by examining the results of the applicant's Environmental Report, Appendix E. None of the systems identified for a Tier-1 review are dominant contributors to the risk reduction worth rankings to core damage frequency, nor are these systems involved in the dominant initiating events.
2-39
 
Systems Identified for Inspection. The staff recommended that the inspection be used to verify scoping results pursuant to 10 CFR 54.4(a)(2). To implement this recommendation in reviewing the LRA, the staff identified four systems for the regional inspection team to include in its scoping and screening inspection.
These systems were included within the scope of license renewal by the applicant pursuant to the 10 CFR 54.4(a)(2) review. The staff requested that the inspection include a sampling review of the Engineering Report (if available), plant layout drawings, and other documentation, as well as walkdowns of the plant areas that contain these systems and associated components. The following are the list of systems, which the staff recommended for inspection:
* Screen Wash System
* Non-essential Chilled Water System
* Waste Processing Building Cooling Water System
* Turbine Generator Lube Oil System In the HNP - NRC Inspection Report 05000400/2007007 dated September 10, 2007, the inspectors documented their review of the applicant's screening and scoping analysis for the above nonsafety-related systems to assess compliance with 10 CFR 54.4(a)(2). The review included the applicant's calculation that assessed the system and component applicability pursuant to 10 CFR 54.4(a)(2), applicable plant drawings, and a visual examination of the in-plant configuration to attempt to identify any nonsafety-related systems located in proximity to safety-related systems and to assess compliance with 10 CFR 54.4(a)(2). The inspectors concluded that the applicant had appropriately implemented the criteria in accordance with 10 CFR 54.4(a)(2) in the identification of in-scope SSCs for these systems.
The inspectors visually examined the service water intake structure and the adjacent CTMU strainer pit and identified no potential for spatial interaction between nonsafety-related and safety-related SSCs at this location. The inspectors reviewed the security power system diesel manual, system drawings, and the scoping calculation document and field inspected the system equipment. The inspectors did not identify any components that were incorrectly omitted from the AMR.
In RAI 2.3-1 dated August 20, 2007, the staff noted that, in several LRA sections for the scoping results of numerous systems, component types such as valves, piping, expansion joints, temperature elements, thermowells, flexible connections, filters, strainers, silencers, accumulators, closure bolting, drain traps, detectors, and pumps were not specifically identified in their associated LRA sections, although they were highlighted in license renewal boundary diagrams as components within the scope of license renewal pursuant to 10 CFR 54.4(a). The staff noted that instead of specific component types, the term "piping, piping components, and piping elements" is used. The staff asked the applicant to explain how each of these components is represented in the LRA and to explain what components the term "piping, piping components, and piping elements" includes for each of the following systems:
* Section 2.3.3.6        Circulating Water System
* Section 2.3.3.18      Emergency Screen Wash System
* Section 2.3.3.21      Emergency Diesel Generator System
* Section 2.3.3.27      Instrument Air System
* Section 2.3.3.28      Service Air System 2-40
* Section 2.3.3.29      Bulk Nitrogen Storage System
* Section 2.3.3.30      Hydrogen Gas Storage System
* Section 2.3.3.37      Laundry and Hot Shower System
* Section 2.3.3.54      Spent Fuel Cask Decontamination and Spray System
* Section 2.3.3.81      Mechanical Components in Electrical Systems
* Section 2.3.4.4        Main Steam Dump System
* Section 2.3.4.14      Turbine System In its response dated September 18, 2007, the applicant stated that the GALL Report defines the term "piping, piping components, and piping elements" as a general category including various features of piping systems that are within the scope of license renewal (i.e., piping, tubing, flow elements, orifices, flex hoses, etc.). The applicant further stated that the GALL Report, Revision 1, which was used in the preparation of the LRA incorporates the term "piping, piping components, and piping elements" to replace various combinations of component types in previous LRAs. The applicant's response included a detailed table of components addressing each of the staff's questions about each LRA section identified above.
Based on its review, the staff finds the applicant's response to RAI 2.3-1 acceptable because it adequately explains how each of the component types were represented using the guidance in the GALL Report, Revision 1, for the term "piping, piping components, and piping elements" and that a detailed table identifying components generically represented by this term was reviewed by the staff. The staff notes that the use of "piping, piping components, and piping elements" was not specifically addressed in the LRA other than the reference to the use of the GALL Report in its preparation. Therefore, the staff's concern described in RAI 2.3-1 is resolved.
2.3.1 Reactor Vessel, Internals, and Reactor Coolant System LRA Section 2.3.1 identifies the reactor vessel, internals, and reactor coolant system SCs subject to an AMR for license renewal.
The applicant described the supporting SCs of the reactor vessel, internals, and reactor coolant system in the following LRA sections:
* 2.3.1.1        reactor vessel and internals
* 2.3.1.2        incore instrumentation system
* 2.3.1.3        reactor coolant system
* 2.3.1.4        reactor coolant pump and motor
* 2.3.1.5        pressurizer
* 2.3.1.6        steam generator 2.3.1.1 Reactor Vessel and Internals 2.3.1.1.1 Summary of Technical Information in the Application LRA Section 2.3.1.1 describes the reactor vessel and internals, which are reactor coolant system (RCS) parts capable of accommodating the temperatures and pressures of RCS operational transients. The reactor vessel contains and supports the reactor vessel internals 2-41
 
which include the reactor core, core support structures, control rods, and other core parts. The reactor vessel is one of the major components within the reactor coolant pressure boundary (RCPB). The reactor vessel exterior has two types of insulation, mostly canned stainless steel reflective sheets at least three inches thick and contoured to match the vessel geometry and in the portion of the vessel with highest neutron leakage a high-efficiency, high-temperature insulation bonded to a layer of neutron attenuation material of varying thickness. All of the insulation and insulating/shielding modules are removable but access to the insulation/shielding is limited by the surrounding concrete.
The components of the reactor vessel internals include of the lower core support structure, the upper core support structure, and the incore instrumentation support structure. The reactor vessel internals support the core, maintain fuel alignment, limit fuel assembly movement, maintain alignment between fuel assemblies and control rod drive mechanisms (CRDMs), direct reactor coolant flow past the fuel elements, direct reactor coolant flow to the pressure vessel head, and provide gamma and neutron shielding and guides for the incore instrumentation. The reactor vessel and internals include components required for the reactor vessel level indicating system (RVLIS). RVLIS instrumentation has a RG 1.97, Category 1, post-accident function of monitoring reactor coolant inventory. The RVLIS has capillary tubing and other components to support the containment isolation pressure boundary function.
The reactor vessel and internals contain safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the reactor vessel and internals potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the reactor vessel and internals perform functions that support fire protection, PTS, and EQ.
LRA Table 2.3.1-1 identifies reactor vessel and internals component types within the scope of license renewal and subject to an AMR:
* reactor vessel; closure head dome
* reactor vessel; closure head flange
* reactor vessel; closure head stud assembly
* reactor vessel; vessel flange leak detection line
* reactor vessel; CRDM head penetration nozzle
* reactor vessel; CRDM head penetration flange
* CRDM latch housings
* CRDM rod travel housings
* reactor vessel; CRDM head penetration thermal sleeves
* reactor vessel; head adapter plug
* reactor vessel; head lifting lugs
* reactor vessel; ventilation shroud support ring
* reactor vessel; seal assembly retaining clamps and closure bolting
* reactor vessel; seal assemblies (core exit thermocouples)
* reactor vessel; primary nozzles
* reactor vessel; primary nozzle support pads
* reactor vessel; primary nozzle safe ends
* reactor vessel; primary nozzle welds
* reactor vessel; upper shell
* reactor vessel; intermediate shell 2-42
* reactor vessel; lower shell
* reactor vessel; beltline welds
* reactor vessel; vessel flange and core support ledge
* reactor vessel; bottom head (dome and torus)
* reactor vessel; core support pads (clevis)
* reactor vessel; instrument tubes (bottom head)
* reactor vessel; head vent pipe (top head)
* upper internals; upper support plate
* upper internals; upper support column
* upper internals; upper support column bolts
* upper internals; upper support column spider
* upper internals; upper core plate
* upper internals; fuel alignment pins
* upper internals; hold-down spring
* upper internals; rod cluster control assembly (RCCA) guide tubes
* upper internals; RCCA guide tube bolts
* upper internals; RCCA guide tube support pins (split pins)
* upper internals; head and vessel alignment pins
* upper internals; head cooling spray nozzles
* upper internals; upper core plate alignment pins
* upper internals; upper instrumentation column, conduit, and supports
* lower internals; core barrel
* lower internals; core barrel flange
* lower internals; core barrel outlet nozzles
* lower internals; thermal shield
* lower internals; baffle and former plates
* lower internals; baffle and former bolts
* lower internals; lower core plate
* lower internals; fuel alignment pins
* lower internals; lower support forging
* lower internals; lower support plate columns
* lower internals; BMI columns
* lower internals; BMI column cruciform
* lower internals; lower support plate column bolts
* lower internals; radial support keys
* lower internals; radial support key bolts
* lower internals; clevis inserts
* lower internals; clevis insert bolts
* lower internals; tie plate (upper and lower)
* lower internals; diffuser plate
* lower internals; secondary core support
* lower internals; irradiation specimen guide
* lower internals; specimen plugs
* flux thimble guide tubes
* flux thimble seals
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements
* solenoid valves 2-43
 
The intended functions of the reactor vessel and internals component types within the scope of license renewal include:
* control rod assembly support, orientation, guidance, and protection
* passageway for the distribution of reactor coolant flow to the reactor core
* reactor core support and orientation
* passageway for incore instrumentation support, guidance, protection
* pressure-retaining boundary
* reactor pressure vessel gamma and neutron shielding
* secondary support to limit core support structure downward displacement
* structural support and seismic integrity
* thermal insulation 2.3.1.1.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.1 and FSAR Sections 3.9.5, 4.5, 5.1, 5.2, 5.3, and 7.7.1.9 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3, Scoping and Screening Results: Mechanical Systems.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.1.1.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the reactor vessel and internals components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.1.2 Incore Instrumentation System 2.3.1.2.1 Summary of Technical Information in the Application LRA Section 2.3.1.2 describes the incore instrumentation system, which is composed of thermocouples positioned to measure fuel assembly coolant outlet temperatures at preselected positions and fission chamber detectors that can be positioned in guide thimbles which run the length of selected fuel assemblies to measure the neutron flux distribution. The incore instrumentation obtains data from which fission power density distribution in the core, reactor coolant enthalpy distribution in the core, and fuel burn-up distribution may be determined. The incore instrumentation system has RVLIS I&C components. RVLIS and incore exit 2-44
 
thermocouples give the operator an advance warning of and monitor recovery from inadequate core cooling. The RVLIS instrumentation is not required to prevent or mitigate the consequences of an accident; however, it has an important post-accident monitoring function.
The incore instrumentation system has components needed for RG 1.97, Category 1, monitoring requirements (i.e., core exit thermocouple temperature). The incore instrumentation system includes components such as flux thimbles and seal assemblies required to maintain the RCS pressure boundary.
The incore instrumentation system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the incore instrumentation system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the incore instrumentation system performs functions that support fire protection and EQ.
LRA Table 2.3.1-2 identifies incore instrumentation system component types within the scope of license renewal and subject to an AMR:
* flux thimble tubes
* flux thimble isolation valves The intended function of the incore instrumentation system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.1.2.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.2 and FSAR Sections 4.4.4 and 7.7.1.9.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.1.2.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the incore instrumentation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.1.3 Reactor Coolant System 2.3.1.3.1 Summary of Technical Information in the Application 2-45
 
LRA Section 2.3.1.3 describes the RCS, which includes piping and components not otherwise included in the reactor vessel and internals, incore instrumentation, reactor coolant pump (RCP), pressurizer, or steam generator systems. The RCS consists of three similar heat transfer loops connected in parallel to the reactor vessel. Each loop contains an RCP, steam generator, piping, and valves. In addition, the system includes interconnecting piping and components of the pressurizer, pressurizer relief and safety valves, and the pressurizer relief tank (PRT).
RCS piping includes the interfacing piping of the following systems:
* chemical and volume control
* residual heat removal (RHR)
* safety injection
* sampling
* pressurizer (i.e., safety and relief valve discharge lines to the PRT)
* auxiliary support piping for the PRT
* RCS drain and instrument piping The RCS includes selected PRT piping. The PRT spray header and nitrogen supply piping penetrates containment and is, therefore, required for containment isolation. This piping is in the RCS; however, its containment isolation valves (CIVs) are in the pressurizer system. RCS piping connects with the RVLIS and includes components for RG 1.97, Category 1, monitoring requirements for system operating parameters.
The RCS contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the reactor coolant system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the reactor coolant system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.1-3 identifies reactor coolant system component types within the scope of license renewal and subject to an AMR:
* Class I piping, fittings, and branch connections less than nominal pipe size (NPS) 4
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the RCS component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.1.3.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.3 and FSAR Sections 5.1, 5.2, and 5.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that 2-46
 
the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.1.3.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the reactor coolant system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.1.4 Reactor Coolant Pump and Motor 2.3.1.4.1 Summary of Technical Information in the Application LRA Section 2.3.1.4 describes the RCP and motor. The RCP is a vertical, single-stage, controlled-leakage, centrifugal pump designed for large volumes of reactor coolant. The pump assembly has three major sections: the hydraulic suction, the seals, and the motor. Additional pump components are the shaft, pump radial bearing, thermal barrier heat exchanger assembly, coupling, spool piece, and motor stand. The RCP thermal barriers and RCP motor bearing oil coolers maintain the component cooling water (CCW) system pressure boundary.
The RCPs supply coolant flow to remove heat from the reactor core and transfer it to the steam generators. The RCPs are an integral part of the RCPB.
The RCP and motor contain safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the reactor coolant pump and motor potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the RCP and motor perform functions that support fire protection.
LRA Table 2.3.1-4 identifies RCP and motor component types within the scope of license renewal and subject to an AMR:
* RCPs (casings)
* RCP closure bolting
* RCP oil cooler and heat exchanger components
* RCP thermal barrier heat exchanger components
* RCP lube oil collection tank
* RCP oil spill protection system piping The intended function of the RCP and motor component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.1.4.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.4 and FSAR Section 5.4.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
2-47
 
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.1.4.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RCP and RCP motor components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.1.5 Pressurizer 2.3.1.5.1 Summary of Technical Information in the Application LRA Section 2.3.1.5 describes the pressurizer, a vertical, cylindrical vessel with hemispherical top and bottom heads constructed of carbon steel and austenitic stainless steel cladding on all internal surfaces exposed to the reactor coolant. A stainless steel liner is in place of cladding in some nozzles. The pressurizer is connected to the hot leg of one of the reactor coolant loops by a surge line. Electric heaters are installed through the bottom head of the vessel while the spray nozzle and the relief valve and safety valve connections are in the top head of the vessel. The pressurizer, a part of the RCPB, mitigates steam generator tube ruptures, events that may cause RCS overpressure, and events that require RCS depressurization for cold shutdown conditions. The pressurizer provides a bleed path for bleed-and-feed RCS cooling. The pressurizer is required for RCS pressure control; however, pressure control and pressurizer water level control during normal power operation are not safety-related functions.
The pressurizer contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the pressurizer potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the pressurizer performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.1-5 identifies pressurizer component types within the scope of license renewal and subject to an AMR:
* pressurizer shell
* pressurizer lower head
* pressurizer upper head
* pressurizer valve support bracket lugs
* pressurizer spray nozzle
* pressurizer relief nozzle
* pressurizer safety nozzle 2-48
* pressurizer surge nozzle
* pressurizer spray head
* pressurizer spray head coupling
* pressurizer spray head locking bar
* pressurizer spray nozzle thermal sleeve
* pressurizer surge nozzle thermal sleeve
* pressurizer instrument nozzles
* pressurizer spray nozzle safe end
* pressurizer relief nozzle safe end
* pressurizer safety nozzle safe end
* pressurizer surge nozzle safe end
* pressurizer manway covers and insert
* pressurizer manway studs
* pressurizer manway nuts
* pressurizer manway pad gasket seating surface
* pressurizer heater well nozzles
* pressurizer immersion heaters
* pressurizer support skirt and flange
* pressurizer seismic lugs
* pressurizer relief tank shell and heads
* pressurizer relief tank flanges
* pressurizer relief tank nozzles
* pressurizer relief tank rupture disk
* closure bolting
* containment isolation piping and components
* filter housings (air and gas)
* piping, piping components, and piping elements
* pressurizer power-operated relief valve (PORV) accumulators
* pressurizer PORV flex hoses
* regulators The intended functions of the pressurizer component types within the scope of license renewal include:
* pressure-retaining boundary
* adequate and proper flow distribution
* structural support and seismic integrity
* thermal insulation 2.3.1.5.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.5 and FSAR Sections 5.4.10, 5.4.13, and 7.7.1.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that 2-49
 
the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.1.5.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the pressurizer components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.1.6 Steam Generator 2.3.1.6.1 Summary of Technical Information in the Application LRA Section 2.3.1.6 describes the steam generators, originally Westinghouse Model D4s, a preheater-type steam generator with Alloy 600 mill-annealed tubes. These steam generators experienced tube and tube support component degradation and other problems similar to industry-wide experience with the model and in the fall of 2001 were replaced with Westinghouse Model Delta 75 steam generators. The steam generator primary function is to transfer heat from reactor coolant loop to the feedwater to generate steam for the turbine generator. The steam generators must maintain both RCPB and secondary side pressure boundary integrity. They provide a heat sink for the reactor core during normal operating, shutdown, and accident conditions. Steam generator level instrumentation is required for post-accident monitoring; however, these components are parts of the nuclear steam supply system (NSSS) process instrumentation system.
The steam generator contains safety-related components relied upon to remain functional during and following DBEs. In addition, the steam generator performs functions that support fire protection and ATWS.
LRA Table 2.3.1-6 identifies steam generator component types within the scope of license renewal and subject to an AMR:
* instrument manifolds and valves
* elliptical head
* steam nozzle
* steam nozzle flow limiter
* steam generator upper shell
* steam generator lower shell
* steam generator transition cone
* feedwater nozzle
* feedwater nozzle thermal sleeve
* AFW nozzle
* auxiliary nozzle thermal sleeve
* steam generator feedwater impingement plate and support 2-50
* secondary manway covers
* secondary manway bolting
* inspection port and handhole covers
* inspection port and handhole closure bolting
* sludge collector maintenance opening covers
* sludge collector maintenance openings closure bolting
* channel head
* steam generator: divider plate
* steam generator support ring
* steam generator primary nozzles
* steam generator primary nozzle safe ends
* secondary side shell penetrations (except steam and feedwater)
* primary manway cover and inserts
* primary manway bolting
* tubeplate
* tubes
* tube plugs
* tube support plates and flow distribution baffles
* steam generator: tube bundle wrapper
* steam generator: anti-vibration bars
* tube bundle support hardware
* feedwater distribution ring and supports
* feedwater distribution ring spray nozzles
* AFW internal spray pipe
* moisture separator assembly
* miscellaneous non-pressure boundary internals The intended functions of the steam generator component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary
* adequate and proper flow distribution
* structural support and seismic integrity
* thermal insulation
* flow regulation 2.3.1.6.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.6 and FSAR Section 5.4.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2-51
 
2.3.1.6.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the steam generator components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.2 Engineered Safety Features Systems LRA Section 2.3.2 identifies the ESF systems SCs subject to an AMR for license renewal.
The applicant described the supporting SCs of the ESF systems in the following LRA sections:
* 2.3.2.1        containment spray system
* 2.3.2.2        containment isolation system
* 2.3.2.3        high head safety injection system
* 2.3.2.4        low head safety injection / residual heat removal system
* 2.3.2.5        passive safety injection system
* 2.3.2.6        control room area ventilation system The staffs findings on review of LRA Sections 2.3.2.1 - 2.3.2.6 are in SER Sections 2.3.2.1 - 2.3.2.6, respectively.
2.3.2.1 Containment Spray System 2.3.2.1.1 Summary of Technical Information in the Application LRA Section 2.3.2.1 describes the containment spray system (CSS), which consists of two independent and redundant loops, each with a spray pump, piping, valves, spray headers, and spray valves. The CSS has two principal modes of operation: (a) the injection mode in which the system sprays borated water taken from the refueling water storage tank (RWST) and (b) the recirculation mode in which the system takes water from the containment sumps. The CSS must function following a loss-of-coolant accident (LOCA), following a safe shutdown earthquake, and under post-accident environmental conditions. Therefore, this system is safety-related and seismic Category I. The CSS provides adequate capability for the fission product scrubbing of the containment atmosphere following a LOCA to keep offsite doses and doses to operators in the control room within 10 CFR 50.67 guidelines.
The CSS has components for containment isolation. Containment isolation valve position indication is an RG 1.97 Category 1 requirement. The CSS has components for post-accident monitoring. RG 1.97 Category 1 parameters monitored include RWST level, containment sump level, containment water level, containment pressure, and sodium hydroxide tank level.
The CSS contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the containment spray system 2-52
 
potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the CSS performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.2-1 identifies CSS component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* containment spray additive tank
* containment spray nozzles
* containment spray pumps
* flow restricting elements
* piping insulation
* piping, piping components, and piping elements
* refueling water storage tank The intended functions of the CSS component types within the scope of license renewal include:
* pressure-retaining boundary
* adequate and proper flow distribution
* thermal insulation
* flow regulation 2.3.2.1.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.1 and FSAR Sections 6.2.2.2.2 and 6.5.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.3-7a dated August 27, 2007, the staff requested that the applicant clarify the intended functions of the nonsafety-related components that are included within the scope of license renewal and if they are reflected in GALL Report Tables 2.0-1, 3.2.1 and 3.3.2.
In its response dated September 24, 2007, the applicant stated that HNP mechanical screening methodology does not treat components within the scope of license renewal pursuant to 10 CFR 54.4(a)(2) differently than components within the scope of license renewal pursuant to 10 CFR 54.4(a)(1) or (a)(3). The list of mechanical component intended functions in LRA Table 2.0-1 can be used individually or in combination to describe a component intended function that supports the overall intended function. The components within the scope of license renewal are treated equally regardless of the reason that they were brought into scope; therefore, the components are included in the appropriate tables.
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Based on its review, the staff finds the applicants response to RAI 2.3.3-7a acceptable because the requested clarification was provided and the applicant gave assurance that when applicable, the intended functions and the AMR of the nonsafety-related components were appropriately included within the scope of license renewal. The staffs concern described in RAI 2.3.3-7a is resolved.
In RAI 2.3.3-7b dated August 27, 2007, the staff requested that the applicant explain the general statement that "the system contains components that are conservatively assumed to meet the criteria of 10 CFR 54.4(a)(2) based on their quality class and are, therefore, included in scope of license renewal." The applicant was specifically asked as to what components are included within the scope of license renewal due to the conservative assumption and if they are reflected in the appropriate tables mentioned in the RAI above.
In its response dated September 24, 2007, the applicant stated that the major structures and plant components such as pumps, valves, tanks, heat exchangers, and instruments at HNP are assigned unique component numbers that are maintained in a controlled database called the PassPort EDB or EDB. The PassPort EDB is a corporate database platform which is utilized for, among other things, compiling and archiving quality requirements for SSCs at the applicants nuclear power plants. The PassPort EDB is used to implement the graded quality classification system defined at HNP. The HNP procedure, Component Quality Class, defines different categories of quality classifications for these unique components. Among these quality classifications, Quality Class B is reserved for nonsafety-related, quality augmented SSCs. This quality class is further broken down into subclasses, which provide a more specific basis for quality designations. Two of these Quality Class B subclasses are not currently defined in the HNP procedure but were incorporated into the EDB based on a historical augmented classification. For the purposes of license renewal, these undefined Quality Class B subclasses were aligned with the license renewal rule such that components with those designations were included within the scope of license renewal pursuant to 10 CFR 54.4(a)(2). The general statement noted in the RAI is included in the system descriptions of the LRA to indicate this case.
As an example, the applicant discussed the chemical volume and control system in LRA Section 2.3.3.1. The applicant noted that the general statement was included for this system and some of the components associated with this category include instrument valves. These valves are included in the "piping, piping components, and piping elements" component/commodity group in LRA Table 2.2.2-1.
The RAI's an applicants responses discussed above are applicable to sections of the LRA where similar statements were included (e.g. 2.3.3.56, 2.3.3.57, 2.3.3.59, 2.3.3.65 and 2.3.3.83).
Based on its review, the staff finds the applicant's response to RAI 2.3.3-7b acceptable because it is the staff's understanding, that additional components were included within the scope of license renewal because they were conservatively assumed to meet the requirements of 10 CFR 54.4(a)(2) based on the PassPort EDB historical augmented classification of the SSCs at HNP. The staffs concern described in RAI 2.3.3-7b is resolved.
2.3.2.1.3 Conclusion 2-54
 
The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the CSS components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.2.2 Containment Isolation System 2.3.2.2.1 Summary of Technical Information in the Application LRA Section 2.3.2.2 describes the containment isolation system, which consists of the valves and actuators required to isolate the containment following a LOCA, main steamline break (MSLB), or fuel handling accident inside the containment.
Systems with primary CIVs are:
* reactor vessel and internals (including the RVLIS)
* RCS
* pressurizer system
* CSS
* high-head safety-injection (HHSI) system
* low-head safety-injection and RHR system
* passive safety-injection system
* chemical and volume control system
* primary sampling system
* PASS
* normal service water system
* ESW system
* CCW system
* instrument air system
* service air system
* fire protection system
* radioactive equipment drains system
* demineralized water system
* radiation monitoring system
* gaseous waste processing
* refueling system
* spent fuel pool cleanup system
* containment vacuum relief system
* containment pressurization system
* penetration pressurization system
* containment atmosphere purge exhaust system
* post-accident hydrogen system
* steam generator blowdown system
* main steam system
* feedwater system 2-55
* AFW system
* secondary sampling system 2.3.2.2.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.2 and FSAR Section 6.2.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.2.2.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment isolation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.2.3 High-Head Safety-Injection System 2.3.2.3.1 Summary of Technical Information in the Application LRA Section 2.3.2.3 describes the HHSI system, which supplies cooling water to the RCS when the RCS leak rate is relatively low or nonexistent, as during a main steam or feedwater line break, and the RCS pressure is high. The HHSI system functions in conjunction with the chemical and volume control system (CVCS) and the CSS via the RWST to deliver borated water to the RCS following a postulated LOCA, MSLB, or other event affecting the RCS liquid inventory. The HHSI system relies upon the charging and safety injection (CSI) pumps, which take suction on the RWST. The HHSI system includes nitrogen gas/air supply piping between the pressurizer PORVs and their pneumatic accumulators. For this reason, the HHSI system supports the pressurizer system intended functions that actuate the PORVs. The HHSI system has Class 1 piping to maintain the RCPB and components for containment isolation.
Containment isolation valve position indication is an RG 1.97, Category 1, function.
The HHSI system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the HHSI system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the HHSI system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.2-2 identifies HHSI system component types within the scope of license renewal and subject to an AMR:
2-56
* closure bolting
* containment isolation piping and components
* flow restricting elements
* piping insulation
* piping, piping components, and piping elements The intended functions of the HHSI system component types within the scope of license renewal include:
* pressure-retaining boundary
* thermal insulation
* flow regulation 2.3.2.3.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.3 and FSAR Section 6.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.2-1 dated August 7, 2007, the staff stated that scoping boundary drawing 5-G-0808-LR, indicates that the boron injection tank is within the scope of license renewal; however, LRA Table 2.3.2-2 does not identify the boron injection tank separately as within the scope of license renewal. Therefore, the staff requests that the applicant indicate which line item in LRA Table 2.3.2-2 includes the subject component.
In its response dated September 5, 2007, the applicant stated that the boron injection tank is within the scope of license renewal and is discussed in LRA Section 2.3.2.3. LRA Table 2.3.2-2 component/commodity, piping, piping components, and piping elements, includes the boron injection tank.
Based on its review, and with the inclusion of this component, the staff finds the applicant's response to RAI 2.3.2-1 acceptable. Therefore, the staff's concern described in RAI 2.3.2-1 is resolved.
In RAI 2.3.2-2 dated August 7, 2007, the staff stated that scoping boundary drawing 5-G-0809-LR, indicates that accumulator tanks are within the scope of license renewal; however, LRA Table 2.3.2-2 does not identify the accumulator tanks separately as within the scope of license renewal. Therefore, the staff requests that the applicant indicate which line item in LRA Table 2.3.2-2 includes the subject component.
In its response dated September 5, 2007, the applicant stated that the above-referenced accumulator tanks, shown on scoping boundary drawing 5-G-0809-LR, are within the scope of license renewal and discussed in LRA Section 2.3.2.5. LRA Table 2.3.2-4 identifies these tanks 2-57
 
as component/commodity cold leg accumulators.
Based on the staffs review, and with the inclusion of this component, the staff finds the applicant's response to RAI 2.3.2-2 acceptable. Therefore, the staff's concern described in RAI 2.3.2-2 is resolved.
2.3.2.3.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the HHSI system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.2.4 Low-Head Safety-Injection / Residual Heat Removal System 2.3.2.4.1 Summary of Technical Information in the Application LRA Section 2.3.2.4 describes the low-head safety-injection (LHSI) and RHR system, which includes the RHR system and is one of three subsystems comprising the emergency core cooling system (ECCS). The LHSI protects the reactor core when the RCS leak rate is high and the RCS pressure low. The LHSI/RHR system includes the residual heat exchangers, RHR pumps, flow orifices, seal coolers, valves, and piping. Each of the lines from the RCS hot legs to the RHR pump suctions has two remote manual motor-operated valves as the boundary between the RCS and the RHR system. The RHR system monitors RHR pump performance during mid-loop operations. The LHSI/RHR system includes Class 1 piping for RCS pressure boundary maintenance and components for containment isolation. Containment isolation valve position indication is an RG 1.97, Category 1, function.
The LHSI/RHR system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the LHSI/RHR system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the LHSI/RHR system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.2-3 identifies LHSI/RHR system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* flow restricting elements
* piping insulation
* piping, piping components, and piping elements
* RHR heat exchanger components
* RHR heat exchanger tubes
* RHR pump seal water cooler components
* RHR pump seal water cooler tubes 2-58
* RHR pumps The intended functions of the LHSI/RHR system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary
* thermal insulation
* flow regulation 2.3.2.4.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.4 and FSAR Sections 6.3.2 and 5.4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.2.4.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the LHSI/RHR system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.2.5 Passive Safety-Injection System 2.3.2.5.1 Summary of Technical Information in the Application LRA Section 2.3.2.5 describes the passive safety-injection (PSI) system, one of three subsystems comprising the ECCS. The PSI system is the subsystem that functions at intermediate RCS pressure, when the HHSI system is not entirely effective because of the high leak rate and the LHSI system is not yet operable. The PSI function is by safety-injection accumulators, pressure vessels partially filled with borated water and pressurized with nitrogen gas. PSI system components include the accumulators, piping, valves, flow elements, and instrumentation. Makeup to the safety-injection accumulators is by borated water pumped from the RWST by a hydrostatic test pump, which serves no safety function and normally is isolated from the process piping during normal plant operation.
The PSI system includes Class 1 piping for the RCPB function, components to provide nitrogen for pressurizer PORV operation, and components required for containment isolation.
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Containment isolation valve position indication is an RG 1.97, Category 1, function.
The PSI system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the PSI system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the PSI system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.2-4 identifies PSI system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* cold leg accumulators
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the PSI system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.2.5.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.5 and FSAR Section 6.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.2.5.3 Conclusion The staff reviewed the LRA, FSAR, drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the PSI system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.2.6 Control Room Area Ventilation System 2.3.2.6.1 Summary of Technical Information in the Application LRA Section 2.3.2.6 describes the control room area ventilation system, which consists of safety-related air conditioning and emergency filtration systems and provides heating, ventilation, cooling, filtration, air intake and exhaust isolation, and maintains 50-percent relative humidity for the control room envelope during normal operation and after design-basis 2-60
 
accidents. The system, located in the reactor auxiliary building (RAB) at the 286-ft. and 305-ft.
elevations, supports operation of the control room envelope, which has been designed for continuous occupancy within radiation exposure limits, during normal operation and extended occupancy throughout the duration of any one of the following postulated design-basis accidents: (a) LOCA, (b) fuel-handling accident, or (c) radioactive releases due to radwaste system failure.
The control room area ventilation system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the control room area ventilation system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the control room area ventilation system performs functions that support fire protection and EQ.
LRA Table 2.3.2-5 identifies control room area ventilation system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* control room smoke purge and exhaust fan housings
* control room air handling unit and emergency filtration unit enclosure
* control room air handling unit and emergency filtration unit fan housings
* control room air handling unit and emergency filtration unit filter housings
* control room air handling unit cooling coil
* ducting
* ducting and components
* ducting closure bolting
* elastomer seals and components
* piping, piping components, and piping elements The intended functions of the control room area ventilation system component types within the scope of license renewal include:
* filtration
* pressure-boundary
* heat transfer 2.3.2.6.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.6 and FSAR Sections 6.4, 7.3.1.5.7, and 9.4.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.3-1 dated August 27, 2007, the staff stated that the top of LRA page 3.3-440 reads:
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"Notes for Tables 3.3.2-1 through 3.3.2-68:" It appears that these Notes are also applicable to Tables 3.3.2-69 through 3.3.2-71. Also, the top of LRA page 3.5-198 reads: "Notes for Tables 3.5.2-1 through 3.5.2-26." It appears that these Notes are also applicable to Tables 3.5.2-27 through 3.5.2-29. The applicant was asked to provide clarification in reference to LRA table notes.
In its response dated September 24, 2007, the applicant stated that yes, the notes are applicable as described. These notes were addressed in LRA Amendment I as Self-Identified Changes 2 and 3 on page 12 of Enclosure 2 of HNP Letter to the NRC Serial: HNP-07-112, dated August 20, 2007.
Based on its review, the staff finds the applicants response to RAI 2.3.3-1 acceptable because the specific clarification requested was provided and this uncertainty as to having a complete application was eliminated. The staffs concern described in RAI 2.3.3-1 is resolved.
2.3.2.6.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the control room area ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3 Auxiliary Systems LRA Section 2.3.3 identifies the auxiliary systems SCs subject to an AMR for license renewal.
The applicant described the supporting SCs of the auxiliary systems in the following LRA sections:
* 2.3.3.1                Chemical and Volume Control System
* 2.3.3.2                Boron Thermal Regeneration System
* 2.3.3.3                Primary Makeup System
* 2.3.3.4                Primary Sampling System
* 2.3.3.5                Post-accident Sampling System
* 2.3.3.6                Circulating Water System
* 2.3.3.7                Cooling Tower System
* 2.3.3.8                Cooling Tower Make-up System
* 2.3.3.9                Screen Wash System
* 2.3.3.10        Main Reservoir Auxiliary Equipment
* 2.3.3.11        Auxiliary Reservoir Auxiliary Equipment The staffs findings on review of LRA Sections 2.3.3.1 - 2.3.3.83 are in SER Sections 2.3.3.1 -
2.3.3.83, respectively.
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2.3.3.1 Chemical and Volume Control System 2.3.3.1.1 Summary of Technical Information in the Application LRA Section 2.3.3.1 describes the CVCS, which provides auxiliary services to the RCS. The CVCS maintains a programmed water level in the pressurizer to maintain the required RCS water inventory by means of the charging and letdown functions, which combine to form a continuous feed-and-bleed process. Reactor coolant is letdown to the CVCS from the RCS loop A crossover leg. The CVCS volume control tank (VCT) provides a surge capacity for reactor coolant expansion not accommodated by the pressurizer. Three CSI pumps take suction on the VCT and return the cooled, purified reactor coolant to the RCS, directing a portion of the charging flow through a seal water injection filter and then to each RCP for seal water injection. For refueling and maintenance, the RCS is drained to the recycle holdup tank via the CVCS letdown line. Following refueling and maintenance, the CSI pumps refill the RCS with purified reactor coolant at the desired blended boron concentration. The CVCS is a means to provide makeup to the RWST. Portions of the CVCS support the RCPB function. The CVCS has components for containment isolation. Containment isolation valve position indication is an RG 1.97, Category 1, function.
The CVCS contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the CVCS potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the CVCS performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.3-1 identifies CVCS component types within the scope of license renewal and subject to an AMR:
* backflushable filters
* boric acid transfer pumps
* CSI pump gear lube oil pumps
* charging pump mini-flow orifices
* closure bolting
* containment isolation piping and components
* CSI pump lube oil pumps
* CSI pumps
* CSI pumps gear oil cooler components
* CSI pumps gear oil cooler tubes
* CSI pumps oil cooler components
* CSI pumps oil cooler tubes
* CSI pumps lube oil piping components
* excess letdown heat exchanger components
* flow restricting elements
* letdown heat exchanger components
* piping insulation
* piping, piping components, and piping elements
* regenerative heat exchanger
* seal water heat exchanger components
* system strainers 2-63
* tank diaphragm
* tanks
* VCT The intended functions of the CVCS component types within the scope of license renewal include:
* filtration
* heat transfer
* pressure-retaining boundary
* structural support and seismic integrity
* thermal insulation
* flow regulation 2.3.3.1.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.1 and FSAR Section 9.3.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.1.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the CVCS components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.2 Boron Thermal Regeneration System 2.3.3.2.1 Summary of Technical Information in the Application LRA Section 2.3.3.2 describes the boron thermal regeneration system (BTRS), which includes compressors, coolers, demineralizers, heat exchangers, pumps, valves, and piping, which was designed to vary the RCS boron concentration during reactor power changes, and which assists in changing RCS boron concentrations for fuel depletion, shutdowns, start-ups, and refueling. The BTRS utilizes a temperature-dependent ion exchange process to store and release boron from the RCS without discharging water to the boron recycle system. The BTRS was designed originally to control changes in reactor coolant boron concentration to compensate for xenon transients during load follow operations without additional makeup for 2-64
 
either boration or dilution but is not used currently at HNP for that purpose. Towards the end of core life the BTRS reduces the reactor coolant boron concentration. All BTRS components except those in the chilled water loop are nuclear safety-related. The BTRS is required to maintain the CVCS pressure boundary.
The BTRS contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the BTRS potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-2 identifies BTRS component types within the scope of license renewal and subject to an AMR:
* BTRS chiller lube oil cooler
* closure bolting
* letdown chiller heat exchanger components
* letdown reheat heat exchanger components
* moderating heat exchanger components
* piping, piping components, and piping elements
* tanks The intended function of the boron thermal regeneration system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.2.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.2 and FSAR Section 9.3.4.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.2.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the boron thermal regeneration system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.3 Primary Makeup System 2.3.3.3.1 Summary of Technical Information in the Application LRA Section 2.3.3.3 describes the primary makeup system designed to supply makeup water to various systems including the CVCS and boron recycle, spent fuel pool cooling, spent fuel pool cleanup, filter backwash, liquid waste processing, gaseous waste processing, and pressurizer systems. The primary makeup system stores and distributes recycled, demineralized water with some tritium content due to previous use within other plant systems. This system is an emergency water makeup source for the CCW system and supplies a sufficient reserve of makeup water to the CVCS to maintain a constant RCS pressurizer level during a cooldown to cold shutdown conditions. The system also provides water to nonsafety-related systems in the RAB during normal operation. The primary makeup system consists of the reactor makeup water storage tank, two reactor makeup water pumps, flow orifices, strainers, valves, and piping. The reactor makeup water storage tank is the head tank for the primary makeup system. Makeup to the reactor makeup water storage tank is supplied by the demineralized water system.
The primary makeup system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the primary makeup system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-3 identifies primary makeup system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* flow restricting elements
* piping, piping components, and piping elements
* reactor makeup water storage tank
* tank diaphragm The intended functions of the primary makeup system component types within the scope of license renewal include:
* pressure-retaining boundary
* structural support and seismic integrity
* flow regulation 2.3.3.3.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.3 and FSAR Section 9.2.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that 2-66
 
the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.3.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the primary makeup system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.4 Primary Sampling System 2.3.3.4.1 Summary of Technical Information in the Application LRA Section 2.3.3.4 describes the primary sampling system (PSS), which is designed to collect fluid and gas grab samples while minimizing radiation exposure to personnel. These samples can be taken from RCS Loop 2 or Loop 3 hot leg, the pressurizer liquid or vapor space, and the RCS support systems. The RCS support systems include the BTRS, the CVCS, the RHR system, the safety-injection system accumulators, and the reactor makeup water storage tank for information needed to maintain RCS chemistry and to control chemistry parameters during normal plant operational modes. The PSS has equipment skids, coolers, compressors, pumps, panels, tanks, sample sinks, piping, and tubing for determining fission and corrosion product activity levels; boron concentration; lithium, pH, conductivity, and radiation levels; crud, dissolved gas, and chloride concentration; and gas compositions in various tanks. The applicant uses the results determined to regulate boron concentration, monitor fuel rod and steam generator tube integrity, specify chemical additions to the various systems, and maintain proper hydrogen and nitrogen overpressure in the VCT. The PSS is required for containment isolation.
Containment isolation valve position indication is an RG 1.97, Category 1, function.
The PSS contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the primary sampling system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-4 identifies primary sampling system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements
* primary sampling condenser components
* primary sampling condenser tubes
* primary sampling cooler components
* primary sampling cooler tubes
* primary sampling evaporator components
* primary sampling evaporator tubes 2-67
 
The intended functions of the primary sampling system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary 2.3.3.4.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.4 and FSAR Section 9.3.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.4.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the PSS components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.5 Post-Accident Sampling System 2.3.3.5.1 Summary of Technical Information in the Application LRA Section 2.3.3.5 describes the PASS designed to collect and analyze fluid samples and to provide grab samples for additional analysis in a LOCA. Samples can be taken from the RCS Loop 2 or Loop 3 hot legs or from either RHR pump discharge line, the former sample points for a reactor coolant sample, the latter for a containment sump sample. The PASS sampling equipment is isolated from the RCPB and the containment and is, therefore, nonnuclear safety class and not designed to seismic Category I requirements; however, the system includes components required for containment isolation. Containment isolation valve position indication is an RG 1.97, Category 1, requirement.
The PASS contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the PASS potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the PASS performs functions that support EQ.
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LRA Table 2.3.3-5 identifies PASS component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping insulation
* piping, piping components, and piping elements The intended functions of the PASS component types within the scope of license renewal include:
* pressure-retaining boundary
* thermal insulation 2.3.3.5.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.5 and FSAR Section 9.3.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.5.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the PASS components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.6 Circulating Water System 2.3.3.6.1 Summary of Technical Information in the Application LRA Section 2.3.3.6 describes the circulating water system (CWS), which supplies the main condenser continuously with cooling water to remove heat from the main turbines. The water circulates through the condenser from the cooling tower basin and a concrete canal directs it from the coiling tower basin to the inlet of the CWS pumps in the circulating water intake structure. The CWS is equipped with three vertical wet-pit pumps that take suction from the circulating water intake structure and discharge water through individual steel pipes into the CWS pump discharge header. The CWS includes components relied on in plant evaluations to perform functions that demonstrate compliance with NRC regulations for fire protection 2-69
 
(10 CFR 50.48) because of its interaction with the normal service water (NSW) system.
The NSW system is credited for fire protection. During normal operation, the NSW return flow paths from branch headers, with the exception of the waste processing building (WPB) return, discharge into the CWS return lines in the turbine building north of the main condenser. The NSW return flow from the WPB joins the CWS lines in the yard between the turbine building and the cooling tower. In the NSW return path to the cooling tower, the flow path within the scope of license renewal includes the return flow path from the outlet of the RAB to the cooling tower basin via the cooling tower sprays. The in-scope piping components extend in the CWS return paths to the branch isolation valves (e.g., condenser discharge valves and WPB and turbine building NSW return flow valves) from other return lines.
The failure of nonsafety-related SSCs in the CWS potentially could prevent the satisfactory accomplishment of a safety-related function. The CWS also performs functions that support fire protection.
LRA Table 2.3.3-6 identifies CWS component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* piping, piping components, and piping elements The intended function of the CWS component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.6.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.6 and FSAR Section 10.4.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.6.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the CWS components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.7 Cooling Tower System 2.3.3.7.1 Summary of Technical Information in the Application LRA Section 2.3.3.7 describes the cooling tower system, which is part of the CWS and designed to operate continuously throughout the year under various weather conditions. In addition, the system is the preferred heat sink for reactor cooldown under normal conditions.
The cooling tower system consists of the cooling tower structure and mechanical and electrical components for its maintenance and operation (e.g., spray nozzle, deicing gate valves, manual slide gate valves, bypass valves, and lighting). The cooling tower basin is the source of water for both CWS and NSW systems. Loss of the cooling tower system as a heat sink for the main condenser will result in a plant trip.
The cooling tower system performs functions that support fire protection.
LRA Table 2.3.3-7 identifies cooling tower system component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* piping, piping components, and piping elements
* spray nozzles The intended functions of the cooling tower system component types within the scope of license renewal include:
* pressure-retaining boundary
* adequate and proper flow distribution 2.3.3.7.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.7 and FSAR Section 10.4.5.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.7.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the 2-71
 
cooling tower system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.8 Cooling Tower Make-Up System 2.3.3.8.1 Summary of Technical Information in the Application LRA Section 2.3.3.8 describes the CTMU system, a part of the CWS. The CTMU system replaces water inventory lost from the cooling tower by natural evaporation, drift, and blowdown.
The CTMU pump supplies water from the main reservoir to the cooling tower basin. One CTMU pump and one standby are in Bays B and C of the ESW and cooling tower (ESW & cooling tower) makeup intake structure. The CTMU system has components relied on in plant evaluations for functions that demonstrate compliance with NRC regulations for fire protection (10 CFR 50.48). The CTMU system discharge piping forms a pressure boundary with the concrete conduit (pipe) between the cooling tower basin and the ESW & CTMU intake structure.
The CTMU system performs functions that support fire protection.
LRA Table 2.3.3-8 identifies CTMU system component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* piping, piping components, and piping elements The intended function of the CTMU system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.8.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.8 and FSAR Section 10.4.5.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.8.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the 2-72
 
CTMU system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.9 Screen Wash System 2.3.3.9.1 Summary of Technical Information in the Application LRA Section 2.3.3.9 describes the screen wash system for traveling screens of the CTMU, ESW, and fire protection water systems. The traveling screens remove debris from the suction of pumps which deliver raw water from the main and auxiliary reservoirs. Screen wash spray keeps the screens clear for continued availability of water to the suction of the pumps. The screens rotate as required to present clear sections through which water flows to the pump suction. As the screens rotate, screen wash water sprayed through nozzles removes debris.
The Screen Wash system is designed to operate outdoors. System piping exposed to the outdoor elements is heat-traced and insulated. The housing for each screen has electric heaters for freeze protection.
The failure of nonsafety-related SSCs in the screen wash system potentially could prevent the satisfactory accomplishment of a safety-related function. The screen wash system also performs functions that support fire protection.
LRA Table 2.3.3-9 identifies screen wash system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* fire service screen wash pumps
* piping, piping components, and piping elements
* system strainer screens and elements
* system strainers The intended functions of the screen wash system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.9.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.9 and FSAR Section 9.2.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.3.9.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the screen wash system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.10 Main Reservoir Auxiliary Equipment 2.3.3.10.1 Summary of Technical Information in the Application LRA Section 2.3.3.10 describes the main reservoir auxiliary equipment, which has civil, mechanical, and electrical components. The civil components (e.g., structural elements of the dam) are evaluated as civil structures. The mechanical and electrical components include electrical meters, monitors, level elements, and circuit breakers. These components located in the ESW & cooling tower makeup intake structure monitor the water level in the main reservoir.
In the ultimate heat sink (UHS) analysis, a main reservoir level of 205.7 ft. is the starting point for determining final UHS temperature and level and water volume adequacy for removal of heat generated by the plant; however, to meet flow requirements for safety-related heat exchangers cooled by ESW, the UHS minimum main reservoir level is 215 ft. HNP technical specifications require UHS operation with a minimum main reservoir water level of 215 ft. mean sea level.
The main reservoir mechanical and electrical components indicate the main reservoir water level. As evaluated these components do not meet 10 CFR 54.4(a)(1) criteria for inclusion within the scope of license renewal as safety-related; however, a conservative assumption is that they meet 10 CFR 54.4(a)(2) criteria by their quality classification because they maintain the initial conditions for water level in the main reservoir.
The failure of nonsafety-related SSCs of the main reservoir auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.10.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.10 and FSAR Sections 2.4.11.6, 2.4.11.7, and 9.2.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.3.10.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the main reservoir auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.11 Auxiliary Reservoir Auxiliary Equipment 2.3.3.11.1 Summary of Technical Information in the Application LRA Section 2.3.3.11 describes the auxiliary reservoir auxiliary equipment, which includes civil, mechanical, and electrical components. The civil components (e.g., structural elements of the dam) are evaluated as civil structures. The mechanical and electrical components include in the ESW screening structure level elements and transmitters that monitor the water level in the auxiliary reservoir. The auxiliary reservoir mechanical and electrical components indicate the auxiliary reservoir level. As evaluated these components do not meet 10 CFR 54.4(a)(1) criteria for inclusion within the scope of license renewal as safety-related; however, a conservative assumption is that they meet 10 CFR 54.4(a)(2) criteria by their quality classification because they maintain the initial conditions for water level in the auxiliary reservoir.
The failure of nonsafety-related SSCs of the auxiliary reservoir auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.11.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.11 and FSAR Sections 2.4.11.7 and 9.2.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.11.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary reservoir auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.12 Normal Service Water System 2.3.3.12.1 Summary of Technical Information in the Application LRA Section 2.3.3.12 describes the NSW system, which consists of components in the following systems:
* NSW system
* ESW system
* emergency screen wash system The NSW system provides cooling water at a maximum temperature of 95°F to remove plant heat loads by utilizing the cooling tower and its components during normal and shutdown operations and detects, controls, and isolates radioactive leakage into and out of the system The NSW system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the NSW system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the NSW system performs functions that support SBO, EQ, and fire protection.
LRA Table 2.3.3-10 identifies NSW system component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* containment isolation piping and components
* NSW pumps
* NSW seal and bearing water booster pump
* piping, piping components, and piping elements
* system strainer screens and elements
* system strainers The intended functions of the NSW system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.12.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.12 and FSAR Section 9.2.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in 2-76
 
accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.3.12-1 dated August 20, 2007, the staff asked the applicant to explain the discrepancy in operating requirements between FSAR Section 9.2.1.2, page 9.2.1-3 and LRA Section 2.3.3.12, pages 2.3-70 and 71, with respect to the function of the NSW pumps. In the LRA, the applicant states that "During Unit start-up, shutdown, and normal operation, SW requirements will be met by one of the NSW pumps"; whereas, in FSAR Section 9.2.1.2, the applicant states that "Both pumps may be required after four hours have elapsed from the plant shutdown initiation (see Table 9.2.1-1)."
In its response dated September 18, 2007, the applicant stated that the functional description of the NSW pumps in LRA Section 2.3.3.12 identifies the normal minimum requirements for one NSW pump to support safe shutdown in the event of a fire. The applicant also stated that the FSAR Section 9.2.1.2 was amplified in Note (3) of FSAR Table 9.2.1-1 to clarify that two NSW pumps would be used when accelerated shutdown would be desired.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.12-1 acceptable because the applicant clarified that the safety function of the NSW pumps is as described in the LRA, and the FSAR description function is when accelerated shutdown would be desired.
Therefore, the staff's concern described in RAI 2.3.3.12-1 is resolved.
2.3.3.12.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the NSW system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.13 Emergency Service Water System 2.3.3.13.1 Summary of Technical Information in the Application LRA Section 2.3.3.13 describes the ESW system, which consists of components in the following systems:
* NSW system
* ESW system
* emergency screen wash system The ESW system flow path that operates continuously during normal and shutdown operating modes is designed to:
* provide cooling water at a maximum temperature of 95°F to remove essential plant heat loads by utilizing the auxiliary reservoir or its backup, the main reservoir, during emergency operation 2-77
* isolate nonessential from essential cooling loads during conditions which otherwise could compromise the system safety function
* provide a heat sink for essential loads assuming a single active or passive component failure
* withstand or be protected from the effects of safe shutdown earthquakes, design-basis tornados, maximum flood levels, or high-energy line breaks without loss of safety function
* provide essential cooling services assuming a loss of offsite power in conjunction with any event in items 3 or 4
* allow periodic testing and inspection of equipment for system integrity and capability
* detect, control, and isolate radioactive leakage into and out of the system
* supply water to the AFW system in the event of loss of the condensate storage tank (CST)
The ESW system includes electrical and mechanical components for containment isolation required to perform in harsh environments during accident conditions.
The ESW system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the ESW system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the ESW system performs functions that support fire protection and EQ.
LRA Table 2.3.3-11 identifies ESW system component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* containment isolation piping and components
* ESW pumps
* flow-restricting elements
* piping insulation
* piping, piping components, and piping elements
* system strainer screens and elements
* system strainers The intended functions of the ESW system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary
* thermal insulation
* flow regulation 2-78
 
2.3.3.13.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.13 and FSAR Section 9.2.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.13 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as discussed below.
In RAI 2.3.3.13-1 dated August 20, 2007, the staff noted that in LRA Section 2.3.3.13, the applicant identifies that under emergency operation, the service water booster pumps start.
However, the booster pumps are not identified in either LRA Table 2.3.3-11 or LRA Table 2.3.3-10 as one of the component/commodity types subject to an AMR. The staff asked the applicant to explain why the service water booster pumps are not identified as a component/commodity type in either LRA Tables 2.3.3-10 or 2.3.3-11.
In its response dated September 18, 2007, the applicant stated that the ESW pumps component/commodity group in LRA Table 2.3.3-11 and LRA Table 3.3.2-11 represents the ESW pumps and the ESW booster pumps. See Plant-Specific Note 323 in AMR Table 3.3.2-11.
The "Note" describes the constituents of this AMR line item as follows:
The component group in this line includes the main Emergency Service Water pumps and the booster pumps. This line only applies to the booster pumps, which are located in the RAB.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.13-1 acceptable because the applicant clarified that the ESW pumps component/commodity group represents both the ESW pumps and the ESW booster pumps. Therefore, the staff's concern described in RAI 2.3.3.13-1 is resolved.
2.3.3.13.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.14 Component Cooling Water System 2.3.3.14.1 Summary of Technical Information in the Application LRA Section 2.3.3.14 describes the CCW system, which provides cooling water to various plant safety-related and nonsafety-related components during all phases of plant operation and shutdown as an intermediate system between the RCS and the ESW and NSW systems. The CCW system supports the ECCS by removing heat from water recirculated from the containment building sump to the reactor and provides cooling water to safeguards pumps in support of ESF functions. The CCW system cools redundant essential CCW loops and a nonessential CCW loop. Each of the two essential loops consists of the one RHR heat exchanger and one RHR pump oil cooler.
The nonessential loop consists of the following:
* one CVCS letdown heat exchanger
* one CVCS seal water heat exchanger
* two spent fuel pool heat exchangers
* one boron recycle evaporator package
* three RCP packages, each consisting of one lower bearing oil cooler and one thermal barrier cooler
* one lower bearing oil cooler and one thermal barrier cooler
* one gross failed fuel detector cooler
* one CVCS excess letdown heat exchanger
* one reactor coolant drain tank heat exchanger
* six PSS sample coolers The CCW system water flow to the nonsafety process sampling system (i.e., sample heat exchangers and gross failed fuel detector) has two air-operated valves on the inlet lines and two check valves on the outlet lines. The air-operated valves on the inlet lines close automatically on an safety-injection signal, thus isolating the CCW system from nonsafety-related systems. Water chemistry control of the CCW system is by additions to the chemical addition tank or to the surge tank.
The CCW system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the component cooling water system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the CCW system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.3-12 identifies cooling water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* CCW heat exchanger components 2-80
* CCW heat exchanger tubes
* CCW pumps
* CCW surge tank
* containment isolation piping and components
* flow-restricting elements
* piping insulation
* piping, piping components, piping elements, and tanks The intended functions of the CCW system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary
* thermal insulation
* flow regulation 2.3.3.14.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and FSAR Section 9.2.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.14.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the CCW system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.15 Waste Processing Building Cooling Water System 2.3.3.15.1 Summary of Technical Information in the Application LRA Section 2.3.3.15 describes the WPB cooling water system, which provides cooling water to waste processing system (WPS) components during various modes of plant operation and shutdown. The WPB cooling water system is also an intermediate heat transfer system between the WPS and the NSW system, reducing the probability of radioactive effluent leakage into the NSW system by transferring heat from WPS components to the two WPB cooling water system heat exchangers cooled by water supplied from the NSW system. Only one cooling 2-81
 
water pump and one heat exchanger are required for operation.
The WPB cooling water system was designed originally to provide cooling water to the various WPS components listed below:
* waste gas compressors
* catalytic recombiners
* waste evaporators
* reverse osmosis concentrate evaporators
* reverse osmosis module precoolers
* reverse osmosis module chillers (refrigeration unit)
* waste evaporator concentrate tank vent gas condensers
* volume reduction condenser
* secondary waste evaporators
* radiation monitors The WPB cooling water system is neither a nuclear safety class nor seismic Category I system.
This system is not considered available during accident and emergency conditions and the applicant takes no credit in the safety evaluation for post-accident operation.
The failure of nonsafety-related SSCs in the WPB cooling water system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-13 identifies WPB cooling water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the WPB cooling water system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.15.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.15 and FSAR Section 9.2.10 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.15.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components 2-82
 
subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the WPB cooling water system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.16 Essential Services Chilled Water System 2.3.3.16.1 Summary of Technical Information in the Application LRA Section 2.3.3.16 describes the essential services chilled water system, which provides chilled water to the cooling coils of air-handling units for the following systems:
* control room area ventilation system
* RAB normal ventilation system
* RAB nonnuclear safety ventilation systems
* RAB ESF equipment cooling system
* RAB switchgear ventilation system
* RAB electrical equipment protection rooms ventilation system
* spent fuel pool pump room ventilation system The essential services chilled water system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the essential services chilled water system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the essential services chilled water system performs functions that support fire protection and EQ.
LRA Table 2.3.3-14 identifies essential services chilled water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* essential chilled water chiller condenser components
* essential chilled water chiller condenser tubes
* essential chilled water chiller compressors oil cooler components
* essential chilled water compressors oil cooler tubes
* essential chilled water system chiller cooler components
* essential chilled water system chiller cooler tubes
* essential chilled water system condenser service water recirculating pump
* essential chilled water system water pumps
* flow restricting elements
* piping, piping components, piping elements and tanks
* system strainers screens and elements
* system strainers
* tanks The intended functions of the essential services chilled water system component types within the scope of license renewal include:
* filtration 2-83
* heat transfer
* pressure-retaining boundary
* flow regulation 2.3.3.16.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.16 and FSAR Section 9.2.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.16 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as discussed below.
In RAI 2.3.3.16-1 dated August 20, 2007, the staff stated that a license renewal drawing for the essential services chilled water system shows a flag with a "3" in it indicating that the piping and valves beyond it are designed to meet Safety Class 3 and Seismic Category I requirements.
The piping beyond the piping class flag (line number 3CX4-71SB-1) is partially highlighted as within the scope of license renewal pursuant to 10 CFR 54.4(a)(1). There is no piping class flag indicating a change in pipe class at the location along the pipe where the highlighting stops.
The staff asked the applicant to explain why pipe line 3CX4-71SB-1 is not highlighted along its total length; thereby, indicating that it is not within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).
In its response dated September 18, 2007, the applicant stated pipe line 3CX4-71SB-1 shown on the license renewal drawing should be highlighted. The applicant explained that this pipe line is included in the component/commodity "piping, piping components, piping elements and tanks" in LRA Table 2.3.3-14. Since the piping class is continuous and the locations are the same as the adjacent sections of highlighted piping there is no impact on the AMR results in AMR Table 3.3.3-14.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.16-1 acceptable because the applicant clarified that pipe line 3CX4-71SB-1 shown on the essential services chilled water system license renewal drawing should have been completely highlighted, indicating that it was within the scope of license renewal pursuant to 10 CFR 54.4(a)(1).
Although not highlighted on the license renewal drawing, the components of pipe line 3CX4-71SB-1 have been included in the component/commodity "piping, piping components, piping elements and tanks" in LRA Table 2.3.3-14 and AMR results Table 3.3.3-14. Therefore, the staff's concern described in RAI 2.3.3.16-1 is resolved.
2.3.3.16.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the 2-84
 
applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the essential services chilled water system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.17 Nonessential Services Chilled Water System 2.3.3.17.1 Summary of Technical Information in the Application LRA Section 2.3.3.17 describes the nonessential services chilled water system, which supplies chilled water to the cooling coils of air handling units for the following nonsafety-related systems:
* Fuel handling building (FHB) HVAC system for spent fuel pools and operating floor areas
* WPB HVAC system The nonessential services chilled water system that supplies a nominal 44 EF chilled water to the cooling coils in the air handling units consists of two 50-percent package water chillers, an expansion tank, a chemical addition tank, two chilled water pumps arranged in parallel (one operating and one stand-by), and a piping system. The cooling water for the condenser section of the chillers is supplied from the NSW system. The expansion tank provides positive suction head, accommodates system volume changes, and adds makeup water to the system. Makeup water to the expansion tank is fed from the fire protection system. A chemical addition tank prevents corrosion and scale buildup in the system. Chemical addition is manual when required by periodic water analysis test.
The failure of nonsafety-related SSCs in the non-essential services chilled water system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-15 identifies non-essential services chilled water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the non-essential services chilled water system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.17.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.17 and FSAR Section 9.2.9 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to 2-85
 
verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.17.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the non-essential services chilled water system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.18 Emergency Screen Wash System 2.3.3.18.1 Summary of Technical Information in the Application LRA Section 2.3.3.18 describes the emergency screen wash system for traveling screens of the CTMU system, ESW system, and fire protection water system. The traveling screens remove debris from the suction of pumps that deliver raw water from the main and auxiliary reservoirs.
Screen wash spray keeps the screens clear for continued availability of water to the suction of the pumps. The screens rotate as required to present clear sections through which water flows to the pump suction. As the screens rotate, screen wash water sprayed through nozzles removes debris. The emergency screen wash system, including the traveling screens, is designed to operate outdoors. The housing for each screen has electric heaters for freeze protection. Portions of the system piping in the ESW screening structure and ESW & cooling tower makeup intake structure exposed to the outdoor elements are heat-traced and insulated.
As it is required only to maintain the essential system portions in a condition of readiness prior to use, the heat tracing is not safety-related nor connectable to the onsite emergency power supply. Heat tracing failure is signaled by alarm in the radwaste control room.
The emergency screen wash system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the emergency screen wash system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the emergency screen wash system performs functions that support fire protection.
LRA Table 2.3.3-16 identifies emergency screen wash system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* ESW screen wash pumps
* flow-restricting elements
* piping insulation
* piping, piping components, and piping elements 2-86
 
The intended functions of the emergency screen wash system component types within the scope of license renewal include:
* pressure-retaining boundary
* adequate and proper flow distribution
* thermal insulation
* flow regulation 2.3.3.18.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.18 and FSAR Section 9.2.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.18.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the emergency screen wash system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.19 Generator Gas System 2.3.3.19.1 Summary of Technical Information in the Application LRA Section 2.3.3.19 describes the generator gas system, which removes heat in the generator windings and other electrical components during main generator operation. Because of its efficient heat transfer characteristics, hydrogen gas is circulated through the generator as the cooling medium. The system admits hydrogen into the generator and carbon dioxide for purging operations. To remove heat, hydrogen gas circulates throughout the generator and is then cooled by a heat exchanger supplied with service water.
A hydrogen gas supply system provides the necessary valves and instrumentation for the admission of hydrogen into the generator. A gas dryer removes moisture from the hydrogen gas to prevent the accumulation of condensation inside the generator. A gas analyzer monitors the purity of the hydrogen gas inside the generator continuously. Three liquid moisture 2-87
 
detectors at low points inside the generator detect any accumulation of water or oil. A water detector is also on the inlet line to the gas dryer. Activation of a liquid detector would indicate a possible hydrogen cooler leak or hydrogen oil seal failure.
The failure of nonsafety-related SSCs in the generator gas system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.19.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.19 and FSAR Section 10.2.2.2. using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.19.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the generator gas system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.20 Hydrogen Seal Oil System 2.3.3.20.1 Summary of Technical Information in the Application LRA Section 2.3.3.20 describes the hydrogen seal oil system, which provides oil for gland seals on the generator rotor shaft for a gas-tight enclosure to prevent the escape of hydrogen cooling gas along the generator shaft. During normal operations the seal oil unit always operates when hydrogen gas is in the generator. Oil supplied to two annular grooves in the gland seal ring flows in both directions along the shaft through the clearance space between the shaft and the gland seal rings. As long as oil pressure in the circumferential groove exceeds the gas pressure in the machine, the seal prevents the escape of hydrogen from the generator.
The purpose of two feed grooves in the gland ring is for separate hydrogen-side and air-side oil subsystems. This design prevents hydrogen-contaminated oil from reaching the main lube oil system. Conversely, the design also keeps oil contaminated with air and moisture out of the generator. When the feed pressure in these two subsystems is balanced properly there is little flow in the clearance space between the two feed grooves. The air-side seal oil pump normally supplies all oil pressure requirements to the air side and the hydrogen-side seal oil pump supplies oil pressure to the hydrogen side of the gland seals.
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The failure of nonsafety-related SSCs in the hydrogen seal oil system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.20.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.20 and FSAR Section 9.3.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.20.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified hydrogen seal oil system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.21 Emergency Diesel Generator System 2.3.3.21.1 Summary of Technical Information in the Application LRA Section 2.3.3.21 describes the EDG system, which provides a reliable source of alternate power to the emergency 6.9 kV buses for use when normal sources of offsite power are not available. Each generator can start and carry the maximum ESF loads required under postulated accident conditions. Each diesel generator unit can be started either manually for test or automatically. The diesel generators automatically start on receipt of an ESF actuation signal, a low bus voltage as indicated by the bus undervoltage relays or a simulated accident signal. They are connected automatically to the bus through the generator output breaker upon either low or lost bus voltage. Each diesel also can supply all power needed for the safe shutdown of the plant under design emergency situations.
The EDG system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the EDG system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the EDG system performs functions that support fire protection.
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LRA Table 2.3.3-17 identifies EDG system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* diesel combustion air intake filter housings and silencers
* diesel combustion air intake piping, piping components, and piping elements
* diesel engine exhaust piping, piping components, and piping elements
* diesel engine governor oil cooler components
* diesel engine governor oil cooler tubes
* diesel engine turbocharger intercooler components
* diesel engine turbocharger intercooler tubes
* diesel exhaust silencers
* piping, piping components, and piping elements The intended functions of the EDG system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary 2.3.3.21.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.21 and FSAR Section 8.3.1.1.1. using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.3.21-1 dated August 20, 2007, the staff asked the applicant to clarify, in LRA Table 2.3.3-17, what the intended verbiage of the component/commodity type of "piping, piping components, and piping components" for the EDG system was supposed to be.
In its response dated September 18, 2007, the applicant stated that the component/commodity type in LRA Table 2.3.3.17 was a typographical error and should read "piping, piping components, and piping elements."
Based on its review, the staff finds the applicant's response to RAI 2.3.3.21-1 acceptable because it adequately explained that the component/commodity group in LRA Table 2.3.3-17 should be identified as "piping, piping components, and piping elements." Therefore the staff's concern described in RAI 2.3.3.21-1 is resolved.
2.3.3.21.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such 2-90
 
omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the EDG system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.22 Diesel Generator Fuel Oil Storage and Transfer System 2.3.3.22.1 Summary of Technical Information in the Application LRA Section 2.3.3.22 describes the diesel generator fuel oil storage and transfer system, which stores, maintains, and supplies fuel oil to the diesel generators as required for all modes of diesel generator operation during normal and abnormal site and plant conditions. The system consists of two separate, independent fuel oil supply subsystems, each serving one of the two EDG system diesel engines. The vertical steel day tanks located in separate, isolated, fire resistant compartments, are situated to assure sufficient pressure at the engine fuel pumps.
The volume of each tank provides approximately six hours of storage, assuming maximum engine fuel consumption. The tank drains and overflows to the building floor drain system and the flow is then delivered to an oil separator unit in the yard for eventual disposal.
The diesel generator fuel oil storage and transfer system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel generator fuel oil storage and transfer system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the diesel generator fuel oil storage and transfer system performs functions that support fire protection.
LRA Table 2.3.3-18 identifies diesel generator fuel oil storage and transfer system component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* diesel fuel oil storage tank building tank liners
* flow restricting elements
* fuel oil day tanks
* fuel oil system transfer pumps
* fuel oil tank flame arrestor elements
* fuel oil tank flame arrestors
* piping, piping components, and piping elements
* system strainer screens and elements
* system strainers The intended functions of the diesel generator fuel oil storage and transfer system component types within the scope of license renewal include:
* filtration
* heat transfer
* pressure-retaining boundary
* flow regulation 2-91
 
2.3.3.22.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.22 and FSAR Section 9.5.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.3.22-1 dated August 20, 2007, the applicant stated in LRA Section 2.3.3.22 that buried fuel oil piping is coated and cathodically protected. The staff noted that LRA Table 2.2-3 excludes the cathodic protection system from within the scope of license renewal. The staff requested that the applicant clarify whether cathodic protection for the diesel generator fuel oil storage and transfer system buried piping is included within the system identified in LRA Table 2.2-3, or if it should be included in LRA Table 2.3.3-18. Otherwise, the staff asked the applicant to explain why the cathodic protection system is not within the scope of license renewal.
In its response dated September 18, 2007, the applicant stated that the nonsafety-related cathodic protection system is correctly excluded from within the scope of license renewal in LRA Table 2.2-3. In addition, the applicant stated that coatings are used to prevent corrosion on the buried yard piping, and that the cathodic protection is used in addition to the coatings.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.22-1 acceptable because it adequately explained that the cathodic protection for the diesel generator fuel oil storage and transfer system buried piping is correctly excluded from within the scope of license renewal, and it is only used in addition to the buried piping's coating, which is the credited method of protection to prevent corrosion. Therefore the staff's concern described in RAI 2.3.3.22-1 is resolved.
In RAI 2.3.3.22-2 dated August 20, 2007, the staff noted that the applicant does not highlight on a license renewal drawing two supply lines from the fuel oil transfer pump piping sections of the diesel generator fuel oil day tanks, which indicates that they are not subject to an AMR. The staff believed that their failure could prevent the accomplishment of the system intended function, which is to transfer fuel oil to the day tanks. The staff requested that the applicant clarify whether or not these non-highlighted piping sections are subject to an AMR. The staff asked the applicant to explain the effects of their failure on the diesel generator fuel oil storage and transfer system if they are not subject to an AMR.
In its response dated September 18, 2007, the applicant agreed that the pipe vents identified on the license renewal drawing should be highlighted. Further, the applicant identified that these piping sections are included in component/ commodity "piping, piping components, and piping elements" in LRA Table 2.3.3-18.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.22-2 acceptable 2-92
 
because it corrected the LRA and the piping sections identified are subject to an AMR and are represented in LRA Table 2.3.3-18 and AMR Table 3.3.2-18 under component/commodity "piping, piping components, and piping elements." Therefore the staff's concern described in RAI 2.3.3.22-2 is resolved.
2.3.3.22.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel generator fuel oil storage and transfer system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.23 Diesel Generator Lubrication System 2.3.3.23.1 Summary of Technical Information in the Application LRA Section 2.3.3.23 describes the diesel generator lubrication system, which provides essential lubrication to EDG system engine components during all modes of operation.
The system consists of the following equipment (per diesel engine):
* one engine-driven pump
* one motor-driven standby pump (motor-driven auxiliary lube oil pump)
* one lube oil cooler
* three lube oil strainers
* two lube oil filters (one duplex filter and one keep-warm filter)
* one lube oil keep-warm pump
* one lube oil prelube electric heater (lube oil heater)
* piping, valves, and instrumentation The lube oil sump tank has low-level instrumentation for leak detection. The level alarm setpoint corresponds to an oil inventory of approximately 1,300 gallons in the system. Manual monitoring of the lube oil sump tank level can be performed either locally at the tank with the installed dipstick or remotely from the engine control panel with the tank level indicator.
The diesel generator lubrication system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel generator lubrication system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the diesel generator lubrication system performs functions that support fire protection.
LRA Table 2.3.3-19 identifies diesel generator lubrication system component types within the scope of license renewal and subject to an AMR:
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* closure bolting
* diesel engine lube oil sumps
* flow-restricting elements
* lube oil auxiliary pumps (motor-driven)
* lube oil cooler components
* lube oil cooler tubes
* lube oil keep-warm pumps
* piping, piping components, and piping elements
* system strainer screens and elements
* system strainers The intended functions of the emergency screen wash system component types within the scope of license renewal include:
* pressure boundary
* throttle
* heat transfer
* filtration 2.3.3.23.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.23 and FSAR Section 9.5.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.23.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel generator lubrication system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.24 Diesel Generator Cooling Water System 2.3.3.24.1 Summary of Technical Information in the Application LRA Section 2.3.3.24 describes the diesel generator cooling water system, which has a separate closed-loop cooling water system of a forced-circulation cooling water type to remove heat from the engine directly by means of a water jacket. The closed-loop system includes an 2-94
 
engine-driven jacket water pump, standpipe, and heat exchanger with interconnecting piping.
The closed-loop subsystem has an electric immersion heater and a motor-driven keep-warm circulating pump which maintains the engine in a ready to start condition. The tube side of the heat exchanger is supplied with cooling water from the ESW system. The engine-driven centrifugal jacket cooling water circulating pump is designed to provide cooling water during all diesel engine loadings.
The pump draws water from the bottom of the standpipe and discharges it through the heat exchanger before it enters the diesel engine cooling passages. The standpipe serves two purposes, as the storage tank for the system and as an absorbent of changes in cooling water volume as the diesel engine heats up and cools down. System makeup is from the potable water supply. The jacket water is treated by addition or removal of chemicals.
The diesel generator cooling water system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel generator cooling water system potentially could prevent the satisfactory accomplishment of a safety-related function. The diesel generator cooling water system also performs functions that support fire protection.
LRA Table 2.3.3-20 identifies diesel generator cooling water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* diesel jacket water keep-warm pumps
* diesel jacket water standpipes, vents, and heaters
* jacket water cooler components
* jacket water cooler tubes
* piping, piping components, and piping elements The intended functions of the diesel generator cooling water system component types within the scope of license renewal include:
* pressure boundary
* heat transfer 2.3.3.24.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.24 and FSAR Section 9.5.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.3.24.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel generator cooling water system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.25 Diesel Generator Air Starting System 2.3.3.25.1 Summary of Technical Information in the Application LRA Section 2.3.3.25 describes the diesel generator air-starting system, which can supply a sufficient quantity of air from its starting air tanks to start the cold diesel engine by cranking it five times without recharging the receiver. The diesel generator air-starting system operates under the same environmental conditions as the diesel generator it serves. Each of the diesel generators has a physically separate air-starting system consisting of two alternating current motor-driven air compressors, two moisture separators, two air dryers and two starting air tanks each capable of five cold start attempts. The system is designed so failure of one receiver does not affect the ability of the remaining receiver to deliver the required quantity of air. Each compressor can recharge one receiver within thirty minutes after a discharge following five starting attempts.
Each starting air tank connects to the diesel engine starting mechanism independently. Upon receipt of a diesel generator start signal, all start-air admission valves open simultaneously, delivering air to the air distributors and the individual air-start valves in proper sequence.
Coincident with admission of air to the cylinders, starting air applied to the governor hydraulic system opens engine fuel racks to maximum fuel position on emergency start. Air supply to each receiver by a motor-driven nonsafety-related air compressor is isolated from the receiver by a safety grade check valve.
The diesel generator air-starting system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel generator air starting system potentially could prevent the satisfactory accomplishment of a safety-related function. The diesel generator air starting system also performs functions that support fire protection.
LRA Table 2.3.3-21 identifies diesel generator air-starting system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* diesel starting air tanks
* piping, piping components, and piping elements
* system strainer screens and elements
* system strainers 2-96
 
The intended functions of the diesel generator air-starting system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.25.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.25 and FSAR Section 9.5.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.25.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel generator air-starting system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.26 Security Power System 2.3.3.26.1 Summary of Technical Information in the Application LRA Section 2.3.3.26 describes the security power system, which provides reliable power to the security building and plant security equipment. For this purpose the system employs both an uninterruptible power supply, provided by an inverter, and an auxiliary diesel generator power source.
The security power system performs functions that support fire protection.
LRA Table 2.3.3-22 identifies security power system component types within the scope of license renewal and subject to an AMR:
* buried tanks
* closure bolting
* diesel combustion air intake piping, piping components, and piping elements
* diesel engine exhaust piping, piping components, and piping elements
* elastomer seals and components
* fan housings 2-97
* fuel oil system transfer pumps
* fuel oil tank flame arrestor elements
* fuel oil tank flame arrestors
* lube oil cooler components
* lube oil cooler tubes
* piping, piping components, and piping elements
* radiator components
* radiator tubes
* tanks The intended functions of the security power system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary 2.3.3.26.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.26 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.26.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the security power system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.27 Instrument Air System 2.3.3.27.1 Summary of Technical Information in the Application LRA Section 2.3.3.27 describes the instrument air system, which provides dry, filtered, oil-free compressed air to meet pneumatic instrument and control requirements. Any of three air compressors may supply the instrument air system. The service air system is normally connected to the instrument air system. Instrument air system components include two instrument air receivers, two service air receivers, two breathing air receivers, piping, valves, and instrumentation. The air receivers are in the turbine building outdoor portion. There is an 2-98
 
air-operated containment isolation valve at the containment penetration for the instrument air system.
Accumulators store compressed air/gas to actuate selected valves required to operate during and following an accident, when credit cannot be taken for the availability of air compressors.
Systems and components supplied with accumulators include the pressurizer PORVs, containment hydrogen purge system valves, and containment vacuum breaker system relief valves. Air-operated valves without accumulators are designed to fail in their required safe position on loss of instrument air pressure.
The instrument air system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the instrument air system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the instrument air system performs functions that support SBO and EQ.
LRA Table 2.3.3-23 identifies instrument air system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the instrument air system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.27.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.27 and FSAR Section 9.3.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.27.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the instrument air system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.28 Service Air System 2.3.3.28.1 Summary of Technical Information in the Application LRA Section 2.3.3.28 describes the service air system, which is designed to deliver dry, filtered, oil-free compressed air for operation of pneumatic tools and other nonsafety-related services.
The service air system performs no safety-related function other than containment isolation.
Service air system lines penetrating the containment structure have locked, closed, manual isolation valves located outside the containment. Compressed air from the service air receivers supplies service air requirements. The service air system consists of piping, valves, and instrumentation downstream of the service air receivers in the turbine building. Safety-related system piping is for containment penetration as well as certain supply piping for essential services chilled water system.
Interacting systems include the instrument air system. A control valve in the common header for the service air and instrument air systems automatically isolates the service air system from the instrument air system in the event of decreased service air receiver pressure to preserve instrument air pressure. The compressed air supply system compresses, filters, and dries air supplied to the service air system. The design connections for the air compressors enable any of the three compressors to supply the service air system.
The service air system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the service air system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the service air system performs functions that support SBO.
LRA Table 2.3.3-24 identifies service air system component types within the scope of license renewal and subject to an AMR:
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the service air system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.28.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.28 and FSAR Section 9.3.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In RAI 2.3.3.28-1 dated August 20, 2007, the staff stated that a license renewal drawing for the 2-100
 
service air system depicts valve 7SA-V79-1 as attached to the continuation piping required for containment isolation at penetration M-41. The piping required for the containment isolation at penetration M-41 is highlighted as within the scope of license renewal for functional support (seismic continuity) pursuant to 10 CFR 54.4(a)(2). The staff asked the applicant to explain why valve 7SA-V79-1 is not highlighted as within the scope of license renewal in accordance with10 CFR 54.4(a)(2), since it may be a part of the continuation piping needed for seismic continuity.
In its response dated September 18, 2007, the applicant stated that valve 7SA-V79-1 is within the scope of license renewal and is depicted on the service air system license renewal drawing near containment penetration M-41. Valve 7SA-V79-1 should have been highlighted on the license renewal drawing as within the scope of license renewal pursuant to 10 CFR 54.4(a)(2),
since it is part of the connected piping needed for seismic continuity. The applicant further stated that valve 7SA-V79-1 is included in the component/commodity group "piping, piping components, and piping elements" shown in LRA Table 2.3.3-24.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.28-1 acceptable because the applicant clarified that valve 7SA-V79-1 shown on the service air system license renewal drawing should have been highlighted indicating that it was within the scope of license renewal pursuant to 10 CFR 54.4(a)(2), since it is part of the connected piping for seismic continuity. Although not highlighted on the license renewal drawing, valve 7SA-V79-1 has been included in the component/commodity group "piping, piping components, piping elements" in LRA Table 2.3.3-24 and thus subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.28-1 is resolved.
In RAI 2.3.3.28-2 dated August 20, 2007, the staff stated that LRA Section 2.3.3.28 states that the service air system includes safety-related system piping associated with the containment penetration as well as supply piping for the essential services chilled water system. In the LRA, the applicant also stated that the license renewal scoping boundaries for the service air system are shown on one boundary drawing, which is listed. However, the staff noted that service air system piping and components are highlighted on two other license renewal scoping drawings associated with the essential services chilled water system, indicating these components are within the scope of license renewal. Therefore, the staff asked the applicant to explain why the two additional license renewal scoping drawings are not included on LRA page 2.3-110 as license renewal scoping drawings for the service air system.
In its response dated September 18, 2007, the applicant stated that license renewal drawings have been developed to facilitate staff review. These drawings depict mechanical components that support system intended functions and are within the scope of license renewal. In LRA Section 2.3.3.28, only the service air system scoping drawing is shown. This drawing is the primary drawing identifying components for the service air system. The applicant further stated that for any given system, it was not the intent of the license renewal review to cross reference every license renewal scoping drawing to every in-scope mechanical component of that system.
In the case of the service air system, there are other license renewal scoping drawings that identify a small number of service air system components. The two drawings discussed in the question mainly depict essential services chilled water system components and are examples of drawings with a relatively small number of service air system components. These two drawings are considered secondary drawings for the service air system and are not required by the HNP process to be listed in LRA Section 2.3.3.28.
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Based on its review, the staff finds the applicant's response to RAI 2.3.3.28-2 acceptable because the applicant clarified that it was not required by the HNP license renewal process to list what HNP considered secondary drawings to the service air system in LRA Section 2.3.3.28. The applicant has identified service air system components within the scope of license renewal on the two secondary drawings but under its process elected not to list them in LRA Section 2.3.3.28, which addresses the service air system. Therefore, the staff's concern described in RAI 2.3.3.28-2 is resolved.
2.3.3.28.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the service air system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.29 Bulk Nitrogen Storage System 2.3.3.29.1 Summary of Technical Information in the Application LRA Section 2.3.3.29 describes the bulk nitrogen storage system, which supplies nitrogen gas for various plant requirements. Examples of equipment which use this nitrogen are the VCT, steam generators during layup periods, pressurizer relief tank, reactor makeup water storage tank, main condenser, safety injection system accumulators, the main feedwater isolation valve (MFIV) accumulators, and the three accumulator tanks for the pressurizer PORVs. The bulk nitrogen storage system can be divided into two parts: (1) the bulk nitrogen storage equipment and (2) the nitrogen distribution system composed of piping, valves, and accumulators required to service plant components. The bulk nitrogen storage system consists of a cryogenic liquid storage tank, two nitrogen pumps, two pressure ambient air vaporizers, a pressure control manifold, and three pressure gas storage vessels in the gas storage yard. A low-pressure alarm informs the operator of a malfunction and the necessity of corrective action to prevent interruption of gases to various users.
The bulk nitrogen storage system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the bulk nitrogen storage system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-25 identifies bulk nitrogen storage system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the bulk nitrogen storage system component types within the scope of license renewal is to provide a pressure-retaining boundary.
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2.3.3.29.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.29 and FSAR Section 9.3.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.29.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the bulk nitrogen storage system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.30 Hydrogen Gas System 2.3.3.30.1 Summary of Technical Information in the Application LRA Section 2.3.3.30 describes the hydrogen gas system, a nonsafety-related system that supplies hydrogen to (1) the plant main generator for generator rotor and stator cooling and (2) to the VCT in the CVCS to control oxygen concentration in the RCS. The system also has a hydrogen gas bottle for supply to the WPB laboratories. The hydrogen gas system can be divided into (1) bulk hydrogen storage equipment with a cryogenic liquid hydrogen storage vessel, an ambient vaporizer, pressure control manifolds, interconnecting piping, valves, and I&Cs and (2) the hydrogen distribution system with piping and valves to service the turbine generator and the VCT. The hydrogen gas storage area is located so any malfunction or failure of a hydrogen gas system component has no adverse effect on any safety-related system or component.
The failure of nonsafety-related SSCs in the hydrogen gas system potentially could prevent the satisfactory accomplishment of a safety-related function. The hydrogen gas system also performs functions that support fire protection.
LRA Table 2.3.3-26 identifies hydrogen gas system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements 2-103
 
The intended function of the hydrogen gas system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.30.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.30 and FSAR Section 9.3.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.30.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the hydrogen gas system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.31 Fire Protection System 2.3.3.31.1 Summary of Technical Information in the Application LRA Section 2.3.3.31 describes the fire protection system with the following design features:
* a water supply and distribution system, including fire pumps and yard and interior distribution piping
* automatic suppression systems
* a fire detection system with automatic suppression systems actuation, and fire protection equipment supervision and signaling
* manual fire response equipment (e.g., portable fire extinguishers, hose stations, breathing equipment, protective clothing, emergency communication equipment, and emergency lighting)
* certain types of fire barriers (i.e., fire doors) and penetrations for piping, electrical cable/conduit, and HVAC ducts The fire protection system contains nonsafety-related components that have the potential to cause an adverse physical interaction with safety-related equipment and/or nonsafety-related piping components connected to and providing support for the safety-related functional boundary of the system. The fire protection system includes components relied on in safety 2-104
 
analyses or plant evaluations to perform a function that demonstrates compliance with the NRC regulations for the fire protection, SBO, and EQ programs.
LRA Table 2.3.3-27 identifies fire protection system component types within the scope of license renewal and subject to an AMR:
* buried piping, piping components, and piping elements
* closure bolting
* containment isolation piping and components
* diesel-driven fire pump
* diesel-driven fire pump fuel oil storage tank
* diesel engine exhaust piping, piping components, and piping elements
* diesel exhaust silencers
* filters
* fuel oil tank flame arrestor elements
* fuel oil tank flame arrestors
* heat exchanger components
* heat exchanger tubes
* jockey fire pump
* motor-driven fire pump
* piping, piping components, and piping elements
* spray nozzles
* sprinkler heads
* system strainer screens and elements
* system strainers The intended functions of the fire protection system component types within the scope of license renewal include:
* filtration
* heat transfer
* pressure-retaining boundary
* adequate and proper flow distribution 2.3.3.31.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.31, FSAR Section 9.5.1, SER dated November 1983 (Supplements 1 through 4), and SER dated January 12, 1987, approving the HNP Fire Protection Program listed in the HNP Operating License Condition 2.F using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff also reviewed HNPs commitment to the fire protection program requirements of 2-105
 
10 CFR 50.48, (i.e., a point-by-point comparison with BTP CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," Revision 2, July 1981).
The staff's review of LRA Section 2.3.3.31 identified areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.31-1 dated February 22, 2007, the staff stated that LRA Section 2.3.3.31 describes fire protection system components. It is not clear from review of LRA Tables 2.3.3-27 and 3.3.2-27 that fire hydrants, standpipes, manual hose stations, floor drains, dikes, filter housings, fire proofing, fire wrap, orifices, valve bodies, and RCP oil collection system components are included within the scope of license renewal and subject to an AMR. The staff requested that the applicant verify whether these components are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If not, the staff requested that the applicant provide a justification for their exclusion.
In its response dated March 23, 2007, the applicant stated that the components identified in RAI 2.3.3.31-1 are within the scope of license renewal and subject to an AMR. In LRA Section 2.3.3.31, the applicant states:
The Fire Protection System at HNP, which is primarily the water based fire suppression system. It includes the fire hydrants, standpipes, and valve bodies among other components shown on the license renewal highlighted reference drawings. This system also contains manual hose stations, as well as fire doors, fire wrap, and penetrations, which HNP license renewal methodology identifies as civil/structural commodities in the yard structures or within the specific structures that house them. Additionally, HNP methodology identifies fire proofing as a material in the civil/structural AMR tables and not a specific commodity. For example, a fire barrier may be constructed using a fire proofing material. Table 2.3.3.31-1 below provides a more complete discussion of this material and its use. As stated on LRA page 2.3-115, Section 2.4 contains the scoping and screening information for structures.
Other items in the above RAI are included as components/commodities in other systems and structures in the scoping and screening sections of the LRA. The associated mechanical systems have 10 CFR 54.4(a)(3) system intended functions associated with fire protection. For example, on LRA page 2.3-17 states:
The Reactor Coolant Pump (RCP) and Motor System meets the scoping criteria for fire protection. In order to reduce the possibility of fire, the system includes an oil collection system. The system also supports the post-fire functions of Reactor Coolant System (RCS) inventory and pressure control.
Furthermore, the table on LRA page 2.3-17 lists the system intended functions. One of the functions states that the system "Support[s] functions associated with fire protection." The LRA screening and AMR tables do not distinguish between the criteria that would place the commodities within the scope for fire protection scoping as opposed to other scoping criteria.
The functions listed in these tables are component/commodity intended functions and do not 2-106
 
generally align themselves with any specific scoping criterion. Except for the components/commodities assigned to the Fire Water System Program and the Fire Protection Program, the fire protection scoping criteria have no bearing on the component, material and environment combinations listed in the AMR tables and the manner in which the aging effects are managed.
The structure intended functions, which have been used to address fire protection concerns, are listed below and in LRA Section 2.4 for each structure.
* C-4 Fire Barrier, which is defined as "Provide fire rated barriers to confine or retard a fire from spreading to or from adjacent areas of the plant."
* C-7 Structural Support for Criterion (a)(2) and (a)(3) components, which is defined as "Provide structural support and/or functional support to non-safety related components."
The full list of structure intended functions and their definitions are provided in LRA Table 2.0-1.
Table 2.3.3.31-1 below provides the specific component/commodities that represent the items in RAI 2.3.3.31-1. This table also lists the corresponding LRA Scoping/Screening and AMR Results Tables.
Table 2.3.3.31-1 Component/Commodity Locations in License Renewal Application RAI Component      Screening          Included in                AMR Table              Comments Table      Component/Commodity Fire Hydrants      2.3.3-27    Buried piping, piping    3.3.2-27 Carbon and Low  Fire Protection components, and piping    Alloy Steel and Gray Cast System - see LRA elements                  Iron in Raw Water and    Section 2.3.3.31 Soil                      for the system description.
Standpipes        2.3.3-27    Piping, piping            3.3.2-27 components, and piping elements Manual Hose        2.4.1-1      Fire Hose Stations        3.5.2-1                  The Fire Hose Station            2.4.2-1                                3.5.2-2                  Stations listed on 2.4.2-9                                3.5.2-10                  Table 2.4.2-28 and 2.4.2-16                              3.5.2-17                  Table 3.5.2-29 are 2.4.2-17                              3.5.2-18                  associated with the 2.4.2-25                              3.5.2-26                  Fire Hose Cabinet 2.4.2-26                              3.5.2.27                  Support Structures.
2.4.2-27                              3.5.2-28 2.4.2-28                              3.5.2-29 Includes Carbon Steel in all environments 2-107
 
RAI Component  Screening            Included in                    AMR Table                  Comments Table        Component/Commodity Drain systems are used to remove fire water to prevent accumulation in areas needed for safe shutdown and to collect potentially radioactive water. Drain systems are also within the scope of license renewal for other scoping criteria, e.g., safety-related containment penetrations, and nonsafety-related spatial interactions or augmented quality.
2.4.1-1        Floor Drains                  3.5.2-1                        This includes the 2.4.2-1                                      3.5.2-2                        grating and the 2.4.2-9                                      3.5.2-10                      exposed portion of 2.4.2-16                                      3.5.2-17                      embedded drains Floor Drains 2.4.2-25                                      3.5.2-26                      which mitigate the effects of flooding.
2.3.3-29        Piping, piping                3.3.2-29 All Material/        Oily Drains System components, and piping        environments for these        - LRA elements                      components/commodities        Section 2.3.3.33 describes the flow System Strainers                                            path supporting fire protection.
2.3.3-30        Piping, piping                3.3.2-30 All Material/        Radioactive Floor components, and piping        environments for these        Drains System -
elements                      components/commodities        LRA Section 2.3.3.34 System Strainers                                            describes the flow path supporting fire Tanks                                                        protection in addition to the paths and equipment used to support other scoping criteria.
2.3.3-31        Piping, piping, and piping    3.3.2-31                      The Radioactive Floor Drains                  elements and tanks                                          Equipment Drains (continued)                                                                                System contains System Strainers                                            components that interface with those required to collect fire fighting water flow. In addition to fire protection, LRA Section 2.3.3.35 describes the equipment and flow paths that are in-scope to support many other scoping criteria.
2-108
 
RAI Component  Screening        Included in            AMR Table      Comments Table  Component/Commodity 2.3.3-32  Piping, piping        3.3.2-32        Secondary Waste components, piping                      System - LRA elements and tanks                      Section 2.3.3.36 describes this system. The license renewal flow diagram shows the buried portion as the 8 inch drain supply pipe header to the Yard Oil Separator shown on drawing 5-G-0485-LR.
2.3.3-33  Piping, piping        3.3.2-33        Laundry and Hot components, piping                      Shower System -
elements                                LRA Section 2.3.3.37 WPB Laundry and Hot                    describes the Shower Tanks                            interface with drains that collect fire fighting water in the WPB, Fuel Handling Building, and the Reactor Auxiliary Building.
2.3.3-39  Piping, piping        3.3.2-39        Oily Waste components, piping                      Collection and elements, and tanks                    Separation System
                                                                - LRA Section 2.3.3.43 describes the interface with fire fighting water drainage.
Floor Drains  2.3.3-40  Liquid Waste Holdup    3.3.2-40        Liquid Waste (continued)              Tank                                    Processing System
                                                                - LRA Piping, piping                          Section 2.3.3.44.
components, piping                      The system elements, and tanks                    interfaces with systems required to collect fire fighting water drainage.
2-109
 
RAI Component    Screening        Included in            AMR Table            Comments Table  Component/Commodity 2.4.2-21  Concrete: Exterior Above 3.5.2-22              This includes the Grade                                          concrete dike wall which make a pit around the diesel oil storage tank (for the diesel engine driven fire pump).
2.4.2-24  Concrete: Exterior Above 3.5.2-25              This includes the Grade                                          concrete foundation and walls which make a pit around the Main, Startup, and Unit Auxiliary Transformers.
Dikes 2.4.2-28  Concrete: Exterior Above 3.5.2-29              This includes the Grade                                          curb/wall which retains oil spillage at the Oil Separator and at the Diesel Fuel Unloading Area.
2.4.2-24  Concrete: Exterior Below 3.5.2-25              This includes the Grade                                          concrete foundation and walls which make a pit around the Main, Startup, and Unit Auxiliary Transformers.
2.4.2-28  Concrete: Exterior Below 3.5.2-29              This includes the Grade                                          curb/wall which retains oil spillage Dikes at the Oil (continued)
Separator and at the Diesel Fuel Unloading Area.
Filter Housings 2.3.3-27  Filters                  3.3.2-27 All material/ This represents the environment            Diesel Driven Fire combinations for this  Pump Engine Oil commodity              Bath Air Intake Filter.
2-110
 
RAI Component  Screening        Included in              AMR Table      Comments Table  Component/Commodity Fire Proofing None      Fire Barrier Assemblies  3.5.2-2,          Fire Proofing is not 3.5.2-10,        listed as a and                      3.5.2-12,        separate 3.5.2-13,        commodity group Fire Barrier Penetration 3.5.2-17,        for license renewal Seals                    3.5.2-22,        but is generically 3.5.2-26,        included as a 3.5.2-27,        material type in for 3.5.2-28          the commodity groups listed in AMR tables. These commodity groups include materials such as sealants, elastomers, foams, thermo-lag, gypsum, etc., as defined in plant documents. The AMR tables in which they appear are listed. There are no sprayed on flame retardant cable coatings used at HNP.
Fire Wrap    2.4.2-1    Fire Barrier Assemblies  3.5.2-2          Fire Barrier 2.4.2-11                            3.5.2-12          Assemblies (See                                3.5.2-17          includes cable and Comments)                                            cable tray fire 2.4.2-16                                              wraps, cable tray fire breaks, fire damper wraps, thermo-lag barriers, and one gypsum board wall.
The Fire Barrier Assemblies listed on Table 3.5.2-12 were inadvertently omitted from Table 2.4.2-11.
Orifices      None                                None              No system orifices were found in the fire protection system.
2-111
 
RAI Component      Screening        Included in              AMR Table            Comments Table    Component/Commodity Valve bodies      2.3.3-27    Piping, piping            3.3.2-27 All material/
components, and piping    environment elements                  combinations for these commodities Buried piping, piping components, and piping elements Reactor coolant    2.3.1-4    RCP Lube Oil Collection  3.1.2-4 All material/  RCP and motor pump oil                      Tank                      environment            system collection                                              combinations for these system                        RCP Oil Spill Protection  commodities components                    System Piping Based on its review, the staff finds the applicant's response to RAI 2.3.3.31-1 acceptable because it adequately explained the applicant's interpretation of the component characterization.
The applicant explained that the fire hydrants, standpipes, and valve bodies are included in LRA Section 2.3.3.31 and are highlighted in license renewal drawings. Manual hose stations, as well as fire doors, fire wrap, and penetrations are included in the civil/structural commodities. Fire proofing was not identified as a specific commodity in license renewal methodology; however, fire proofing material is included as a material type in the commodity group such as sealant, elastomer, foams, Thermo-Lag, gypsum as defined in plant documents. Further, in its response, the applicant stated that the RCP oil collection system components motor system meets the scoping requirements in 10 CFR 54.4(a)(3) for support functions associated with fire protection that are within the scope of license renewal and subject to an AMR.
The staff noted that Hemyc/MT fire barrier assemblies were not included in the line item description in LRA Table 3.5.2-12. The staff believes that Hemyc/MT fire barriers considered as a passive component should be within the scope of license renewal in accordance with 10 CFR 54.49(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). The staff concludes that Hemyc/MT fire barriers were excluded incorrectly from within the scope of license renewal and subject to an AMR.
During a telephone conference dated November 14, 2007, the staff requested that the applicant justify why Hemyc/MT fire barriers were not included within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
In its response dated December 11, 2007, the applicant stated that LRA Plant Specific Note 565 to LRA Tables 3.5.2-2, 3.5.2-12, and 3.5.2-17 reads:
Fire barriers assemblies types include the following: Thermo Lag walls, Gypsum Board walls, Cable Fire Wraps (including HemycTM, InteramTM and Promatec 2-112
 
MTTM), and Cable Tray Breaks.
Based on its review, the staff finds the applicants response to RAI 2.3.3.31-1 acceptable because the applicant to include fire hydrants, standpipes, manual hose stations, floor drains, dikes, filter housings, proofing material, fire wrap (thermo lag walls, gypsum board walls, cable fire wraps, and cable tray breaks), orifices, valve bodies, and RCP oil collection system components in the radioactive waste system, as within the scope of license renewal and subject to an AMR. The staff is adequately assured that these components will be considered appropriately during plant aging management activities. Therefore, the staff's concern described in RAI 2.3.3.31-1 is resolved.
In RAI 2.3.3.31-2 dated February 22, 2007, the staff stated that the LRA Section B.2.14 includes an AMP for fire barrier assemblies. It is not clear from the review of LRA Tables 2.3.3-27 and 3.3.2-27 that fire barrier walls, ceilings, floor, slabs, penetration seals, seismic joint filler, and fire doors are included within the scope of license renewal and subject to an AMR. The staff requested that the applicant verify whether these components are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If not, the staff requested that the applicant provide a justification for their exclusion.
In its response dated March 23, 2007, the applicant stated that the commodities listed in this RAI are within the scope of license renewal and are subject to an AMR as described in LRA Section 2.4. In LRA Section 2.3.3.31, the applicant describes the "Fire Protection System" at HNP, which is primarily the water-based fire suppression system. It includes the fire hydrants, standpipes, and valve bodies among other components shown on the highlighted reference drawings. This system also includes penetration seals (fire barrier penetration seals at HNP),
seismic joint filler, and fire doors (fire rated doors at HNP). The HNP license renewal methodology identifies fire barrier penetration seals, seismic joint filler, and fire rated doors as civil/structural commodities in the structures that house them. As stated in LRA Section 2.3.3.31 on Page 2.3-115, "Fire barriers are addressed as civil commodities within the associated structure. Scoping and screening of structures is discussed in Section 2.4." Fire barrier walls, ceilings, floors, slabs are not included with the "Fire Protection System" in LRA Tables 2.3.3-27 and 3.3.2-27. Table 2.3.3.31-2 below indicates the specific components/commodities that represent the items in RAI 2.3.3.31-2 and the relevant tables in LRA Sections 2.4 and 3.5.
2-113
 
Table 2.3.3.31-2 Component/Commodity Locations in License Renewal Application RAI Component      Screening          Included in      AMR Table          Comments Table    Component/Commodity Fire Barrier        2.4.2-1      Fire Barrier Assemblies  3.5.2-2  Fire Barrier Assemblies Assemblies          2.4.2-11 (See                          3.5.2-12  include cable and cable tray Comments)                              3.5.2-17  fire wraps, cable tray fire 2.4.2-16                                        breaks, fire damper wraps, thermo-lag barriers, and one gypsum board wall as discussed in response to RAI 2.3.3.31-1. This would include thermo-lag barrier walls which are located only in the reactor auxiliary building. The Fire Barrier Assemblies listed on Table 3.5.2-12 were inadvertently omitted from Table 2.4.2-11.
2.4.1-1      Concrete: Above Grade -  3.5.2-1  These concrete commodity Dome; Wall; Ring girder;          groups have a C-4 intended Basement                          function of: "Provide rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant."
Fire Barrier Walls, 2.4.2-1      Concrete: Exterior Above 3.5.2-2  These concrete commodity Ceilings, Floor    2.4.2-9      Grade                    3.5.2-10  groups have a C-4 intended Slabs              2.4.2-11                              3.5.2-12  function of: "Provide rated 2.4.2-12      Concrete: Interior      3.5.2-13  fire barrier to confine or 2.4.2-16                              3.5.2-17  retard a fire from spreading 2.4.2-21      Concrete: Roof Slab      3.5.2-22  to or from adjacent areas of 2.4.2-24                              3.5.2-25  the plant."
2.4.2-25                              3.5.2-26 2.4.2-26                              3.5.2-27 2.4.2-27                              3.5.2-28 Fire Barrier Walls  2.4.2-1      Masonry Walls            3.5.2-2  This masonry commodity 2.4.2-16                              3.5.2-17  group has a C-4 intended function of: "Provide rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant."
Penetration Seals  2.4.2-1      Fire Barrier Penetration 3.5.2-2  This Fire Barrier Penetration 2.4.2-9      Seals                    3.5.2-10  Seal commodity group has 2.4.2-11                              3.5.2-12  a C-4 intended function of:
2.4.2-12                              3.5.2-13  "Provide rated fire barrier to 2.4.2-16                              3.5.2-17  confine or retard a fire from 2.4.2-21                              3.5.2-22  spreading to or from 2.4.2-25                              3.5.2-26  adjacent areas of the plant."
2.4.2-26                              3.5.2-27 2.4.2-27                              3.5.2-28 2-114
 
RAI Component        Screening            Included in      AMR Table            Comments Table        Component/Commodity Seismic Joint Filler  2.4.2-1        Seismic Joint Filler    3.5.2-2    This Seismic Joint Filler 2.4.2-16                                3.5.2-17    commodity group has a C-4 2.4.2-27                                3.5.2-28    intended function of:
                                                                            "Provide rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant."
Fire Doors            2.4.2-1        Fire Rated Doors        3.5.2-2    This Fire Rated Doors 2.4.2-9                                3.5.2-10    commodity group has a C-4 2.4.2-11                                3.5.2-12    intended function of:
2.4.2-16                                3.5.2-17    "Provide rated fire barrier to 2.4.2-25                                3.5.2-26    confine or retard a fire from 2.4.2-26                                3.5.2-27    spreading to or from 2.4.2-27                                3.5.2-28    adjacent areas of the plant."
Based on its review, the staff finds the applicant's response to RAI 2.3.3.31-2 acceptable because the applicant states that it considers fire barrier walls, ceilings, floor, slabs, penetration seals, seismic joint filler as civil/structural commodities, as discussed in LRA Section 2.4. The staff is adequately assured that these components will be considered appropriately as within the scope of licensing renewal and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.31-2 is resolved.
In RAI 2.3.3.31-3 dated August 7, 2007, the staff stated that the LRA drawing 5-G-0055-LRA, "Fire Protection System Unit 1," shows the auxiliary boiler fuel oil storage tanks foam fire suppression system as out of the scope of license renewal (i.e., not highlighted). The staff requested that the applicant verify whether the foam fire suppression system and its components are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requested that the applicant provide a justification for their exclusion.
In its response dated September 5, 2007, the applicant stated:
As described in LRA Section 2.3.3.31, the HNP fire protection system is within the scope of license renewal in accordance with 10 CFR 54.4(a). Although the auxiliary boiler fuel oil storage tanks foam fire suppression system is a part of the fire protection system, as discussed on LRA Page 2.3-116, the foam fire suppression system components do not support or perform any system intended function and are; therefore, not subject to an AMR per 10 CFR 54.21(a)(1). In LRA Section B.2.14, the applicant describes the position regarding the auxiliary boiler fuel oil storage tanks foam fire suppression system.
In addition, a foam suppression system is used to protect the auxiliary boiler fuel oil tanks, which are isolated from and over 500 feet from any Class 1 structure and those structures directly related to power production. The foam suppression system is not needed to comply with the requirements of 10 CFR 50.48.
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These tanks are considered part of the miscellaneous structures and are excluded from within the scope of license renewal. The foam protection equipment is isolated from the fire water system water supply and can have no impact on it (refer to the subject Scoping Drawing 5-G-055-LR). Miscellaneous structures are described in the response to item BTP 9.5-1, C.7.r, in a letter from S. R. Zimmerman (CP&L) to H. R. Denton, (NRC),
(Serial: NSL 86-137), "Fire Protection - BTP 9.5-1," dated May 7, 1986. An excerpt from that response is:
Project Conformance:
C.7.r. Miscellaneous Areas Miscellaneous areas such as plant administrative offices, shops, warehouses, and auxiliary boilers are located so that a fire or effects of a fire, including smoke, do not adversely affect any safety-related systems or equipment, since most will be located in separate, detached buildings.
The Fire Protection - BTP 9.5-1 position goes on to describe the protection equipment that is also provided. Since the fires in the miscellaneous areas are located so they do not adversely affect any safety-related systems or equipment, the components do not support the system intended function; therefore, do not require an AMR.
This position is consistent with the NEI 95-10 position regarding what to include within the scope of the CLB for regulated events. NEI 95-10, Revision 6, Section 3.1.3, states the following regarding systems that are relied on to support regulated events:
The information sources in Table 3.1-1 could be considered for identifying the systems, structures and components whose functions are relied on to demonstrate compliance with the regulatory requirements (i.e., whose functions were credited in the analysis or evaluation). Mere mention of a system, structure or component in the analysis or evaluation does not constitute support of a specified regulatory function.
Based on the above discussion, the foam fire suppression system and its components are a part of the fire protection system, which is within the scope of license renewal in accordance with 10 CFR 54.4(a). However, the foam fire suppression system components are not subject to an AMR in accordance with 10 CFR 54.21(a)(1), because these components are not needed to support the fire protection system intended function.
Based on its review, the staff did not find the applicant's response to RAI 2.3.3.31-3 acceptable.
The applicant stated that the auxiliary boiler fuel oil storage tanks foam fire suppression system is a part of the fire protection system, as discussed on LRA Page 2.3-116, and that the foam fire suppression system components do not support or perform any system intended function and; are therefore, not subject to an AMR pursuant to 10 CFR 54.21(a)(1). The staff finds this contrary to the HNP Point-by-Point Comparison with BTP CMEB 9.5-1, dated May 7, 1986.
HNPs response to BTP CMEB 9.5-1, Position C.7.r, states that, "The fuel oil tanks for auxiliary boiler are above ground surrounded by dikes sized to contained the entire tank content of oil and are equipped with a semi-fixed manual foam system."
The applicant indicated in the RAI response that the foam suppression system in question was not within the scope of license renewal because the system is not required to function to 2-116
 
suppress a fire to protect SSCs. Therefore, the applicant is using the requirements of 10 CFR 54.4(a)(2) to exclude the foam system. The applicant assumes there is no adverse effect due to the foam system failure. The applicant is excluding this component on that basis and has not properly identified the fact that this component is relied upon to meet the requirements of 10 CFR 50.48 (in accordance with the CLB) pursuant to10 CFR 54.4(a)(3).
However, BTP CMEB 9.5-1 Position C.7.r, states, "Miscellaneous areas such as shops, warehouses, auxiliary boiler rooms, fuel oil tanks, and flammable and combustible liquid storage tanks should be so located and protected that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment."
The applicant's CLB demonstrates that this component was credited to meet the guidance of BTP CMEB 9.5-1. Therefore, the foam system in question should not be excluded from the scope of license renewal. In addition, this component should not be excluded on the basis that it is not required to function to suppress a fire, nor is it required for compliance with 10 CFR 50.48, without factoring in the CLB.
During a telephone conference on November 14, 2007, the staff requested that the applicant justify why the foam fire suppression system and its associated components were not included within the scope of license renewal in accordance with to 10 CFR 54.4(a), and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
In its response dated December 11, 2007, the applicant stated that regarding the auxiliary boiler fuel oil storage tank manual foam suppression system, a review of historical documentation was performed in concert with interviews with knowledgeable plant personnel.
By letter to the applicant dated October 1978, the HNP architect/engineer recommended that a field-purchased and -installed, semi-fixed mechanical foam system be provided for the auxiliary boiler fuel oil storage tanks. The applicant approved the recommendation in December 1978 and requested that the architect/engineer provide the details of the installation. The details of the installation were transmitted in December 1982 with a recommendation that the foam system details be submitted to Nuclear Mutual Limited for review and approval. No additional requirements were identified at the time.
By letter from A. B. Cutter (CP&L) to H. R. Denton (NRC), Serial: NLS-86-188, dated June 4, 1986, the applicant incorporated the fire protection program into FSAR Chapter 9.
Table 3.7-5 included the ESW intake structure, ESW screening structure, diesel generator building, and the diesel fuel oil storage tank building. The technical specification bases stated:
The OPERABILITY of the Fire Suppression Systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety-related equipment is located.
In the event of a fire in the auxiliary boiler fuel oil storage tank area, the out building fire pre-plans procedure states that the primary access route is from hydrant 1FP-521 east of the fuel oil tanks with a fog nozzle; and, for fire extinguishment:
* A hose trailer is needed
* Hydrant 1FP-521 east of tanks is equipped with a fog nozzle 2-117
* The backup hydrant is south of 1FP-521, and
* Hydrant 1FP-523, north of gas storage, may also be used to attack the area from the west In addition, two 50 ft. sections of 2/2 inch fire hose, a double female adapter, adjustable wrench and a pickup tube are required to connect the eductor for each tank to the hydrant in order to apply 150 gallons of foam concentrate to extinguish a fire in the diked area.
Based on the preceding discussion, the installation of the manual foam suppression system for the auxiliary boiler fuel oil storage tanks was based on commercial requirements and not related to compliance with the fire protection rule.
Based on its review, the staff finds the applicant's response to RAI 2.3.3.31-3 acceptable because the applicant explained that the foam fire suppression system and its associated components are not credited for compliance with 10 CFR 40.48 and GDC3. This system is for property protection and for loss prevention. Therefore, the staffs concern described in RAI 2.3.3.31-3 is resolved.
In RAI 2.3.3.31-5 dated August 7, 2007, the staff stated that the FSAR listed various types of water fire suppression systems provided in the plant fire areas for fire suppression activities.
The fire suppression systems in various areas are:
* Automatic Pre-Action Sprinkler System (Fire Areas: 10-A-CSRA, 12-A-BAL, 12-A-HV&IR, 5-W-BAL, and Turbine Generator- Unit No.1)
* Automatic Multi-Cycle Sprinkler System (Fire Areas: 1-A-BAL, 1-A-EPA, 1-A-EPB, 5-F-CHF, 5-F-FPP,1-D-DGA,1-D-DGB,1-D-DTA,1-D-DTB,1-O-PA, and 1-O-PB)
* Water Spray System (Fire Area: Turbine Generator- Unit No. 1 and Charcoal Filter Assemblies)
* Manual Fluoro-Protein Mechanical Foam System (Fuel Oil Storage Tanks)
* Wet-Pipe System
* Deluge Systems The staff requested that the applicant verify whether the above fire suppression systems installed in various areas of the plant are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requested that the applicant provide justification for their exclusion.
In its response dated September 5, 2007, the applicant stated that, as described in LRA Section 2.3.3.31, the HNP fire protection system is within the scope of license renewal pursuant to 10 CFR 54.4(a). Included in the fire protection system are the fire suppression systems listed below. Also listed is whether the fire suppression system and/or fire area combination is subject to an AMR pursuant to 10 CFR 54.21(a)(1) and justification for their exclusion if not subject to the requirements of 10 CFR 54.21(a)(1).
Some of the fire areas listed below are very large areas consisting of many fire zones as 2-118
 
indicated in the fire hazards analysis. These fire areas may have more than one type of fire suppression system. For example, Fire Area 5-W-BAL has wet pipe systems on Elevations 261 ft. and 276 ft., and a pre-action system on Elevation 91 ft. If the suppression system in the fire area listed is subject to an AMR, an affirmative answer is given. In this case, that type of suppression system protects equipment in at least one of the fire zones in the fire area. A negative answer contains an accompanying justification for the exclusion from an AMR.
Additionally, a not applicable (N/A) response has a corresponding explanation.
YES    Automatic Pre-Action Sprinkler System (Fire Areas: 1-A-CSRA (The question incorrectly identified this area as 10-A-CSRA.), 12-A-BAL, 12-A-HV&IR, 5-W-BAL, and Turbine Generator- Unit No. 1)
YES    Automatic Multi-Cycle Sprinkler System (Fire Areas: 1-A-BAL, 1-A-EPA, 1-A-EPB, 5-F-CHF, 5-F-FPP, 1-D-DGA, 1-D-DGB, 1-D-DTA, 1-D-DTB, 1-O-PA, and 1-O-PB);
although not included in the RAI, Fire Area 1-C also uses these suppression systems, and the water supplies are shown in License Renewal Scoping drawing 5-G-0388-LR.
YES    Water Spray System (Fire Area: Turbine Generator- Unit No. 1 Building).
N/A    Water Spray System (Fire Area: Turbine Generator- Unit No. 1 Building charcoal filter room). This equipment in the Turbine Building is protected by a Pre-Action System as noted above. Water Spray Systems are not used for protection of charcoal filter assemblies.
NO      Manual Fluoro-Protein Mechanical Foam System (Fuel Oil Storage Tanks). This system protects the Auxiliary Boiler Fuel Oil Storage Tanks. See response to RAI 2.3.3.31-3.
YES    Wet-Pipe Systems are shown on 5-G-0406-LR. They are in the HVAC room on the roof of the RAB (coordinate B-16) and in various locations in the Waste Processing Building.
YES    Deluge Systems (Note: The deluge systems are the same as the Water Spray System.
There are five Water Spray (deluge) systems using open sprinklers for several areas on Elevation 261 ft. in the Turbine Building and seven systems using spray nozzles protecting the transformers adjacent to the Turbine Building.).
The above fire suppression systems that are subject to an AMR are highlighted components on license renewal drawing 5-G-0406-LR. The following designators on these drawings show the types of systems that are within the scope of license renewal. The symbols on the drawings indicating the type of system are these letters enclosed in a triangle.
M        -      Multi-cycle Sprinkler Systems P        -      Pre-Action Sprinkler Systems W        -      Water Spray Systems (Note that this designator is also used for the Deluge Systems listed in FSAR Table 9.5.1-5B S        -      Wet Pipe Sprinkler System Based on its review, the staff did not find the applicant's response to RAI 2.3.3.31-5 acceptable.
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The applicant explains that the manual fluoro-protein mechanical foam system for fuel oil storage tanks listed above is not needed to meet the requirements of 10 CFR 50.48. The staff finds this contrary to the HNP fire protection SER, dated April 1981, as the CLB. HNP committed to BTP CMEB 9.5-1 to satisfy Regulatory Position C.7.r "Miscellaneous Areas," by providing fuel oil storage tanks with a manual fluoro-protein mechanical foam system. The staff finds that the applicant's analysis of fire protection regulations did not completely capture the fire protection SSCs required for compliance with 10 CFR 50.48. The scope of SSCs required for compliance with 10 CFR 50.48 and GDC 3 goes beyond preserving the ability to maintain safe-shutdown in the event of a fire. GDC 3 states in part, that "fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety."
Furthermore, the general requirements provided in GDC 3 to "minimize the adverse effects of fires on SSCs important to safety" are stated to provide a general level of protection which is afforded to all systems, not only where required to prevent a loss of safe-shutdown capability.
Section 50.48(a) of 10 CFR states that "each operating nuclear power plant must have a fire protection plan that satisfies Criterion 3 of Appendix A of this part." The term "important to safety" encompasses a broader scope of equipment than safety-related and safe-shutdown equipment. Though there is a focus on the protection of safety-related equipment or safe-shutdown equipment, this does not imply that there is an exclusion of any equipment which protects nonsafety-related equipment. For example, in accordance with 10 CFR 50.48, some portions of suppression systems may be required in plant areas where a fire could result in the release of radioactive materials to the environment, even if no safety-related or safe-shutdown equipment is located in that particular fire area.
Based on the preceding discussion in RAI 2.3.3.31-3, the staff finds the foam fire suppression system and its associated components are not credited for compliance with 10 CFR 50.48 and GDC3. This system is for property protection and for loss prevention. Therefore, the staffs concern described in 2.3.3.31-5 is resolved.
In RAI 2.3.3.31-6 dated August 7, 2007, the staff stated that the LRA Table 2.3.3-27 excludes several types of fire protection components that appear in the SER and/or FSAR, and which are also highlighted in the LRA drawings. These components are listed below:
* yard fire hydrants
* interior hose standpipe
* hose connections and racks
* manual hose stations
* pipe fittings
* pipe supports
* couplings
* threaded connections
* restricting orifices
* interface flanges
* chamber housings
* heat-actuated devices
* gauge snubbers
* tank heaters
* Halon 1301 storage cylinders 2-120
* thermowells
* water motor alarms
* expansion joint
* filter housing
* gear box housing
* heat exchangers (bonnet)
* heat exchangers (shell)
* heat exchangers (tube)
* heater housing
* diesel driven fire pump engine's muffler
* diesel driven fire pump engine's intake and exhaust silencers
* orifices
* sight glass
* strainer housing
* turbocharger housing
* flexible hose
* latch door pull box
* pneumatic actuators
* actuator housing
* dikes (contain oil spill)
* storage tanks for fire water system
* buried underground fuel oil tanks
* expansion tank
* jacket cooling water keepwarm pump and heater
* lubricating oil collection system components for reactor coolant pump
* lubricating oil cooler
* auxiliary lubricating oil makeup tank
* rocker lubricating oil pump
* flame retardant coating for cables
* fire barrier penetration seals
* fire barrier walls, ceilings, floor, and slabs
* fire doors
* fire rated enclosures
* fire retardant coating for structural steel supporting wall and ceiling For each, the staff requested that the applicant determine whether the component should be included in LRA Table 2.3.3.27, and if not, the staff requested that the applicant provide justification for the exclusion.
In its response dated September 5, 2007, the applicant stated that LRA Section 2.3.3.31 describes the fire protection system. LRA Section 2.3.3 provides the scoping and screening results for mechanical systems designated as auxiliary systems. LRA Table 2.3.3-27 lists the passive mechanical components/commodities that require an AMR. LRA Table 2.3.3-27 does not include mechanical components that do not require an AMR, and it does not include civil or electrical components/commodities. Civil and electrical scoping and screening results are in LRA Sections 2.4 and 2.5.
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As described in the LRA Section 2.3.3.31:
The Fire Detection System is an electrical system. Scoping and screening of electrical systems are discussed in Section 2.5. Fire barriers are addressed as civil commodities within the associated structure. Scoping and screening of structures is discussed in Section 2.4.
Components and/or subcomponents, such as fire rated doors, penetrations, other fire barriers (e.g., walls, floors, and ceilings), fire rated enclosures, spray-on fire proofing coating, cable enclosures, and fire breaks are addressed as civil commodities. They are included in the structures that are within the scope of license renewal and have a fire protection structure intended function.
As noted in LRA Section 2.5:
The screening for electrical/instrumentation & control (I&C) components was performed on a generic component (commodity group) basis for the in-scope electrical/I&C systems listed in Table 2.2-3, as well as the electrical/I&C component types associated with in-scope mechanical systems and civil structures listed in Tables 2.2-1 and 2.2-2.
Therefore, electrical/I&C type components are not included in LRA Table 2.3.3-27.
The component/subcomponent column in the table below addresses the items listed in this RAI.
The column on the right either identifies the corresponding component/commodity that includes the component or subcomponent or justifies why it is not subject to an AMR.
Table 2.3.3.31-6 Component/Commodity Justification for Exclusion Component/          Included with the following Component/Commodity or Justification for Exclusion Subcomponent yard fire hydrants        Included in buried piping, piping components, and piping elements interior hose standpipe  Included in piping, piping components, and piping elements hose connections and      Hose connections are included in piping, piping components, and piping elements.
racks                    Racks are not included in Table 2.3.3-27; refer to Fire Hose Stations which are a Civil Commodity included in various structures that house them manual hose stations      Not included in Table 2.3.3-27. Refer to Fire Hose Stations which are a Civil Commodity included in various structures that house them. See Response to RAI 2.3.3.31-1 in applicants letter to NRC (Serial: HNP-07-032), dated March 23, 2007 pipe fittings            Included in buried piping, piping components, and piping elements and included in piping, piping components, and piping elements pipe supports            Not included in Table 2.3.3-27. Refer to Anchor/Embedment and Supports for Non-ASME Piping & Components which are Civil Commodities included in various structures that house them couplings                Included in piping, piping components, and piping elements 2-122
 
Component/      Included with the following Component/Commodity or Justification for Exclusion Subcomponent threaded connections    Threaded connections are considered part of the associated Component/Commodity piping, piping components, and piping elements restricting orifices    Not included in Table 2.3.3-27; there were no restricting orifices identified in the system interface flanges      Considered part of the associated buried piping, piping components, and piping elements and piping, piping components, and piping elements chamber housings        Included in piping, piping components, and piping elements heat-actuated devices  Not included in Table 2.3.3-27; heat-actuated electrical devices do not require an AMR as they are active devices. Fire detection components that are used to detect fires; actuate fire suppression systems; monitor the operating status of fire suppression system components; annunciate fire, operation, trouble, and actuation signals; actuate local and general fire alarms; identify the location of fires; and maintain a record of fire related events are part of the Fire Detection System. This system is an electrical system per LRA Table 2.2-3 License Renewal Scoping Results For Electrical/I&C Systems (LRA Page 2.2-11). Damper fusible links do not require an AMR. A fusible link is part of the damper actuating mechanism. Heat changes its properties, and it changes configuration to permit operation of the damper. Therefore, it is considered an active subcomponent. Heat from a fire will cause individual sprinkler heads to fuse, allowing water flow from the sprinkler heads. These heat-actuated devices are considered active subcomponents; because, as heat changes their properties, they change configuration to operate and perform their intended function.
gauge snubbers          Not included in Table 2.3.3-27. There were no gauge snubbers identified in the system.
tank heaters            Not included in Table 2.3.3-27. There were no tank heaters identified in the system.
Halon 1301 storage      Not included in Table 2.3.3-27. As described in LRA Section B.2.14, the fixed cylinders              Halon 1301 system does not support a license renewal intended function and is not subject to an AMR. Portable storage cylinders are replaced on condition by the Fire Protection Program activities and are therefore short-lived and not subject to an AMR.
thermowells            Not included in Table 2.3.3-27. There were no thermowells identified in the system.
water motor alarms      Included in piping, piping components, and piping elements expansion joint        Not included in Table 2.3.3-27. There was no expansion joint identified in the diesel engine exhaust system.
filter housing          Included in filters gear box housing        Included in Heat Exchanger Components. The angle gear box housing between the Diesel-Driven Fire Pump engine and pump shaft also contains cooling coils. Therefore the gear box housing was considered part of the Heat Exchanger Components.
heat exchangers        Included in Heat Exchanger Components (bonnet) heat exchangers (shell) Included in Heat Exchanger Components heat exchangers (tube)  Included in Heat exchanger tubes for the Heat Transfer Function, and included in Heat Exchanger Components for the Pressure Boundary function heater housing          Included in piping, piping components, and piping elements 2-123
 
Component/          Included with the following Component/Commodity or Justification for Exclusion Subcomponent diesel driven fire pump    Included in Diesel Exhaust Silencers engine's muffler diesel driven fire pump    Included in Diesel Exhaust Silencers. This small diesel engine does not have an intake engine's intake and        silencer.
exhaust silencers orifices                  Not included in Table 2.3.3-27. There were no orifices identified in the system.
sight glass                Included in Heat Exchanger Components, or included in a larger component and identified as part of the AMR evaluation. See Plant-Specific Note 355 in LRA Table 3.3.2-27.
strainer housing          Included in system strainers turbocharger housing      Not included in Table 2.3.3-27. In the case of this small diesel engine, HNP methodology considers this part of a complex assembly; and, therefore, it is considered active. See LRA Section 2.1.2.1, Page 2.1-21, item 2, for a discussion regarding complex assemblies.
flexible hose              Included in piping, piping components, and piping elements latch door pull box        Not included in Table 2.3.3-27. This is a Civil Commodity included in Racks, Panels, Cabinets, and Enclosures for Electrical Equipment and Instrumentation (includes support members, welds, bolted connections, support anchorage to building structure).
pneumatic actuators        Not included in Table 2.3.3-27. The HNP methodology considers this an active component.
actuator housing          Not included in Table 2.3.3-27. The HNP methodology considers Actuators in their entirety as part of the active component.
dikes                      Not included in Table 2.3.3-27. These are a Civil Commodity included in Concrete:
(contain oil spill)        Exterior Above Grade and Concrete: Exterior Below Grade in various structures that house them. See response to RAI 2.3.3.31-1 in applicants letter to NRC (Serial: HNP-07-032), dated March 23, 2007.
storage tanks for fire    Not included in Table 2.3.3-27. HNP uses the Auxiliary Reservoir as the Fire Water water system              Supply. The fire water pumps are located at the Emergency Service Water Screening Structure.
buried underground        Not included in Table 2.3.3-27. There are no buried underground fuel oil tanks in the fuel oil tanks            Site Fire Protection System. The Diesel-Driven Fire Pump Fuel Oil Storage Tank is an elevated saddle tank.
expansion tank            Included in piping, piping components, and piping elements. The small jacket water coolant container is treated as part of the miscellaneous piping associated with Diesel-Driven Fire Pump Engine auxiliaries.
jacket cooling water      A keepwarm pump is not included in Table 2.3.3-27. There is no keepwarm pump for keepwarm pump and          this diesel. The electric heater housing is part of the commodity piping, piping heater                    components, and piping elements.
lubricating oil collection Not included in LRA Table 2.3.3-27. These lubricating oil collection system system components for      components are included in the Reactor Coolant Pump and Motor System and not the reactor coolant pump      Fire Protection System. See LRA Table 2.3.1-4 (Page 2.3-18).
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Component/        Included with the following Component/Commodity or Justification for Exclusion Subcomponent lubricating oil cooler    Not included in Table 2.3.3-27. For the diesel-driven fire pump, the lubricating oil cooler is bolted to the engine block and is treated as part of the diesel engine complex assembly. See LRA Section 2.1.2.1, Page 2.1-21, item 2, for a discussion regarding complex assemblies. The approach to the diesel-driven fire pump engine is supported by the GALL Report. There is no listing in GALL Report, Volume 2, Section VII.G, Fire Protection, that suggests that the diesel-driven fire pump lube oil cooler requires aging management.
auxiliary lubricating oil Not included in Table 2.3.3-27. There is no auxiliary lubricating oil makeup tank for this makeup tank              small diesel engine.
rocker lubricating oil    Not included in Table 2.3.3-27. The oil pump is part of the diesel engine complex pump                      assembly.
flame retardant coating  Not included in Table 2.3.3-27. There are no sprayed on flame retardant cable for cables                coatings used at HNP. See the response to RAI 2.3.3.31-1 in applicants letter to NRC (Serial: HNP-07-032), dated March 23, 2007, under Fire Proofing fire barrier penetration  Not included in Table 2.3.3-27. See the response to RAI 2.3.3.31-2 in applicants letter seals                    to NRC (Serial: HNP-07-032), dated March 23, 2007 fire barrier walls,      Not included in Table 2.3.3-27. These are Civil commodities included in the structure ceilings, floor, and      that houses them. See the corresponding civil commodities in response to slabs                    RAI 2.3.3.31-2 in applicants letter to NRC (Serial: HNP-07-032), dated March 23, 2007 fire doors                Not included in Table 2.3.3-27. See the response to RAI 2.3.3.31-2 in applicants letter to NRC (Serial: HNP-07-032), dated March 23, 2007.
fire rated enclosures    Not included in Table 2.3.3-27. These are civil commodities included in Fire Rated Assemblies in the structures that house them.
fire retardant coating    Not included in Table 2.3.3-27. See the civil commodity Fire Rated Assemblies in for structural steel      response to RAI 2.3.3.31-1 in applicants letter to NRC (Serial: HNP-07-032), dated supporting wall and      March 23, 2007 ceiling Based on its review, the staff finds the applicant's response to RAI 2.3.3.31-6 acceptable.
Although the applicant states that they consider some components to be included in other line items, the descriptions of the line items in the LRA do not actually list all these components specifically. Further, the applicant has committed to interpret some components (e.g., racks, manual hose stations, latch door pull box, dikes (contain oil spill), expansion tank, fire rated enclosures, and fire retardant coating for structural steel supporting wall and ceiling) as being included in the civil commodity type. The applicant has included the following items within the scope of license renewal and subject to an AMR because of their intended functions as part of the pressure boundary: yard fire hydrants, interior hose standpipe, pipe fittings, pipe supports, couplings, threaded connections, interface flanges, chamber housings, water motor alarms, filter housing, gear box housing, heat exchanger (bonnet), heat exchange (shell), heat exchange (tube), heater housing, diesel driven fire pump engine's muffler, diesel driven fire pump engine's intake and exhaust silencers, sight glass, strainer housing, fire barrier penetration seals, fire barrier walls, ceilings, floor, and slab, and fire doors. Because the applicant committed to treat these components as included in the line items specified, the staff is adequately assured that these components will be considered appropriately during plant aging management activities. For each of the following components, the staff found that they 2-125
 
were not included in the line item descriptions in the LRA: heat-actuated devices, Halon 1301 storage cylinders, pneumatic actuators, and actuator housing. The staff recognizes that the applicant's treatment of these components as active will result in more vigorous oversight of their condition and performance. The staff concludes that the above components were excluded correctly from the scope of license renewal and are not subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.31-6 is resolved.
2.3.3.31.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the fire protection system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.32 Storm Drains System 2.3.3.32.1 Summary of Technical Information in the Application LRA Section 2.3.3.32 describes the storm drains system, which removes grade elevation run-off and routes it to plant waterways. One function of the storm drains system is to dispose of water run-off from all areas of the plant. The water is collected in local catch basins, gravity-drained through concrete piping, and released through drop structures into the following plant waterways: CTMU water intake channel, ESW intake channel, ESW discharge channel, and the main reservoir. Sumps are located in low elevation areas where gravity draining is impossible. Sump pumps are then used to pump the water up to the storm drain piping and eventually the plant waterways.
The failure of nonsafety-related SSCs in the storm drains system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-28 identifies storm drains system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the storm drains system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.32.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.32 and FSAR Sections 3.4.1.1 and 9.3.3.2.2.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
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During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.32.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the storm drains system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.33 Oily Drains System 2.3.3.33.1 Summary of Technical Information in the Application LRA Section 2.3.3.33 describes the oily drains system, which brings inputs to the oily waste collection and separation system from the following locations:
* diesel fuel oil storage tank building sump
* diesel fuel oil unloading area sump
* diesel generator building sumps The major system components of the oily drains system are the diesel fuel oil storage tank building sump pumps, the diesel fuel oil unloading area sump pump, and the EDG building sump pumps. Portions of the system piping near the diesel fuel oil storage tank building and the diesel fuel oil unloading area are buried.
The failure of nonsafety-related SSCs in the oily drains system potentially could prevent the satisfactory accomplishment of a safety-related function. The oily drains system also performs functions that support fire protection.
LRA Table 2.3.3-29 identifies oily drains system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements
* system strainers 2-127
 
The intended functions of the oily drains system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.33.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.33 and FSAR Sections 9.3.3.2.2.4 and 9.3.3.2.2.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.33.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the oily drains system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.34 Radioactive Floor Drains System 2.3.3.34.1 Summary of Technical Information in the Application LRA Section 2.3.3.34 describes the radioactive floor drains system, one of the radioactive drainage systems between reactor auxiliary equipment and waste processing treatment facilities for drainage of equipment, tanks, and wetted surfaces during normal plant operation.
The radioactive floor drain system collects and processes water from the floor drains in the RAB, FHB, WPB, tank area/building, and portions of the hot machine shop. The radioactive floor drain system uses floor drains and sumps to collect potentially radioactive drainage, including water for fire fighting, then pumps the wastewater to floor drain tanks for treatment by the modular fluidized transfer demineralizer system. The water then is sampled and reused or discharged to the environment via the cooling tower blowdown line.
In the WPB, drainage from expected nonradioactive areas is collected by the building sanitary drainage system and discharged to the site sanitary drainage system. Drainage from radioactive areas is collected by the radioactive floor drains system and discharged to the floor drains tanks.
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The failure of nonsafety-related SSCs in the radioactive floor drains system potentially could prevent the satisfactory accomplishment of a safety-related function. The radioactive floor drains system also performs functions that support fire protection.
LRA Table 2.3.3-30 identifies radioactive floor drains system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements
* system strainers
* tanks The intended functions of the radioactive floor drains system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.34.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.34 and FSAR Sections 9.3.3.2.1 and 9.3.3.2.2.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.34 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.34-1 dated August 20, 2007, the staff noted that, in LRA Section 2.3.3.34, the applicant has included "system strainers" as a component/commodity type in LRA Tables 2.3.3-30 and 3.3.2-30. This component has intended functions of filtration and pressure boundary. On license renewal scoping drawings 5-G-0816-LR at location F-3, and 5-G-0866-LR at locations F-2, 4 and 6, pump strainers were found, however these strainers are not highlighted on the drawings as being within the scope of license renewal. Additionally, if these strainers as indicated in LRA Tables 2.3.3-30 and 3.3.2-30 have a pressure boundary intended function, the surrounding piping would also need to also have a pressure boundary function.
The staff requested that the applicant clarify if these strainers and the surrounding piping are the specified components indicated in LRA Tables 2.3.3-30 and 3.3.2-30 that are subject to an AMR or justify their exclusion.
In its response dated September 18, 2007, the applicant stated that in-line pump strainers and the surrounding piping identified on license renewal scoping drawings 5-G-0816-LR at 2-129
 
location F-3, and 5-G-0866-LR at locations F-2, 4, and 6 are not the system strainers indicated in LRA Tables 2.3.3-30 and 3.3.2-30 that are subject to an AMR. Radioactive floor drains system strainers identified in LRA Section 2.3.3.34, LRA Table 2.3.3-30, and LRA Table 3.3.2-30 include strainers such as: a) in-line pump strainers depicted on 5-G-0816-LR at locations K-11, 14 with a pressure boundary required intended function, b) sump pump integral strainers depicted on 5-G-0187-LR at locations L-10, 15 with both a pressure boundary and filtration required intended function, and c) sump pump integral strainers depicted on 5-G-0184-LR at locations I-16, 18 with both pressure boundary and filtration required intended functions. The referenced sump pumps are mounted vertically with the strainer attached to the bottom of the pump volute.
Based on the above discussion, the staff finds the applicant's response to RAI 2.3.3.34-1 acceptable because the applicant specifically identified the system strainers subject to an AMR that were referenced in LRA Tables 2.3.3-30 and 3.3.2-30. Therefore, the staff's concern described in RAI 2.3.3.34-1 is resolved.
2.3.3.34.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the radioactive floor drains system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.35 Radioactive Equipment Drains System 2.3.3.35.1 Summary of Technical Information in the Application LRA Section 2.3.3.35 describes the radioactive equipment drains system, one of the radioactive drainage systems between reactor auxiliary equipment and waste processing treatment facilities for drainage of equipment, tanks, and wetted surfaces during normal plant operation.
The radioactive equipment drains system collects and transfers reactor grade water from equipment leaks and drains, valve leakoffs, pump seal leakoffs, tank overflows, and tritiated water sources to the waste holdup tank.
The radioactive equipment drains system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the radioactive equipment drains system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the radioactive equipment drains system performs functions that support fire protection, SBO, and EQ.
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LRA Table 2.3.3-31 identifies radioactive equipment drains system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, piping elements and tanks
* reactor coolant drain tank heat exchanger components
* reactor coolant drain tank heat exchanger tubes
* system strainers The intended functions of the radioactive equipment drains system component types within the scope of license renewal include:
* filtration
* heat transfer
* pressure-retaining boundary 2.3.3.35.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.35 and FSAR Sections 9.3.3.2.1 and 9.3.3.2.2.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.35.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the radioactive equipment drains system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.36 Secondary Waste System 2.3.3.36.1 Summary of Technical Information in the Application LRA Section 2.3.3.36 describes the secondary waste system, which drains high- and low-conductivity wastes generated by secondary steam and condensate, condensate polisher regeneration, steam generator blowdown electromagnetic filter back flush equipment, miscellaneous leak-off points, and certain floor drainage in the turbine building and FHB. HVAC 2-131
 
condensate drains are also parts of this system. Secondary waste drains are located in their respective buildings near equipment requiring them. In general, drainage to the secondary waste drains is confined to water from the turbine building containing oil, acid, or both and caustic and water from the FHB. After treatment and sampling for acceptable purity, water may be released to the environment. A portion of the piping routed to the oil-water separator is buried.
The failure of nonsafety-related SSCs in the secondary waste system potentially could prevent the satisfactory accomplishment of a safety-related function. The secondary waste system also performs functions that support fire protection.
LRA Table 2.3.3-32 identifies secondary waste system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, piping elements, and tanks The intended function of the secondary waste system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.36.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.36 and FSAR Section 9.3.3.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.36.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the secondary waste system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.37 Laundry and Hot Shower System 2.3.3.37.1 Summary of Technical Information in the Application LRA Section 2.3.3.37 describes the laundry and hot shower system, a liquid waste processing system subsystem that collects, stores, and processes potentially radioactive liquid wastes from 2-132
 
detergent, hot shower, decontamination drains, and various sumps. The laundry and hot shower system receives inputs from the WPB detergent drain sump, RAB detergent drain sump, FHB detergent drain sump, FHB decontamination receiving and transfer tank, and gravity detergent drains, chemical drains, fuel cask wash, and fuel pool drains; however, as laundry is sent offsite for processing, there are no laundry wastes. The system is designed to process accumulated liquids by filtration, reverse osmosis, evaporation, and ion exchange to meet water quality requirements. The system transfers the processed water to the treated laundry and hot shower tanks where it is mixed and sampled.
LRA Table 2.3.3-33 identifies laundry and hot shower system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* FHB decontamination receiving and transfer tank
* FHB decontamination transfer pumps
* FHB detergent drain sump pumps
* piping, piping components, and piping elements
* RAB detergent drain sump pumps
* system strainers
* WPB laundry and hot shower tanks The intended functions of the laundry and hot shower system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.37.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.37 and FSAR Section 11.2.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.37.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the laundry and hot shower system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.38 Upflow Filter System 2.3.3.38.1 Summary of Technical Information in the Application LRA Section 2.3.3.38 describes the upflow filter system, formerly a subsystem of the primary filtered makeup water system designed to provide treated water for the potable and sanitary water and demineralized water systems; however, the upflow filter system components in the water treatment building have been abandoned in place. The modified primary filtered makeup system consists of a microfiltration system followed by a nanofiltration system, both skid-mounted and located in the water treatment building with redundant filtration flowpaths for treated water to the potable water and the demineralized water systems.
The failure of nonsafety-related SSCs in the upflow filter system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-34 identifies upflow filter system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the upflow filter system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.38.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.38 and FSAR Section 9.2.3.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.38.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the upflow filter system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.39 Potable and Sanitary Water System 2-134
 
2.3.3.39.1 Summary of Technical Information in the Application LRA Section 2.3.3.39 describes the potable and sanitary water system, which provides the plant and the Harris Energy and Environmental Center both hot and cold water at required pressures, flow rates, and temperature for human consumption and for the operation of all sanitary plumbing fixtures and selected equipment. The system is not cross-connected to any fixture or equipment with potentially radioactive material. The boundary between the potable and sanitary water system and the diesel generator cooling water system is at safety-related check valves of the diesel generator cooling water system. When required, a temporary hose from the nonsafety-related piping in the potable and sanitary water system fills the diesel generator standpipes.
As an alternate supply of cooling water for the NSW pump seals and bearings the potable and sanitary water system has piping and check valves that form a pressure boundary with the NSW system booster pump discharge piping.
The failure of nonsafety-related SSCs in the potable and sanitary water system potentially could prevent the satisfactory accomplishment of a safety-related function. The potable and sanitary water system also performs functions that support fire protection.
LRA Table 2.3.3-35 identifies potable and sanitary water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the potable and sanitary water system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.39.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.39 and FSAR Section 9.2.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.39.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the potable and sanitary water system components within the scope of license renewal, as required 2-135
 
by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.40 Demineralized Water System 2.3.3.40.1 Summary of Technical Information in the Application LRA Section 2.3.3.40 describes the demineralized water system, which supplies water of specified quality sufficient for the anticipated makeup demands of various systems, including the RCS, and demands for plant startup and operation with allowance for regeneration of the demineralizers and a normal amount of downtime for maintenance. The demineralized water system is designed to supply demineralized water to the 500,000-gallon demineralized water storage tank. One of two demineralized water transfer pumps operates continuously and distributes water to the following:
* reactor makeup water storage tank
* CST
* refueling water storage tank
* miscellaneous users The demineralized water system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the demineralized water system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the demineralized water system performs functions that support SBO.
LRA Table 2.3.3-36 identifies demineralized water system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the demineralized water system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.40.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.40 and FSAR Section 9.2.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.40.3 Conclusion 2-136
 
The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the demineralized water system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.41 Filter Backwash System 2.3.3.41.1 Summary of Technical Information in the Application LRA Section 2.3.3.41 describes the filter backwash system, a liquid waste processing system subsystem which backflushes designated flushable filters of the following systems to collect, store, and transfer filtered sludge and particulates to the solid waste processing system via the filter particulate concentrates tank:
* liquid waste processing system
* secondary waste treatment system
* CVCS
* boron recycle system
* spent fuel pool cooling
* spent fuel pool cleanup system Filtered waste goes to the respective filter backflush transfer tanks. The filter backwash transfer tank pumps transfer the filter sludge to the backwash storage tank in the WPB and recycle the sludge through the backwash storage tank filters. After filtering, the liquid goes to the waste hold-up tanks for further processing. The sludge from the filters is pumped to the filter particulate concentrates tank, which has pumps that route its contents to either the solidification system or the spent resin storage tanks.
LRA Table 2.3.3-37 identifies filter backwash system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the filter backwash system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.41.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.41 and FSAR Section 11.2.2.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those 2-137
 
components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.41.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the filter backwash system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.42 Radiation Monitoring System 2.3.3.42.1 Summary of Technical Information in the Application LRA Section 2.3.3.42 describes the radiation monitoring system, which consists of the process and effluent radiological monitoring and sampling systems and the area and airborne radioactivity monitoring systems. The major function of the radiation monitoring system is to provide plant operations and health physics personnel with both current and historical measurements of radiological conditions in certain areas and plant systems during both normal and design-basis conditions. In addition, this system automatically warns plant personnel by alarms and in certain cases acts to control unusual radiological conditions or equipment malfunctions. The radiation monitoring system has nonsafety-related and safety-related portions.
The radiation monitoring system consists of the following:
* area radiation monitoring system
* airborne radiation monitoring system
* process radiological monitoring system
* effluent radiological monitoring system
* process and effluent radiological sampling system The normal functions of the area radiation monitoring system are to provide local and remote indication and alarms of ambient gamma radiation in general plant areas; to furnish records, including radiation survey information, of radiation levels in specific plant areas; and to warn of uncontrolled or inadvertent movement of radioactive material in the plant. The functions of the area radiation monitoring system during postulated accidents are to signal to isolate the containment in a LOCA or for abnormally high radiation inside the containment, to monitor post-LOCA long-term conditions inside the containment and in vital access areas outside containment, and to signal to isolate the FHB and start the emergency ventilation system in a fuel-handling accident.
The normal functions of the airborne radiation monitoring system are to inform operations personnel and furnish records of airborne particulate, iodine, and gaseous activity trends in the 2-138
 
various plant structures; to help detect leaks from the reactor coolant pressure boundary (as recommended in RG 1.45) and other areas of the plant; and to provide information for evaluation of the performance of plant systems that function to minimize the release of airborne radioactivity and for maintenance of low radiation exposure for plant personnel via inhalation of airborne particulates and iodine, in accordance with 10 CFR Part 20. The functions of the airborne radiation monitoring system during postulated accidents are to indicate particulate and gaseous radioactivity levels inside the containment; to signal to close the normal control room outside air intake valves, stop the exhaust fans, close the exhaust dampers, start up the emergency filtration fans, and put the air flow into the recirculation mode; and to indicate radioactivity levels at each emergency air intake to allow the operator to choose which emergency intake to open.
The process radiological monitoring system, supplemented by the process sampling system (i.e., the primary sampling and secondary sampling systems and the PASS), is designed to provide radiological information for system operation and early detection of radioactivity leakage into normally nonradioactive systems. The system has safety-related components that monitor CCW system radioactivity levels to detect leakage into the system from equipment that may contain radioactivity.
The normal functions of the effluent radiological monitoring system are representative sampling, monitoring, storage of information, indication, and, if necessary, alarm on liquid and gaseous radioactivity levels in plant effluents; automatic closure of the waste discharge valves before effluent release limits are approached or exceeded; and detection of noncondensable fission product gases for redirection to high-efficiency particulate air (HEPA) and charcoal filters before release to the environment.
The radiation monitoring system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the radiation monitoring system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the radiation monitoring system performs functions that support fire protection and EQ.
LRA Table 2.3.3-38 identifies radiation monitoring system component types within the scope of license renewal and subject to an AMR:
* containment isolation piping and components
* flow straighteners
* piping, piping components, and piping elements The intended function of the radiation monitoring system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.42.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.42 and FSAR Section 12.3.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with 2-139
 
intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.42.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the radiation monitoring system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.43 Oily Waste Collection and Separation System 2.3.3.43.1 Summary of Technical Information in the Application LRA Section 2.3.3.43 describes the oily waste collection and separation system designed to collect nonradioactive oily water generated during normal plant operation or during fire fighting with hoses or sprinklers. This system receives water from plant areas that could contain oil or oily solid contaminants, separates the water from any oil or oily solid contaminants, and discharges it to the waste neutralization basin to remove any residual hydrazine and to adjust pH. Oil wastes are drummed for offsite shipment.
The oily waste collection and separation system receives water from the following locations:
* auxiliary boiler fuel oil diked area sump
* auxiliary boiler fuel oil unloading area sump
* diesel fuel oil storage tank building sump
* diesel fuel oil storage unloading area sump
* diesel generator building sumps
* turbine building condensate pump area sump
* security building oil sump
* turbine building industrial waste sumps
* paint shop and storage building sump In the diesel fuel oil storage tank building, the floor drain system collects drainage from fire-fighting water flow and routes it to the building sumps. The sump pumps discharge the water to the yard oil separator, which pumps its contents to the waste neutralization system.
Major system components include the following:
* oil-water separator and holding tanks
* water transfer pumps
* oil transfer pumps
* sludge transfer pumps
* sludge bin 2-140
* sump pumps in the areas where oily water is collected The failure of nonsafety-related SSCs in the oily waste collection and separation system potentially could prevent the satisfactory accomplishment of a safety-related function. The oily waste collection and separation system also performs functions that support fire protection.
LRA Table 2.3.3-39 identifies oily waste collection and separation system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, piping elements, and tanks The intended function of the oily waste collection and separation system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.43.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.43 and FSAR Sections 9.3.3.2.2.4, 9.3.3.2.2.5, and 9.3.3.2.2.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.43 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.43-1 dated August 20, 2007, the staff noted that, on the license renewal scoping drawing titled "Scoping Notes for Miscellaneous Systems," also known as "System Boundary Drawing Scoping Discussions," Attachment 4, Revision 2, the applicant states that highlighted flow paths in the "Oily Drains System" are intended to indicate flow paths for draining fire fighting water when needed. However, on license renewal scoping drawing 5-G-0485-LR, the applicant does not highlight portions of the system downstream of the oil water separator. The staff asked the applicant to explain why the piping downstream of the oil water separator is not within the scope of license renewal to support the intended function of draining fire fighting water. The staff asked the applicant to justify the exclusion of the cited piping from within the scope of license renewal, or include the piping downstream of the oil water separator necessary to support the fire protection intended function within the scope of license renewal.
In its response dated September 18, 2007, the applicant stated that the piping downstream of the oil water separator is not needed to support the intended function of draining fire fighting water. The applicant stated that the floor drains on license renewal scoping drawings 5-G-133-LR, for the diesel generator building floor drains, and 5-G-485-LR for the diesel fuel oil storage tank building floor drains at location H-12, are designed to accommodate 2-141
 
any water discharged from fire suppression equipment and prevent damage to safety-related equipment.
The HNP methodology treats the piping downstream of the oil water separator as an interfacing system that is secondary to the portion of the system that supports the fire protection intended function. This downstream interfacing system does not need to be included within the scope of license renewal based on considerations described in NEI 95-10. As discussed in NEI 95-10, Section 3.1.3, in regards to SSCs relied on to demonstrate compliance with certain specific commission regulations:
Mere mention of a system, structure or component in the analysis or evaluation does not constitute support of a specified regulatory function. An applicant should rely on the plant's CLB, plant-specific experience, industry wide operating experience, as appropriate and existing plant-specific engineering evaluations to determine the appropriate systems, structures and components in this category.
Consideration of hypothetical failures that could result from system interdependencies that are not part of the plant's CLB and that have not been previously experienced is not required.
Based on the above discussion, the staff finds the applicant's response to RAI 2.3.3.43-1 acceptable because the applicant adequately explained why the piping downstream of the oil water separator is not needed to support the intended function of draining fire fighting water.
This function is met by the floor drains in the diesel generator building and diesel fuel oil storage tank building, which are within the scope of license renewal. Therefore, the staff's concern described in RAI 2.3.3.43-1 is resolved.
2.3.3.43.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the oily waste collection and separation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.44 Liquid Waste Processing System 2.3.3.44.1 Summary of Technical Information in the Application LRA Section 2.3.3.44 describes the liquid waste processing system, which collects, stores, processes, and controls release of radioactive and potentially radioactive liquids in the operation of the nuclear power plant. The discharge of treated wastes is controlled and monitored to ensure that any discharges are as low as reasonably achievable. The liquid waste processing system is designed to collect and process all primary plant radioactive waste water to reduce its radionuclide concentration to permit its discharge to the environs. In addition, the liquid waste processing system is designed to treat occasional batches of secondary liquids if 2-142
 
primary to secondary leakage occurs. The system has six subsystems:
* equipment drain treatment system
* floor drain treatment system
* laundry and hot shower treatment system
* chemical drains system
* filter backwash system
* secondary waste treatment system These subsystems segregate the various types of liquid radwaste according to their sources because of their composition and process requirements. Waste input to the floor drain treatment system, laundry and hot shower system, and the chemical drain system have not differed so much that separate processing trains have been necessary. These wastes are processed by the modular fluidized transfer demineralization system, which is designed to reduce the radionuclide concentrations in the station effluents but not to produce reactor coolant quality water from the liquid radwaste.
The liquid waste processing system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the liquid waste processing system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the liquid waste processing system performs functions that support fire protection.
LRA Table 2.3.3-40 identifies liquid waste processing system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* liquid waste holdup tank
* piping, piping components, and piping elements The intended function of the liquid waste processing system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.44.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.44 and FSAR Section 11.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.3.44.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the liquid waste processing system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.45 Secondary Waste Treatment System 2.3.3.45.1 Summary of Technical Information in the Application LRA Section 2.3.3.45 describes the secondary waste treatment system, which collects, stores, and processes the following potentially radioactive wastes:
* low-conductivity wastes from condensate polisher rinsing, steam generator blowdown, electromagnetic filter backflush, contaminated auxiliary steam condensate, and industrial waste sumps
* high-conductivity wastes from condensate polisher regeneration and the turbine building acid and caustic sumps Secondary waste treatment system components are not safety-related and are not required to operate during design-basis accidents. The secondary waste sample tank releases its content continuously to the A waste neutralization basin, where it is pH neutralized and discharged to the lake through the waste neutralization settling basin to the cooling tower blowdown line.
Major system components are the pH adjusting skid, holding and sample tanks, pumps, filters, piping, and I&Cs.
The failure of nonsafety-related SSCs in the secondary waste treatment system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-41 identifies secondary waste treatment system component types within the scope of license renewal and subject to an AMR:
* closure piping
* piping, piping components, piping elements, and tanks The intended function of the secondary waste treatment system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.45.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.45 and FSAR Section 11.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to 2-144
 
verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.45 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as discussed below.
In RAI 2.3.3.45-1 dated August 20, 2007, the staff noted that in LRA Section 2.3.3.45, the applicant stated that the secondary waste treatment system only performs the system intended function of containing components that have the potential for spatial interactions with safety-related SSCs or are relied on for seismic continuity in accordance with 10 CFR 54.4(a)(2). However, on license renewal scoping drawing titled "Scoping Notes for Miscellaneous Systems," the applicant stated that highlighted flow paths in the "Liquid Waste Processing System" are intended to indicate flow paths for draining fire fighting water when needed. In FSAR Section 11.2.2.6, the applicant described the secondary waste treatment system as a subsystem of the liquid waste processing system. The staff asked the applicant to explain the exclusion of the system intended function associated with fire protection (10 CFR 50.48) for the secondary waste treatment system in accordance with 10 CFR 54.4(a)(3).
In its response dated September 18, 2007, the applicant stated that the HNP license renewal system scoping process is described in LRA Section 2.1. In part, the applicant cited the following on LRA page 2.1-2:
The initial step in the process is to compile a list of SSCs for scoping. Major structures and plant components, such as pumps, valves, tanks, heat exchangers, and instruments at HNP, are assigned unique component numbers that are maintained in a controlled database called the PassPort Equipment Database (PassPort EDB or EDB). Each HNP system is identified in EDB by a unique system number, and each component in a given system is assigned a unique EDB component identification number.
The applicant stated that the secondary waste treatment system has a unique system number assigned to it by the PassPort EDB, which is different than the system number assigned to the liquid waste processing system. Based on this methodology, the secondary waste treatment system is treated as a different system than the liquid waste processing system. License renewal system scoping and identification of system intended functions were performed on each system identified in the EDB with a unique system number. Since the secondary waste treatment system does not process or receive inputs from systems associated with fire protection, the secondary waste treatment system does not have a system intended function associated with fire protection (10 CFR 50.48) in accordance with 10 CFR 54.4(a)(3).
Based on its review and the above discussion, the staff finds the applicant's response to RAI 2.3.3.45-1 acceptable because the applicant explained that the secondary waste treatment system is treated as a different system than the liquid waste processing system in the PassPort EDB, and that the secondary waste treatment system does not process or receive inputs from 2-145
 
systems associated with fire protection. Therefore, the staff's concern described in RAI 2.3.3.45-1 is resolved.
2.3.3.45.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the secondary waste treatment system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.46 Boron Recycle System 2.3.3.46.1 Summary of Technical Information in the Application LRA Section 2.3.3.46 describes the boron recycle system, which receives and recycles reactor coolant effluent to be recycled as boric acid and makeup water for the RCS. The system decontaminates the effluent by demineralization and gas stripping and separates and recovers the boric acid and makeup water by evaporation. The boron recycle system collects and processes effluent which can be reused readily as RCS makeup and, for water management purposes, as makeup to the spent fuel pools. For the most part, this effluent is the deaerated, tritiated, borated, and radioactive water from the CVCS letdown line and process drains. The boron recycle system also collects water from the following sources:
* CVCS letdown line
* reactor coolant drain tank (primarily RCP seal leakage)
* VCT and charging pump suction pressure relief and RHR pumps pressure relief
* boric acid blender
* spent fuel pool pumps
* valve leakoffs and equipment drains
* safety-injection system (flush water)
The evaporator concentrates the boric acid solution until a 4-weight-percent solution is obtained. The accumulated batch is normally transferred directly to the boric acid tanks in the CVCS through the recycle evaporator concentrates filter. Before transfer from the evaporator to the boric acid tank, the boric acid is analyzed and can be diverted back to the recycle holdup tank for reprocessing or to the liquid waste processing system for disposal if it does not meet required chemical standards.
The boron recycle system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the boron recycle system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-42 identifies boron recycle system component types within the scope of license renewal and subject to an AMR:
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* closure bolting
* heat exchanger components
* piping, piping components, and piping elements
* tanks The intended function of the boron recycle system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.46.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.46 and FSAR Section 9.3.4.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.46.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the boron recycle system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.47 Gaseous Waste Processing System 2.3.3.47.1 Summary of Technical Information in the Application LRA Section 2.3.3.47 describes the gaseous waste processing system, which collects, processes, and stores gaseous wastes generated by plant operation including expected startup and maintenance operations. The system processes the influent gases by compressing them with the waste gas compressor followed by hydrogen conversion to water in the catalytic recombiner. Radioactive gases are stored in the gas decay tanks. Water formed or condensed in the system is filtered and returned to the VCT in the CVCS or to the boron recycle system holding tanks. The gaseous waste processing system is designed to receive gaseous inputs from the following sources:
* CVCS VCT purge
* boron recycle system recycle evaporator
* liquid waste processing waste evaporators (acting as recycle evaporators)
* PRT
* reactor coolant drain tank 2-147
* boron recycle system recycle holdup tank
* primary sampling panel The gaseous waste processing system also has sufficient capacity to hold the gases generated during reactor shutdown. Nitrogen gas from previous shutdowns contained in the gas decay tanks strips hydrogen from the RCS during subsequent shutdowns. One gas decay tank normally at low pressure accepts relief valve discharges from the inservice gas decay tank, the hydrogen recombiner, and the waste gas compressors.
The gaseous waste processing system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the gaseous waste processing system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the gaseous waste processing system performs functions that support SBO and EQ.
LRA Table 2.3.3-43 identifies gaseous waste processing system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping insulation
* piping, piping components, piping elements, and tanks The intended functions of the gaseous waste processing system component types within the scope of license renewal include:
* pressure-retaining boundary
* thermal insulation 2.3.3.47.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.47 and FSAR Section 11.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.47.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the gaseous waste processing system components within the scope of license renewal, as required 2-148
 
by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.48 Radwaste Sampling System 2.3.3.48.1 Summary of Technical Information in the Application LRA Section 2.3.3.48 describes the radwaste sampling system, which transports radioactive liquid and gaseous samples from process points in the radiological waste processing systems to sample sinks located in shielded rooms at various places in the WPB and tank area/building to minimize sample tubing runs. Ventilated hoods protect those who obtain samples at each of the sinks. The results of sample analyses aid operators in monitoring radwaste operations, selecting treatment paths, and demonstrating compliance of liquid and gaseous effluents with discharge limitations.
The radwaste sampling system is designed to collect representative samples from process points in the following waste processing systems:
* secondary waste
* filter backwash
* radioactive floor drains
* chemical drain
* spent resin storage and transfer
* solid waste processing (for recirculation loop of pretreatment tanks)
* waste holdup and evaporation
* gaseous waste processing
* laundry and hot shower System sampling is manual with no special instrumentation. The waste processing sampling system has Safety Class 2 valves which isolate it from the RWST; therefore, the system must maintain the RWST pressure boundary.
The radwaste sampling system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the radwaste sampling system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-44 identifies radwaste sampling system component types within the scope of license renewal and subject to an AMR:
* piping, piping components, and piping elements The intended function of the radwaste sampling system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.48.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.48 and FSAR Section 11.5.1.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
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During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.48.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the radwaste sampling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.49 Refueling System 2.3.3.49.1 Summary of Technical Information in the Application LRA Section 2.3.3.49 describes the refueling system, a subset of the fuel handling system. The refueling system equipment consists of:
* manipulator crane
* fuel transfer system
* fuel handling tools and fixtures The bridge and trolley manipulator crane has a vertical mast extending down into the refueling water. The bridge spans the refueling cavity. The bridge and trolley place the vertical mast in position over a fuel assembly in the core. A long tube with a pneumatic gripper on the end lowered out of the mast grips the fuel assembly. The fuel assembly is raised and transported while inside the mast tube to its new position. The fuel transfer system transports fuel assemblies between the FHB and containment through the fuel transfer tube and has an underwater conveyor car on tracks extending from the refueling cavity through the transfer tube and into the fuel transfer canal. When a fuel assembly is removed from the reactor, the upending frame in the refueling cavity receives it in the vertical position from the manipulator crane and lowers it to a horizontal position for passage through the transfer tube. Then, the upending frame in the fuel transfer canal raises it to a vertical position.
The hoist on the spent fuel bridge takes the fuel assembly to a position in the spent fuel racks via the fuel transfer canals. The reactor containment is sealed during unit operation by a double-gasketed blind flange bolted on the end of the transfer tube in the refueling cavity inside containment and a manually-operated valve locked closed in the fuel transfer canal in the FHB.
The blind flange performs the containment isolation function for this penetration. The gaskets are short-lived and replaced whenever the flange is removed. The transfer tube and the blind flange are designed to seismic Category I requirements. The refueling system has tools and fixtures for handling fuel assemblies, rod cluster control assemblies, and other components 2-150
 
during refueling operations.
The refueling system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the refueling system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-45 identifies refueling system component types within the scope of license renewal and subject to an AMR:
* closure piping
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the refueling system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.49.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.49 and FSAR Section 9.1.4.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.49.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the refueling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.50 New Fuel Handling System 2.3.3.50.1 Summary of Technical Information in the Application LRA Section 2.3.3.50 describes the new fuel handling system, a fuel handling system subset that consists of the components that transport, handle, inspect, and store new (unirradiated) fuel assemblies and that maintain fuel assemblies, when stored in either wet or dry condition, in a subcritical nuclear state. The major components of the new fuel handling system consist of:
* dry storage racks located in the new fuel inspection pit to maintain subcriticality 2-151
 
of the new fuel assemblies stored in an air environment
* fuel racks in Spent Fuel Pool A that can store either new or spent fuel and maintain subcriticality of the new fuel assemblies when flooded with unborated water
* the new fuel handling tool that lifts and transfers new fuel assemblies between the shipping containers and the new fuel inspection stand, dry fuel storage rack and the new fuel elevator
* the new fuel elevator that lowers new fuel from the FHB operating deck level down to the bottom of the fuel transfer canal where it can be removed from the elevator by the spent fuel tool and placed in a fuel pool storage rack The new fuel racks, which maintain subcriticality of the fuel, are safety-related because of the structural design of the rack. Boraflex is encapsulated for neutron absorption in the stainless steel walls of each storage cell of the storage racks located in Spent Fuel Pool A.
The failure of nonsafety-related SSCs in the new fuel handling system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.50.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.50 and FSAR Sections 9.1.1 and 9.1.4.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.50.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the new fuel handling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.51 Spent Fuel System 2.3.3.51.1 Summary of Technical Information in the Application LRA Section 2.3.3.51 describes the spent fuel system, a fuel handling system subset that safely and reliably handles and stores and maintains subcriticality of fuel assemblies when stored in the fuel storage racks in the fuel pool. The major components of the spent fuel handling system and their purposes are as follows:
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* spent fuel handling tools safely handle fuel assemblies in the fuel pools and transfer canals. HNP utilizes tools for handling both PWR and boiling-water reactor (BWR) spent fuel
* spent fuel racks are designed to safely store both PWR and BWR spent fuel assemblies. For license renewal, the spent fuel racks are evaluated as civil/structural components within the FHB
* handling tools to safely remove, transfer, and install various fuel inserts in the fuel assemblies (e.g., thimble plug change tool, portable RCCA change tool, burnable poison rod assembly change tool, and trash basket handling tool) in the pools The spent fuel system is designed to minimize the possibility of fuel assembly mishandling, which could cause fuel damage and fission product release. Safety-related components in the spent fuel system are the fuel handling tools and the fuel storage racks. The fuel handling tools handle fuel safely and reliably. The BWR storage racks in Pools A, B, and C and the PWR storage racks in Pools C and D are designed to maintain a subcritical array of keff < 0.95 even if the pools are flooded with unborated water. Soluble boron is credited to maintain keff < 0.95 for the PWR racks in Pools A and B. A neutron-absorbing material is encapsulated into the stainless steel walls of the BWR racks in Pools A, B and C and the PWR racks in Pools C and D. Some fuel racks utilize Boraflex panels as a neutron absorber; others utilize Boral plates. The function of the Boraflex and Boral material is to maintain subcriticality by absorbing neutrons.
The failure of nonsafety-related SSCs in the spent fuel system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.51.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.51 and FSAR Sections 9.1.2 and 9.1.4.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.51.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the spent fuel system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.52 Spent Fuel Pool Cooling System 2.3.3.52.1 Summary of Technical Information in the Application LRA Section 2.3.3.52 describes the spent fuel pool cooling system, a part of the FSAR-described fuel pool cooling and cleanup systems servicing Pools A and B - south end, Pools C and D - north end, and fuel transfer canals. The new fuel pool, Pool A, and the spent fuel pool, Pool B, are connected by the south fuel transfer canal. The cask loading/unloading pool, Pool C, and Pool D are connected by the north fuel transfer canal. The main fuel transfer canal connects the south and north fuel transfer canals. The spent fuel pool cooling system provides safety-related cooling for the new and spent fuel pools, adequate cooling water inventory to support the cooling function, and shielding via the large water inventory. The fuel pools are cooled by two independent cooling loops, either of which can remove the decay heat loads generated. In the event of a single failure in one of the spent fuel cooling system loops, the other loop will provide adequate cooling. System piping removes water from a pool, passes it through a strainer, and pumps it to a heat exchanger for cooling prior to returning the water to the pool.
The FHB fuel pools are not affected by any LOCA in the containment building. The water in the pools is isolated from that in the refueling cavity during most of the refueling operation. Only a very small amount of water interchange occurs as fuel assemblies are transferred during refueling. The fuel pool cooling pump suction line, which can lower the pool water level, penetrates the fuel pool wall approximately 18 ft. above the fuel assemblies. The penetration location precludes uncovering of the fuel assemblies by a postulated suction line rupture. Piping in contact with fuel pool water is austenitic stainless steel welded except where flanged connections facilitate maintenance.
The spent fuel pool cooling system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the spent fuel pool cooling system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-46 identifies spent fuel pool cooling system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* flow-restricting elements
* fuel pool cooling pumps
* fuel pool heat exchanger components
* fuel pool heat exchanger tubes
* piping insulation
* piping, piping components, and piping elements
* system strainers The intended functions of the spent fuel pool cooling system component types within the scope of license renewal include:
* filtration 2-154
* heat transfer
* pressure-retaining boundary
* thermal insulation
* flow regulation 2.3.3.52.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.52 and FSAR Section 9.1.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.52.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the spent fuel pool cooling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.53 Spent Fuel Pool Cleanup System 2.3.3.53.1 Summary of Technical Information in the Application LRA Section 2.3.3.53 describes the spent fuel pool cleanup system, part of the FSAR-described fuel pool cooling and cleanup systems servicing Pools A and B - south end, Pools C and D -
north end, and fuel transfer canals. Gates isolate the pools as necessary. The spent fuel pool cleanup system maintains water inventory as well as water quality and clarity in the fuel pools and refueling cavity by utilizing skimmers, filters, and a demineralizer to remove impurities and suspended solids. Spent fuel pool cleanup system components include demineralizers, filters, skimmers, skimmer pumps, connecting valves, piping, and fuel pool and refueling water purification pumps. The latter pumps can take suction from and return fluid to the RWST via the safety-injection system, transfer canal, fuel pools, or the refueling cavity. Each pump can also take suction from the demineralized water storage tank for makeup to the fuel pools and line flushing. The system has CIVs.
The containment isolation function is required to maintain containment integrity for the purification lines connecting the spent fuel pool cleanup system to the refueling cavity. The vertical steel fuel pool gates on the new fuel pool, spent fuel pools, fuel transfer canals, and cask loading pools allow the spent fuel to be immersed at all times while being moved to its destination, allow each area to be isolated for drainage if necessary, and enable new fuel to be 2-155
 
stored dry in the new fuel pool.
The spent fuel pool cleanup system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the spent fuel pool cleanup system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the spent fuel pool cleanup system performs functions that support SBO.
LRA Table 2.3.3-47 identifies spent fuel pool cleanup system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the spent fuel pool cleanup system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.53.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.53 and FSAR Section 9.1.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.53.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the spent fuel pool cleanup system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.54 Spent Fuel Cask Decontamination and Spray System 2.3.3.54.1 Summary of Technical Information in the Application LRA Section 2.3.3.54 describes the spent fuel cask decontamination and spray system, which consists of a series of spray nozzles located around the periphery of the cask loading pool, a cask stand and cask decontamination enclosure with horizontal and vertical spray nozzles, a decontamination chemical addition tank, and the pumps, valves, and piping necessary to rinse 2-156
 
and wash a spent fuel cask with demineralized water. While the spent fuel cask is lifted out of the cask loading pool, the decontamination rinse pump may be started to deliver demineralized water to the spray nozzles. This rinse removes pool water and prepares the cask for transfer to the cask stand and final decontamination. The cask is washed down by the decontamination wash pump in the cask decontamination enclosure with warm demineralized water and a mild detergent. The cask also can be scrubbed by hand until acceptable decontamination has been achieved. A final rinse of demineralized water is then applied. This system also has an ultrasonic generator, an ultrasonic tank, a rinse tank, and a service sink to clean and decontaminate tools and equipment used in fuel and cask handling.
The failure of nonsafety-related SSCs in the spent fuel cask decontamination and spray system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-48 identifies spent fuel cask decontamination and spray system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the spent fuel cask decontamination and spray system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.54.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.54 and FSAR Section 9.1.4.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.54.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the spent fuel cask decontamination and spray system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.55 Spent Resin Storage and Transfer System 2.3.3.55.1 Summary of Technical Information in the Application 2-157
 
LRA Section 2.3.3.55 describes the spent resin storage and transfer system, which sluices, collects, stores, and then transfers spent resins for dewatering and transport to an offsite disposal facility. The system is designed to receive inputs from the following sources:
* secondary waste demineralizers
* spent fuel pool demineralizers
* recycle evaporator condensate demineralizers
* recycle evaporator feed demineralizers
* boron thermal regeneration demineralizers
* laundry and hot shower demineralizer
* waste monitor tanks demineralizer
* mixed-bed demineralizers (CVCS)
* cation-bed demineralizer (CVCS)
* waste evaporator condensate demineralizer
* filter particulates and resin fines from the filter backwash system
* condensate polishing demineralizers The influent is collected in the two low-activity or two high-activity spent resin storage tanks from which it is pumped to outside contractor liners for processing. The spent resin storage and transfer system is designed to operate as a batch process and provides sufficient holdup capacity for average yearly input to the system. System components include spent resin storage tanks, spent resin sluice pumps, spent resin transfer pumps, spent resin sluice filters, system piping, and instrumentation.
LRA Table 2.3.3-49 identifies spent resin storage and transfer system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the spent resin storage and transfer system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.55.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.55 and FSAR Section 11.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.55.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In 2-158
 
addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the spent resin storage and transfer system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.56 Containment Auxiliary Equipment 2.3.3.56.1 Summary of Technical Information in the Application LRA Section 2.3.3.56 describes the containment auxiliary equipment (e.g., lighting fixtures, floor drains, sump pumps, piping, and valves) for the structure. These items may be within the scope of license renewal because they have components that perform one or more license renewal intended functions and the applicant has evaluated this equipment for components that support such functions. The containment building has electrical (e.g., fuses, breakers, process control boards, pressure transmitters, recorders, and video displays) and mechanical (e.g., air leak test equipment and pressure indicators) components that monitor containment internal pressure, provide electrical protection for a nonsafety-related electrical circuit, and test pressure.
The primary function of the containment auxiliary equipment electrical and mechanical components is to provide containment pressure monitoring signals that initiate ESF systems.
These components display pressure values in the control room for a maximum available pressure range of 0 - 55 psig. Containment pressure is sensed by four physically separated differential pressure transmitters mounted by rigid supports outside the containment and connected to the containment atmosphere by a filled, sealed hydraulic transmission system.
The containment auxiliary equipment contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs of the containment auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the containment auxiliary equipment performs functions that support SBO and EQ.
LRA Table 2.3.3-50 identifies containment auxiliary equipment component types within the scope of license renewal and subject to an AMR:
* piping, piping components, and piping elements The intended function of the containment auxiliary equipment component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.56.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.56 and FSAR Section 7.3.1.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with 2-159
 
intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.56.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.57 Containment Liner Penetration Auxiliary Equipment 2.3.3.57.1 Summary of Technical Information in the Application LRA Section 2.3.3.57 describes the containment liner penetration auxiliary equipment (e.g.,
floor drains, sump pumps, piping, and valves) for the structure. These items may be within the scope of license renewal because they have components that perform license renewal intended functions and the applicant has evaluated them for components that support such functions.
The components that support the containment liner penetration auxiliary equipment are position and pressure switches, fuses, motors, electro-hydraulic operators, valves, pumps, and pressure indicators that support operation of containment hatches and airlocks. The personnel emergency air lock has a door at each end of the lock in series and mechanically interlocked to ensure that one door cannot be opened until the other is sealed. Leakage and pressure test clamps for the personnel emergency air lock fit either door and are designed to withstand, as a minimum, the full peak containment internal pressure.
The containment liner penetration auxiliary equipment contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs of the containment liner penetration auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the containment liner penetration auxiliary equipment performs functions that support EQ.
LRA Table 2.3.3-51 identifies containment liner penetration auxiliary equipment component types within the scope of license renewal and subject to an AMR:
* piping, piping components, and piping elements The intended function of the containment liner penetration auxiliary equipment component types within the scope of license renewal is to provide a pressure-retaining boundary.
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2.3.3.57.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.57 and FSAR Sections 3.8.1.1.3.3 and 3.8.2.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.57.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment liner penetration auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.58 Security Building HVAC System 2.3.3.58.1 Summary of Technical Information in the Application LRA Section 2.3.3.58 describes the security building HVAC system, an independent ventilation system dedicated to the security building, classified as nonsafety-related, and not required for the safe shutdown of the plant. The security building HVAC system operations are independent from the modes of plant operation and continuous to maintain the environment for mechanical and electrical equipment and to provide comfort for operating personnel. The security building HVAC system is designed as once-through ventilation with separate provision for heating by electric unit heaters. The system, except the heating components, receives electric power from the security system diesel generator in a loss of offsite power. Mechanical components in this system include fans, ductwork, filters, dampers, compressors, cooling coils, chillers, heaters, valves, and necessary instrumentation to support operation for personnel and equipment.
The security building HVAC system performs functions that support fire protection.
LRA Table 2.3.3-52 identifies the security building HVAC system component types within the scope of license renewal and subject to an AMR:
* bird screens
* ducting and components
* ducting closure bolting
* elastomer seals and components 2-161
* fan housings The intended functions of the security building HVAC system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.58.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.58 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.58.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the security building HVAC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.59 Containment Vacuum Relief System 2.3.3.59.1 Summary of Technical Information in the Application LRA Section 2.3.3.59 describes the containment vacuum relief system, which consists of a check valve and an automatic air-operated butterfly valve outside containment in each of two independent vacuum relief lines. Actuation of the butterfly valves is controlled by differential pressure between the outside atmosphere and the containment. There are two safety-grade differential pressure transmitters for monitoring and two for control. One set of transmitters signals for control action to open the butterfly valves when the differential pressure between the containment and outside reaches its setpoint value. The second set, by a different manufacturer, signals continuously to the control room for indication and sets off an alarm before the differential pressure reaches the butterfly valve setpoint.
The containment vacuum relief system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the containment vacuum relief system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the containment vacuum relief system performs functions 2-162
 
that support SBO and EQ.
LRA Table 2.3.3-53 identifies containment vacuum relief system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* containment isolation piping and components
* containment vacuum relief accumulator tank
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* piping, piping components, and piping elements The intended functions of the containment vacuum relief system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.59.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.59 and FSAR Section 6.2.1.1.3.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.59.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment vacuum relief system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.60 Bridge Crane Equipment 2.3.3.60.1 Summary of Technical Information in the Application LRA Section 2.3.3.60 describes the bridge crane equipment, which consists of the following 2-163
 
bridge cranes:
* fuel handling bridge crane
* FHB auxiliary crane
* EDG bridge cranes A & B
* reactor containment building jib cranes A & B
* miscellaneous bridge cranes in the RAB, WPB, and service building The fuel handling bridge crane is designated safety-related. The bridge crane system has equipment conservatively assumed to meet 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) criteria based on quality class designation and therefore included within the scope of license renewal.
The structural parts of the bridge cranes system are evaluated as civil/structural components/commodities within the buildings or structures of their locations.
The bridge crane equipment contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs of the bridge crane equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.60.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.60 and FSAR Section 9.1.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.60.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the bridge crane equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.61 Containment Pressurization System 2.3.3.61.1 Summary of Technical Information in the Application LRA Section 2.3.3.61 describes the containment pressurization system for containment pressurization during Type A integrated leak rate testing. The system consists of piping from the southwest corner of the tank area/building through Containment Penetration M-96. Portable 2-164
 
air compressors connected to the piping outside of the tank area/building pressurize the containment for the integrated leak rate test. There are also penetrations and piping for containment pressure sensing and for a controlled flow release (verification flow) during the integrated leak rate test. The containment pressurization system has components required for containment isolation.
The containment pressurization system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the containment pressurization system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the containment pressurization system performs functions that support SBO.
LRA Table 2.3.3-54 identifies containment pressurization system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the containment pressurization system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.61.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.61 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.61.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment pressurization system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.62 Penetration Pressurization System 2.3.3.62.1 Summary of Technical Information in the Application 2-165
 
LRA Section 2.3.3.62 describes the penetration pressurization system, designed as a flow path for pressurizing the containment electrical penetrations, valve chambers, equipment hatch, and air locks for testing by pressurization to the accident design pressure to determine penetration leak rate. The system uses both nitrogen and instrument air for testing. System components include valves, piping components, and flow and pressure instrumentation. Containment electrical penetrations are pressurized continuously by nitrogen to verify integrity and to prevent the entry of moisture into the internals of the penetration itself. The flow rate of the nitrogen is monitored to assure the integrity of the electrical penetrations. Each electrical penetration is designed to be isolated and tested individually if necessary. The instrument air system can supply the penetration pressurization system piping for testing of the following mechanical penetrations:
* emergency air lock
* personnel air lock
* containment spray valve chambers
* RHR valve chambers During testing of the mechanical penetrations, air flow is directed to the penetration where local pressure indicators monitor penetration pressure during testing. The air flow rate is monitored for the integrity of the mechanical penetrations.
The penetration pressurization system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the penetration pressurization system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-55 identifies penetration pressurization system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements The intended function of the penetration pressurization system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.62.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.62 and FSAR Sections 6.2.6.1.3 and 3.8.1.1.3.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.3.62.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the penetration pressurization system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.63 Containment Cooling System 2.3.3.63.1 Summary of Technical Information in the Application LRA Section 2.3.3.63 describes the containment cooling system, which supports the containment heat removal system, which performs the containment heat removal function required by 10 CFR 50 Appendix A, GDC-38, Containment Heat Removal. The containment cooling system performs the following functions:
* during normal operation, the containment cooling system is designed to maintain the indicated containment temperature below 120&deg;F
* in a design-basis accident, containment fan coolers are designed to remove heat
* in a design-basis accident, containment fan coolers are designed to assist in mixing the containment atmosphere The containment cooling system consists of four safety-related fan cooler units and three nonsafety fan coil units. Following a design-basis accident only the safety-related fan cooler units are required to operate. During normal power operation, safety-related units operate with the nonsafety-related fan coil units to maintain the required containment temperature. Each of the safety-related containment fan cooler units consists of a service water cooling coil section and two fans. A gravity damper at the discharge side of each fan prevents airflow in the reverse direction when only one fan per unit is required to operate. Both fans of the unit discharge into a common duct connected to a concrete airshaft. A branch duct connection upstream of the shaft isolation damper serving as a post-accident discharge nozzle is normally isolated by a pneumatically-operated, fail-open damper. When in operation, air is drawn from containment space through the cooling coils to the fan suction.
The fan discharge is directed to either the concrete shaft or the post-accident nozzles, depending on the operation mode. A ductwork distribution network supplies air to the steam generator and pressurizer subcompartments, the operating floor, the ground floor, the instrument room, and the containment dome. A portion of the fan discharge is tapped to serve the reactor supports cooling system, the digital rod position indication cabinets, and the primary shield cooling system. Other areas of containment are cooled by natural convection. Each of the nonsafety-related containment fan coil units consists of a service water cooling coil and two fans. Each fan has an air-operated discharge damper to isolate the fan not in operation. Both fans discharge into common ductwork. When in operation, air is drawn from containment space, through the cooling coils, to the fan suction. Cooling air from the fan coil unit is directed 2-167
 
to the RCP sub-compartments.
The containment cooling system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the containment cooling system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the containment cooling system performs functions that support fire protection and EQ.
LRA Table 2.3.3-56 identifies containment cooling system component types within the scope of license renewal and subject to an AMR:
* containment fan cooler - cooler coil
* containment fan cooler - housing
* containment fan-coil - housing
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* flow-restricting elements
* piping, piping components, and piping elements The intended functions of the containment cooling system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary
* flow regulation 2.3.3.63.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.63 and FSAR Sections 6.2.2 and 7.3.1.3.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staffs review of LRA Section 2.3.3.63 identified areas in which additional information was necessary to complete the review of the applicants scoping and screening results. The applicant responded to the staffs RAIs as discussed below.
In RAI 2.3.3-2 dated August 27, 2007, the staff noted that Plant-Specific Note No. 716 for LRA Tables 3.3.2-1 through 3.3.2-68 reads "Alignments for piping and ducting may be considered equivalent components. This is supported by equivalencies in NUREG-1801, such as found in NUREG-1801, Section V.A-I." GALL Report Section V A, Engineered Safety Features -
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Containment Spray System (PWR), has an Item V.A-I for steel ducting, piping and components external surfaces in air-indoor uncontrolled (external) environment with the effect being loss of material/general corrosion and identifies the applicable AMP as GALL AMP XI.M36, "External Surfaces Monitoring." The staff requested that the applicant answer the following questions: (1) Is this the "Section V.A-I" being referred to, (2) What is the definition of "alignments, (3) Are "alignments for piping and ducting" referring to supports, fittings and/or components, assemblies or something else, and (4) In what sense or with what are they "considered equivalent components" and exactly how does GALL Report Section VA, Item V.A-1, support this equivalency determination.
In its response by letter dated September 24, 2007, the applicant stated:
NUREG-1801 Section VA Engineered Safety Features - Containment Spray System (PWR) has an Item V.A-1 for Steel Ducting, piping and components external surfaces in Air - Indoor uncontrolled (External) environment with the effect being Loss of material / general corrosion and identifies the applicable aging management program as NUREG-1801 Chapter XI.M36, External Surfaces Monitoring.
Referring to Section 4.2.2 of NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, Rev. 6, alignments are discussed as follows: Section 4.2.2 Consistency With NUREG-1801 Volume 2 Line Items: Each combination of component type, material, environment and aging effect requiring management should be compared with NUREG-1801 Volume 2 line items to identify consistencies. If there is no corresponding line item in NUREG-1801 Volume 2, the combination is a plant-specific aging evaluation result. Each applicant should identify how the aging evaluation results align with information in NUREG-1801, Volume 2. This is accomplished through a series of notes identified on Table 4.2-2. All note references with letters are standard notes that will be the same from application to application throughout the industry. Any notes the plant requires that are in addition to the standard notes will be identified by a number and deemed plant specific.
The various NUREG-1801 chapters contain summary descriptions and tabulations of evaluations of aging management programs for structures and components in the various major plant systems in light-water reactor nuclear power plants. However, the evaluations in NUREG-1801 for a given system may not contain all of the material/environment combinations likely to be encountered.
For example, NUREG-1801, Volume 2, Section VII, AUXILIARY SYSTEMS, F3 Primary Containment Heating and Ventilation System (i.e., VII F3), contains only one line item for stainless steel ducting (VII.F3-1). This line item contains condensation as the only environment choice. Referring to LRA Table 3.3.2-56 on Page 3.3-370 for the line items Containment Cooling System - ducting and components/stainless steel - Air/Gas (Wetted) (Inside) and Air - Indoor (Outside), it was deemed that a better alignment could be made to a line item in a different NUREG-1801 Section (i.e., VII.J-15) that is described as components of the type Piping, piping components, and piping elements. Note 716 is stating that the duct and pipe are considered equivalent components and provides an 2-169
 
example in NUREG-1801 (i.e., V.A-1) where precedence for such an equivalency is made. Section VA Item V.A-I supports this equivalency determination because the component ducting is treated equivalently with the component piping and components in this line item.
Based on its review, the staff finds the applicants response to RAI 2.3.3-2 acceptable because the specific clarifications requested were provided and the applicants application is consistent with the guidance of the GALL Report and NEI 95-10 with regard to the formulation and use of the note. This RAI is also applicable to LRA Sections 2.3.3.64, 2.3.3.66 and 2.3.3.67. The staffs concern described in RAI 2.3.3-2 is resolved.
In RAI 2.3.3-3 dated August 27, 2007, the staff noted that license renewal drawing 8-G-0517-LR has a box shaded green titled "DISCHARGE FROM CRDM COOLING FANS" at grid location G-9. The staff requested that the applicant clarify whether this drawing depicts a common discharge ductwork plenum or just a containment volume where mixing occurs and if the latter, why it is highlighted green.
In its response by letter dated September 24, 2007, the applicant stated that the box shaded green titled "DISCHARGE FROM CRDM COOLING FANS" at grid location G-9 on license renewal drawing 8-G-0517-LR represents the volume of air within the containment to which the CRDM cooling fans discharge. This volume should not have been highlighted on the subject scoping drawing.
Based on its review, the staff finds the applicants response to RAI 2.3.3-3 acceptable because the drawing was labeled in error and the letter corrected the mistake. Therefore, the staffs concerns described in RAI 2.3.3-3 are resolved.
2.3.3.63.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment cooling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.64 Airborne Radioactivity Removal System 2.3.3.64.1 Summary of Technical Information in the Application LRA Section 2.3.3.64 describes the airborne radioactivity removal system, designed to remove airborne particulate radioactivity from the containment atmosphere to permit personnel entry by recirculating the atmosphere through HEPA filters and charcoal adsorbers. The airborne radioactivity removal system consists of two recirculating airborne radioactivity removal units, one operational and one standby. Each unit includes a medium efficiency filter bank, a HEPA filter bank, a charcoal adsorber bank, and a centrifugal fan. The airborne radioactivity removal unit operates continuously to limit the build-up of airborne radioactivity which might leak from 2-170
 
the RCS during normal operation. The airborne radioactivity removal system is not safety-related and not required to operate during accident conditions. Upon a loss of power, the system is shut down.
The failure of nonsafety-related SSCs in the airborne radioactivity removal system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-57 identifies airborne radioactivity removal system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housings
* piping, piping components, and piping elements The intended function of the airborne radioactivity removal system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.64.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.64 and FSAR Section 9.4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staffs review of LRA Section 2.3.3.64 identified areas in which additional information was necessary to complete the review of the applicants scoping and screening results. See Section 2.3.3.63 and the RAI 2.3.3-2 response discussion.
2.3.3.64.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the airborne radioactivity removal system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.65 Containment Atmosphere Purge Exhaust System 2.3.3.65.1 Summary of Technical Information in the Application LRA Section 2.3.3.65 describes the containment atmosphere purge exhaust system, designed for the following functions:
* maintain low concentration of radioactivity in the containment atmosphere by continually purging the containment with a low volume of outside air to allow the system to draw down the containment atmosphere to a slight negative pressure
* reduce radioactivity concentration in the containment atmosphere to a level acceptable for personnel access by purging the containment with a high volume of outside air
* control combustible gases in containment; the hydrogen purge function as a backup for the redundant hydrogen recombiners and is not relied upon for safety The containment hydrogen purge system for hydrogen control inside the containment building purges hydrogen from the containment as a backup to the hydrogen recombiner system. The system consists of a purge make-up penetration line, an exhaust penetration line, and a filtered exhaust system. The post-accident hydrogen purge system, up to the first isolation valve outside Containment is Safety Class 2, seismic Category I, and designed to retain its integrity following a design-basis LOCA. The remainder of the system is not for design-basis safety as it serves as a backup system to the hydrogen recombiners. The system is designed to exhaust the air and hydrogen from the containment for replacement with outside air. The system has no functional and operational redundancy as it serves only as a diverse backup to the already redundant containment hydrogen recombiners; however, the system can control hydrogen inside containment following a LOCA independently of operation of the recombiners.
The containment atmosphere purge exhaust system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the containment atmosphere purge exhaust system potentially could prevent the satisfactory accomplishment of a safety-related function. The containment atmosphere purge exhaust system performs functions that support SBO, fire protection, and EQ.
LRA Table 2.3.3-58 identifies containment atmosphere purge exhaust system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* containment isolation piping and components
* containment purge cooling coil housing
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housings
* piping, piping components, and piping elements 2-172
 
The intended functions of the containment atmosphere purge exhaust system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.65.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.65 and FSAR Sections 9.4.7.2.2 and 6.2.5.1.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.65.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment atmosphere purge exhaust system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.66 Control Rod Drive Mechanism Ventilation System 2.3.3.66.1 Summary of Technical Information in the Application LRA Section 2.3.3.66 describes the CRDM ventilation system, a forced-air cooling system that reliably supplies cooling air to the CRDM magnetic coil housing during normal reactor operation.
The system draws containment air into a plenum area above the CRDM assemblies and down over the coil housing faces. The air exits below the coil housing and across the upper surface of the reactor vessel head via a return duct to centrifugal fans which exhaust to the containment atmosphere. The system consists of four 50-percent capacity centrifugal fans mounted on the upper section of the shroud structure. Internal baffles between the cooling shroud and the outer row of mechanisms along with dummy CRDM cans in positions which do not contain mechanisms create an exhaust plenum between the reactor vessel head and the lower mechanism coil housings.
Ducts inside the shroud structure direct air from this plenum up to and through fans on the upper portion of the shroud structure. In the unlikely event of a complete loss of CRDM cooling air, overheating eventually results in shorting of the CRDM coils and tripping of the rods. This problem is not safety-related problem because these coils perform no safeguard function. The 2-173
 
fans are not required to operate during a LOCA or MSLB; therefore, this system is not safety-related.
The failure of nonsafety-related SSCs in the control rod drive mechanism ventilation system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-59 identifies CRDM ventilation system component types within the scope of license renewal and subject to an AMR:
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* rod drive cooling system screens The intended functions of the CRDM ventilation system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.66.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.66 and FSAR Section 9.4.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.66 identified areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. See Section 2.3.3.63 and the RAI 2.3.3-2 response discussion.
2.3.3.66.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the control rod drive mechanism ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.67 Primary Shield and Reactor Supports Cooling System 2.3.3.67.1 Summary of Technical Information in the Application LRA Section 2.3.3.67 describes the primary shield and reactor supports cooling system, designed to supply cooling air to the annular clearance between the reactor vessel and primary shield wall, the reactor vessel supports, and the annular space between the reactor coolant legs and the concrete wall. The primary shield and reactor supports cooling system is a subsystem of the containment heat removal system. The primary shield cooling portion of the system consists of two Safety Class 3, 100-percent capacity, direct-driven supply fans, each serving as a standby for the other with a locked open inlet damper and a gravity-type discharge damper to prevent back flow through the standby fan. Each axial supply fan draws cool air from the vertical concrete air shaft and supplies it to the annular clearance between the reactor vessel and primary shield wall through connecting ductwork. Cooling by the primary shield cooling system minimizes the possibility of concrete dehydration.
The reactor supports cooling portion of the system consists of two Safety Class 3, 100-percent capacity direct-driven vane axial fans, each serving as a standby for the other with a locked open inlet damper and a gravity-type discharge damper to prevent back flow through the idle fan. The system draws cooling air from the vertical concrete air shaft and supplies it to the reactor vessel supports and to the annular space between reactor coolant legs and sleeves through the primary shield. Cool air is forced through these spaces uniformly in a ductwork distribution system. Cooling by the reactor supports cooling system limits thermal expansion of the reactor vessel supporting steelwork. The primary shield and reactor supports cooling system includes fans, fan motors, dampers, and I&Cs.
The primary shield and reactor supports cooling system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the primary shield and reactor supports cooling system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.3-60 identifies primary shield and reactor supports cooling system component types within the scope of license renewal and subject to an AMR:
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings The intended function of the primary shield and reactor supports cooling system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.67.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.67 and FSAR Section 6.2.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
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During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.67 identified areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. See Section 2.3.3.63 and the RAI 2.3.3-2 response discussion.
2.3.3.67.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the primary shield and reactor supports cooling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.68 Fuel Cask Handling Crane System 2.3.3.68.1 Summary of Technical Information in the Application LRA Section 2.3.3.68 describes the fuel cask handling crane system, part of the fuel handling system. The fuel cask handling crane transfers the spent fuel cask between the cask transport railroad car and the spent fuel cask loading pool. The FHB design and the fuel cask handling crane prevent the cask from passing over or falling into any fuel pool.
The failure of nonsafety-related SSCs in the fuel cask handling crane system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.68.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.68 and FSAR Section 9.1.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.3.68.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the fuel cask handling crane system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.69 Reactor Auxiliary Building Ventilation System 2.3.3.69.1 Summary of Technical Information in the Application LRA Section 2.3.3.69 describes the RAB ventilation system, which is designed for RAB cooling, heating, ventilation, differential pressure control, and radiological habitability control, and consists of the following systems:
* The RAB normal ventilation system ventilates the RAB during normal plant operation.
The once-through type system consists of a supply system and an exhaust system.
Under accident conditions, spaces with major containment penetrations and selected potentially contaminated areas are isolated automatically, the normal ventilation system shuts down, and the air from those areas is treated by the filtered RAB emergency exhaust system prior to release to the environment.
* The RAB emergency exhaust system maintains selected potentially contaminated RAB areas below atmospheric pressure following an safety-injection signal and minimizes unfiltered outleakage of airborne radioactive materials. This system consists of redundant fan and filter subsystems. Each of the two subsystem filter trains has a valve, decay heat cooling air connection, demister, electric heating coil, medium-efficiency filter, HEPA prefilter, charcoal adsorber, and HEPA after-filter. Connected to each filter train outlet is a fan with a valve on its inlet and a backdraft damper on its outlet to prevent reverse airflow through the inactive fan.
* The RAB nonnuclear safety ventilation system consists of two heating and ventilating equipment room subsystems (north and south), each having an outside air intake plenum, medium-efficiency filter, electric heating coil, chilled water cooling coil, and centrifugal supply and return fans. The system can function as a once-through or as a mixed (recirculation with makeup) system. The chilled water for the cooling coil is supplied from the essential services chilled water system. The RAB nonnuclear safety ventilation system is not safety-related and not required to operate during accident conditions.
* The RAB ESF equipment cooling system provides emergency cooling by fan coolers for areas with equipment essential for safe shutdown. The system consists of cooling systems for various ESF equipment areas and a steam tunnel ventilation system. Each cooling system has an air handling unit which consists of fan, cooling coil, and filter sections.
* The RAB switchgear rooms ventilation system serves the RAB switchgear rooms, 2-177
 
battery rooms, and the process instrument Cabinet Room A. Each switchgear room has its own independent air conditioning system. Each switchgear room ventilation system consists of an air intake protected from missiles and equipped with a self-acting tornado damper, medium efficiency filter, electric heating coil, two 100-percent redundant chilled water cooling coils connected in series, and two redundant fans arranged in parallel.
* The RAB electrical equipment protection room ventilation system has two redundant trains that share the same ductwork. The system consists of two 100-percent capacity subsystems in parallel, one normally operating and one in standby. Each supply subsystem consists of a motorized inlet damper, medium-efficiency filter, chilled water cooling coil, supply fan, gravity damper and electric heating coil. The exhaust subsystem has redundant fans. Exhausted air is discharged to the atmosphere through a valve protected from missiles.
* The RAB computer and communication rooms ventilation system consists of the computer and communication rooms HVAC system and the battery and HVAC equipment room HVAC system. The areas served are at an elevation of 305 ft. in a superstructure on the RAB roof. The system maintains areas at the proper design temperature and pressure for suitable operation of equipment, mitigates the consequences of a radiological accident, removes smoke in case of fire, and removes hydrogen by ventilation near batteries.
The RAB ventilation system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the RAB ventilation system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the RAB ventilation system performs functions that support fire protection and EQ.
LRA Table 2.3.3-61 identifies reactor auxiliary building ventilation system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housing
* piping, piping components, and piping elements
* RAB nonsafety-related cooling coil housings
* RAB safety-related cooling coil housings
* RAB safety-related cooling coils The intended functions of the RAB ventilation system component types within the scope of license renewal include:
* filtration
* heat transfer 2-178
* pressure-retaining boundary 2.3.3.69.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.69 and FSAR Sections 6.5.1, 9.4.3, 9.4.5, and 9.4.9 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.3.69 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staffs RAI as discussed below.
In RAI 2.3.3-4 dated August 27, 2007, the staff noted that license renewal drawing 8-G-0517-SO3-LR, Grid B-2, shows fan P-5 lB housing as being partially highlighted while fan P-5 IA housing is entirely highlighted. The staff requested that the applicant clarify whether fan P-5 1B housing is entirely within the scope of license renewal.
In its response dated September 24, 2007, the applicant stated that P-5 (1A-NNS) and P-5 (1B-NNS) are pumps. License renewal drawing 8-G-0517 S03-LR should have shown pump P-5 (1B-NNS) casing as being entirely highlighted identically as the casing for pump P-5 (IA-NNS) is entirely highlighted. The casing for pump P-5 (1B-NNS) is within the scope of license renewal and is included in the AMR results in LRA Table 3.3.2-61, Auxiliary Systems -
Summary of Aging Management Evaluation - Reactor Auxiliary Building Ventilation System, in the component/commodity "piping, piping components, and piping elements."
Based on its review, the staff finds the applicants response to RAI 2.3.3-4 acceptable because the drawing was labeled in error. The staffs concern described in RAI 2.3.3-4 is resolved.
2.3.3.69.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RAB ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.70 Emergency Service Water Intake Structure Ventilation System 2.3.3.70.1 Summary of Technical Information in the Application LRA Section 2.3.3.70 describes the ESW intake structure ventilation system located in the ESW & CTMU intake structure and consisting of the electric equipment room HVAC system and the emergency pump room ventilation system. This safety-related system designed to maintain a maximum temperature of 116F in each electrical motor control center room and of 122&deg;F in the emergency pump room is an ESF ventilation system. The pump room ventilation system operates during emergency conditions and can be started manually as required during normal conditions. The system consists of two exhaust systems, each exhausting and ventilating a single pump room.
The exhaust unit consists of an inline fan with a gravity discharge damper. Intake air is drawn from outside through louvers protected from missiles to the emergency pump room and discharged to atmosphere through a louver protected from missiles. Four electric unit heaters maintain the temperature for each pump room. In a loss of offsite power, this system is powered from the EDGs.
A single active failure in this system can affect only one of the two motor control center rooms or pump rooms; therefore, one pump is available to mitigate the consequences of a design-basis accident for safe plant shutdown.
The ESW intake structure ventilation system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the ESW intake structure ventilation system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the ESW intake structure ventilation system performs functions that support fire protection.
LRA Table 2.3.3-62 identifies ESW intake structure ventilation system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* ESW intake structure cooling coil enclosures
* fan housings
* filter housings
* piping, piping components, and piping elements The intended functions of the ESW intake structure ventilation system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2-180
 
2.3.3.70.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.70 and FSAR Section 9.4.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staffs review of LRA Section 2.3.3.70 identified an area in which additional information was necessary to complete the review of the applicants scoping and screening results. The applicant responded to the staffs RAI as discussed below.
In RAI 2.3.3-5 dated August 27, 2007, the staff noted that license renewal drawing 8-G-0548-LR, Grid B-8, shows a screen that is partially highlighted. The staff requested that the applicant clarify whether this is the "bird screen" and if this screen is entirely within the scope of license renewal.
In its response dated September 24, 2007, the applicant stated that the two damper bodies/enclosures, DG-GD3 (SA- 1) and DG-GD4 (SA- 1), shown on license renewal drawing 8-G-0548-LR at location J-4 should be entirely highlighted. The two damper bodies/enclosures are within the scope of license renewal and are included in the AMR results in LRA Table 3.3.2-65, Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator Building Ventilation System, in the component/commodity "Damper Housings."
Based on its review, the staff finds the applicants response to RAI 2.3.3-5 acceptable because the specific clarification requested was provided and this uncertainty as to what was highlighted on the drawing as being within the scope of license renewal was eliminated. The staffs concern described in RAI 2.3.3-5 is resolved.
2.3.3.70.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW intake structure ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.71 Turbine Building Area Ventilation System 2.3.3.71.1 Summary of Technical Information in the Application LRA Section 2.3.3.71 describes the turbine building area ventilation system, which ventilates, cools, heats, and filters enclosed areas in the turbine generator building. The system also filters and purges exhaust air from potentially contaminated areas and can vent and purge smoke from areas with potential smoke conditions. The following subsystems make up the turbine building area ventilation system:
* The condensate polishing demineralizers area ventilation system heats and ventilates spaces in the condensate polishing demineralizer areas, corridor areas, and the heating
        & ventilating equipment room.
* The electrical and battery room ventilation system heats and ventilates the electrical equipment room and battery room. The system, consisting of supply and exhaust units, is a once-through type during summer operation and an economizer cycle-type during the winter season.
* The general service switchgear room ventilation system heats and ventilates the turbine building switchgear room. The ventilation system for the switchgear room is a once-through during summer operation and an economizer cycle during winter operation.
* The condensate vacuum pump effluent treatment system filters exhaust for the condensate vacuum pump. It is a nonnuclear-safety, nonseismic Category I-designed ventilation cleanup system.
* The elevator machinery room ventilation system and sampling room HVAC system ventilate and heat the elevator machinery room and the secondary sampling room.
* The secondary sampling equipment enclosure system cools the secondary sampling equipment enclosure. The system consists of two four-ton split-system air conditioning units. The two air conditioning units start in sequence according to the demand of the thermostat and operate in a recirculation mode.
* The turbine building decontamination facility HVAC system is designed (1) to provide heating, ventilating and cooling for personnel comfort during plant normal operation, (2) to provide potentially contaminated areas with once-through ventilation, (3) to purge smoke in a fire, and (4) to provide redundant fans for continuous reliable operation. The system serves the health physics rooms, health physics office, decontamination rooms, locker rooms, corridors, and vestibule. The system is not safety-related and not required to operate during accident conditions.
The turbine building area ventilation system performs functions that support fire protection.
LRA Table 2.3.3-63 identifies turbine building area ventilation system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting 2-182
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housings
* piping, piping components, and piping elements The intended functions of the turbine building area ventilation system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.71.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.71 and FSAR Sections 9.4.4 and 9.4.10 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.71.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine building area ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.72 Waste Processing Building HVAC System 2.3.3.72.1 Summary of Technical Information in the Application LRA Section 2.3.3.72 describes the WPB HVAC system, which ventilates and heats WPB areas. The system has a filtered exhaust system for potentially contaminated areas to reduce offsite airborne radioactivity during the normal operation of the plant. The system detects and controls the spread of smoke through WPB areas. The WPB HVAC system consists of the following:
: 1.      The waste processing areas ventilation system ventilates WPB areas during normal plant operation. The major part of the system is a once-through type for contaminated 2-183
 
areas. A small portion of the system serving noncontaminated areas is an economizer cycle which blends outside air and return air as required. The filtered exhaust consists of filtered subsystems including dampers, medium-efficiency filter, HEPA filter, charcoal adsorber, and a fan.
: 2.      The WPB control room HVAC system provides heating, ventilation, and air conditioning for personnel comfort and safety and for functional protection of equipment and controls. The system includes two 50-percent capacity units consisting of a common outside air intake plenum, a return outside air mixing section with dampers, medium-efficiency filters, electric heating coil, chilled water cooling coil, electric reheat coil, and a fan.
: 3.      The personnel handling facility HVAC system provides heating, ventilating, and air conditioning for selected WPB areas. The system consists of an outside air intake plenum, dampers, medium-efficiency filters, electric heating coil, chilled water cooling coil, and a fan.
: 4.      The office and laundry areas HVAC system provides heating, ventilating, and air conditioning for three subsystems:
: a.      The laundry dryer supply system is a once-through system providing makeup air, heat, and ventilation to the cold laundry area. The supply system has six supply fans sharing a common outside air intake with a prefilter section and common supply air ductwork.
: b.      The laundry facility air conditioning system is a once-through system with an air-handling unit and a zone reheat coil.
: c.      The office areas air conditioning system consists of an air-handling unit, a recirculating fan, and electric zone reheat coils. The air-handling unit includes a mixing section with dampers, a medium-efficiency filter, an electric heating coil, a chilled water cooling coil, and a fan. The cooling coil is supplied with chilled water from the nonessential services chilled water system.
: 5.      The laboratory areas HVAC system provides heating ventilating and air conditioning for laboratory areas and ventilation for fume hoods. The system has three supply units for all the fume hoods and an air-handling unit for laboratory areas. Each fume hood supply unit includes dampers, medium-efficiency filters, an electric heating coil, and a fan.
: 6.      The instrumentation and control shop HVAC system provides ventilation for personnel comfort and safety and for functional protection of equipment. The system consists of an air-handling unit which draws air from the outside through a damper, medium-efficiency filters, an electric heating coil, a chilled water cooling coil, and a fan followed by an electric reheat coil.
The WPB HVAC system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the WPB HVAC system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the WPB HVAC system performs functions that support fire protection.
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LRA Table 2.3.3-64 identifies WPB HVAC system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* cooling coil housing
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housings
* motor control center and instrument rack area cooling coil housing
* motor control center and instrument rack area cooling coil
* piping, piping components, and piping elements The intended functions of the WPB HVAC system component types within the scope of license renewal include:
* filtration
* heat transfer
* pressure-retaining boundary 2.3.3.72.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.72 and FSAR Section 9.4.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.72.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the WPB HVAC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.73 Diesel Generator Building Ventilation System 2.3.3.73.1 Summary of Technical Information in the Application LRA Section 2.3.3.73 describes the diesel generator building ventilation system, designed for temperature control and ventilation in rooms of that building to maintain the temperature in the EDG rooms whenever the EDGs operate and to maintain the temperature in the electrical equipment and fan rooms to protect electric equipment and motors. This safety-related ESF system provides redundant trains and remains functional during and after a safe shutdown earthquake. The following descriptions are for each EDG unit:
* The diesel generator room ventilation system has two EDG room exhaust fans, 1A and 1B, each with a gravity discharge damper.
* The electrical equipment room ventilation system is designed to filter and pressurize this air space to limit dust accumulation. The system consists of an air handling unit with medium efficiency filters, an electric heating coil, and two EDG electrical equipment room cooling fans.
* The fuel oil day tank and exhaust silencer room ventilation system consists of two centrifugal exhaust fans and dampers.
* The air start system and axial fan area ventilation system contains the exhaust fans and dampers for the EDG room.
* The HVAC equipment room ventilation system draws air through its room by two centrifugal exhaust fans via the adjacent silencer room. During EDG operation, combustion air is withdrawn from this area via the engine air intakes.
System safety-related components required for safe shutdown of the plant and design-basis accidents receive emergency power from their respective EDGs. An independent instrument air system provides instrument and control air for operation of the nonsafety-related air-operated dampers at the outside air intakes of the EDG room and fuel oil day tank area and HVAC equipment room. Electric unit heaters for the EDG areas are not safety-related and not required to operate during emergency conditions.
The diesel generator building ventilation system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel generator building ventilation system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the diesel generator building ventilation system performs functions that support fire protection.
LRA Table 2.3.3-65 identifies diesel generator building ventilation system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* cooling coil housing
* damper housings
* ducting and components 2-186
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housings
* piping, piping components, and piping elements The intended functions of the diesel generator building ventilation system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.73.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.73 and FSAR Section 9.4.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.73.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel generator building ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.74 Fuel Oil Transfer Pump House Ventilation System 2.3.3.74.1 Summary of Technical Information in the Application LRA Section 2.3.3.74 describes the fuel oil transfer pump house ventilation system, designed to remove combustible diesel fuel fumes and maintain temperature in the fuel oil transfer pump rooms. Although the system has safety-related components, it is not required for operability of the diesel fuel oil system. This ESF system can operate during normal and emergency conditions but performs no safety-related function required to support EDG operation. The system consists of two exhaust subsystems, each supporting one of two fuel oil transfer pump rooms with two redundant full-capacity exhaust fans with gravity discharge dampers to prevent reverse airflow through the inactive fans. One outside air intake structure and one air discharge structure for the system are located on the roof and protected from missiles. The electric unit 2-187
 
heaters are not safety-related and not required to operate during emergency conditions. During emergency conditions, a single failure in the system can affect only one of the two fuel oil transfer pump rooms; furthermore, the affected fuel oil transfer pump remains fully operable even with its ventilation system inoperable.
The fuel oil transfer pump house ventilation system contains safety-related components relied upon to remain functional during and following DBEs. In addition, the fuel oil transfer pump house ventilation system performs functions that support fire protection.
LRA Table 2.3.3-66 identifies fuel oil transfer pump house ventilation system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* piping, piping components, and piping elements The intended functions of the fuel oil transfer pump house ventilation system component types within the scope of license renewal include:
* filtration
* pressure-retaining boundary 2.3.3.74.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.74 and FSAR Section 9.4.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.74.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the fuel oil transfer pump house ventilation system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.75 Fuel Handling Building Auxiliary Equipment 2.3.3.75.1 Summary of Technical Information in the Application LRA Section 2.3.3.75 describes the FHB auxiliary equipment (e.g., lighting fixtures, floor drains, sump pumps, discharge piping, and valves) for the structure. These items may be within the scope of license renewal because they have components that perform one or more license renewal intended functions. The applicant has evaluated this equipment for mechanical or electrical/I&C components that support license renewal intended functions. The FHB houses (1) facilities for storing, moving, and handling both new and spent fuel, (2) secondary waste equipment (e.g., evaporators, demineralizers, heaters, condensers, pumps, filters, and control panels), and (3) recycle evaporators, recycle holdup tanks, HVAC ducts, pumps, filters, and the hydrogen purge unit. Structural elements, cranes, cubicles, panel, and racks are evaluated as structural components with the FHB structure.
This subsection evaluates electrical and mechanical equipment (e.g., heaters, lights, and circuit breakers) that support the FHB. FHB auxiliary equipment has mechanical and electrical components conservatively assumed to meet 10 CFR 54.4(a)(2) criteria based on their quality class designation and therefore included within the scope of license renewal.
The failure of nonsafety-related SSCs of the FHB auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.75.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.75 and FSAR Section 3.8.4.1.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.75.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the FHB auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.3.76 Fuel Handling Building HVAC System 2.3.3.76.1 Summary of Technical Information in the Application LRA Section 2.3.3.76 describes the FHB HVAC system, which provides heating, ventilation, and cooling to maintain the FHB indoor design temperature range during plant operation; to isolate fuel handling areas in any accidental release of radioactive material; and to maintain these areas at sub-atmospheric pressure by the emergency exhaust system to limit potential offsite exposures. The system also cools the spent fuel pool pump room and other areas housing safety-related equipment during normal and emergency conditions and detects and controls the spread of smoke in a fire. The FHB HVAC system consists of:
* The air conditioning system for the operating floor (i.e., the spent fuel pool area) provides ventilation and the proper temperature for personnel comfort and safety, equipment protection, and isolation of selected areas in a fuel handling accident or any accidental release of radioactive material. The system consists of a supply and an exhaust subsystems.
* The emergency exhaust system is a safety-related ESF filter system designed to mitigate the consequences of a postulated fuel handling accident by removing the airborne radioactivity from the FHB exhaust air prior to release to the atmosphere. The system maintains the FHB operating floor under negative pressure following a fuel handling accident to prevent unfiltered outleakage of airborne radioactive materials.
* The normal ventilation system ventilates areas below the operating floor, provides cooling to protect mechanical and electrical equipment, and directs air flow from areas of low to areas of progressively higher potential radioactivity. The system consists of a normal supply and a normal exhaust subsystems.
* The spent fuel pool pump room ventilation system cools pumps, heat exchangers, and equipment of the emergency exhaust system. The system includes two 100-percent capacity air handling units with consisting of medium-efficiency filters, a chilled water cooling coil, and a fan.
The FHB HVAC system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the FHB HVAC system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the FHB HVAC system performs functions that support fire protection and EQ.
LRA Table 2.3.3-67 identifies FHB HVAC system component types within the scope of license renewal and subject to an AMR:
* bird screens
* closure bolting
* damper housings
* ducting and components
* ducting closure bolting
* elastomer seals and components
* fan housings
* filter housings 2-190
* flow-restricting elements
* FHB normal supply cooling coil housing
* FHB pump room cooling coil
* FHB pump room cooling coil housing
* pipe, piping components, and piping elements The intended functions of the FHB HVAC system component types within the scope of license renewal include:
* heat transfer
* pressure-retaining boundary
* flow regulation 2.3.3.76.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.76 and FSAR Sections 6.5.1, 9.4.2, and 9.4.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.76.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the FHB HVAC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.77 Turbine Building Health Physics Room Auxiliary Equipment 2.3.3.77.1 Summary of Technical Information in the Application LRA Section 2.3.3.77 describes the turbine building health physics room auxiliary equipment (e.g., lighting fixtures, floor drains, sump pumps, discharge piping, and valves) for the structure.
These items may be within the scope of license renewal because they have components that perform one or more license renewal intended functions. The applicant has evaluated this equipment for components that support license renewal intended functions. The turbine building health physics room has equipment for the support and maintenance of respirators. Mechanical equipment (e.g., decontamination devices, heaters) and electrical equipment (e.g., breakers, motors, meters, and modules) are evaluated as parts of this system. The turbine building health physics room auxiliary equipment has components conservatively assumed to meet 2-191
 
10 CFR 54.4(a)(2) criteria based on their quality class designation and therefore included within the scope of license renewal.
The failure of nonsafety-related SSCs of the turbine building health physics room auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.3.77.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.77 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.77.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine building health physics room auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.78 Polar Crane Auxiliary Equipment 2.3.3.78.1 Summary of Technical Information in the Application LRA Section 2.3.3.78 describes the polar crane auxiliary equipment (e.g., lighting fixtures, floor drains, sump pumps, discharge piping, and valves) for the structure. These items may be within the scope of license renewal because they have components that perform one or more license renewal intended functions. The applicant has evaluated this equipment for components that support license renewal intended functions. The circular bridge containment polar crane located in the containment building is for the movement of equipment on the containment operating floor. The polar crane auxiliary equipment consists of mechanical and electrical components (e.g., drive mechanism, reduction gear, breakers, alarms, cables, switches, lighting, fuses, motors, rectifiers, resistors, and transformers) conservatively assumed to meet 10 CFR 54.4(a)(2) criteria based on their quality class and therefore included within the scope of license renewal.
The failure of nonsafety-related SSCs of the polar crane auxiliary equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
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2.3.3.78.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.78 and FSAR Section 9.1.4.3.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.78.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the polar crane auxiliary equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.79 Elevator System 2.3.3.79.1 Summary of Technical Information in the Application LRA Section 2.3.3.79 describes the elevator system, which consists of the following elevators:
* containment building elevator
* FHB elevator
* K-building elevator located in the outside power block structure
* RAB elevator
* turbine building elevator
* WPB elevator #1
* WPB elevator #2 Elevators outside the containment serve as escape routes and may be used as access routes for fire fighting. These elevators are located throughout the plant along with electrical switches, circuit breakers, and supporting enclosures. The applicant evaluates elevator system structural components as civil commodities as parts of buildings where they are located. The remaining mechanical and electrical components (e.g., alternating current circuit breakers, motors, gearboxes, and disconnect switches) are evaluated as parts of this system.
The failure of nonsafety-related SSCs in the elevator system potentially could prevent the satisfactory accomplishment of a safety-related function.
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2.3.3.79.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.79 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.79.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the elevator system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.80 Technical Support Center HVAC System 2.3.3.80.1 Summary of Technical Information in the Application LRA Section 2.3.3.80 describes the technical support center HVAC system located in the FHB.
The technical support center has radiological and monitoring equipment to protect personnel.
The monitoring equipment can indicate dose rates and airborne radioactivity concentrations continuously. Technical support center components are mechanical and electrical (i.e., lighting, switches, breakers, alarms, motors, controllers, transmitters, sensors, air handling units, dampers, fans, ductwork, filters, and heat pumps).
The failure of nonsafety-related SSCs in the technical support center HVAC system potentially could prevent the satisfactory accomplishment of a safety-related function. The system also performs functions that support fire protection.
LRA Table 2.3.3-68 identifies technical support center HVAC system component types within the scope of license renewal and subject to an AMR:
* ducting and components
* ducting closure bolting The intended function of the technical support center HVAC system component types within the scope of license renewal is to provide a pressure-retaining boundary.
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2.3.3.80.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.80 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.80.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the technical support center HVAC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.81 Mechanical Components in Electrical Systems 2.3.3.81.1 Summary of Technical Information in the Application LRA Section 2.3.3.81 describes the mechanical components in electrical systems. Specifically, the 230kV switchyard system and the gross failed fuel detection system have been assigned to the electrical and I&C area; however, they have mechanical components that support system intended functions. The 230kV switchyard system connects the power generated by HNP to the Carolina Power & Light Company system for distribution to its customers and provides a source of dependable offsite power to the plant during startup, emergency, or controlled shutdown operations. The startup transformers within the 230kV switchyard system are supplied power from the switchyard via underground 230kV low-pressure cable filled with oil provided through piping from tanks. The tanks, piping, and piping elements up to the cable connection are mechanical components that support the system intended function.
The mechanical components in electrical systems perform functions that support SBO.
LRA Table 2.3.3-69A identifies mechanical components in electrical systems component types within the scope of license renewal and subject to an AMR:
* piping, piping components, and piping elements
* tanks 2-195
 
LRA Table 2.3.3-69B identifies mechanical components in electrical systems component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the mechanical components in electrical systems component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.3.81.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.81 and FSAR Section 9.3.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.81.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the mechanical components in electrical systems components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.82 Monorail Hoists Equipment 2.3.3.82.1 Summary of Technical Information in the Application LRA Section 2.3.3.82 describes the monorail hoists equipment, which supports the monorail hoists located throughout the plant and consists of electrical switches, circuit breakers, and supporting enclosures. Structural components like cranes, hoists, and protective enclosures are evaluated as civil components or commodities as parts of buildings where they are located.
Monorail hoists equipment has components conservatively assumed to meet 10 CFR 54.4(a)(2) criteria based on their quality class designation and, therefore, included within the scope of license renewal.
The failure of nonsafety-related SSCs of monorail hoists equipment potentially could prevent the satisfactory accomplishment of a safety-related function.
2-196
 
2.3.3.82.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.82 and FSAR Section 9.1.4.2.2.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.82.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the monorail hoists equipment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.3.83 Post-Accident Hydrogen System 2.3.3.83.1 Summary of Technical Information in the Application LRA Section 2.3.3.83 describes the post-accident hydrogen system, which consists of the hydrogen recombiners and hydrogen monitoring components. The hydrogen purge function is a backup for the recombiners and not relied upon for safety. The post-accident hydrogen system ensures that hydrogen gas generated inside the containment following a LOCA does not exceed the RG 1.7 limit of 4 percent by volume. The system has an RG 1.97 Category 1 requirement to monitor post-accident hydrogen concentration in containment and has components required for containment isolation. CIV position indication is an RG 1.97 Category 1 requirement.
The post-accident hydrogen system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the post-accident hydrogen system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the post-accident hydrogen system performs functions that support EQ.
LRA Table 2.3.3-70 identifies post-accident hydrogen system component types within the scope of license renewal and subject to an AMR:
* hydrogen analyzer tubing and valves
* hydrogen recombiners
* remote sample dilution panel pump
* remote sample dilution panel refrigeration unit 2-197
* remote sample dilution panel sample cooler
* remote sample dilution panel sample cooler tubes
* remote sample dilution panel tubing and valves
* closure bolting
* containment isolation piping and components
* piping insulation
* piping, piping components, and piping elements The intended functions of the post-accident hydrogen system component types within the scope of license renewal include:
* pressure-retaining boundary
* thermal insulation 2.3.3.83.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.83 and FSAR Section 6.2.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.3.83.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the post-accident hydrogen system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4 Steam and Power Conversion Systems LRA Section 2.3.4 identifies the steam and power conversion systems SCs subject to an AMR for license renewal.
The applicant described the supporting SCs of the steam and power conversion systems in the following LRA sections:
* 2.3.4.1                Steam Generator Blowdown System
* 2.3.4.2                Steam Generator Chemical Addition System
* 2.3.4.3                Main Steam Supply System
* 2.3.4.4                Steam Dump System 2-198
* 2.3.4.5                Auxiliary Boiler/steam System
* 2.3.4.6                Feedwater System
* 2.3.4.7                Feedwater Heater Drains & Vents System
* 2.3.4.8                Afw System
* 2.3.4.9                Auxiliary Steam Condensate System
* 2.3.4.10        Condensate System
* 2.3.4.11        Condensate Storage System
* 2.3.4.12        Secondary Sampling System
* 2.3.4.13        Steam Generator Wet Lay up System
* 2.3.4.14        Turbine System
* 2.3.4.15        Digital-electric Hydraulic System
* 2.3.4.16        Turbine-generator Lube Oil System The staffs findings on review of LRA Sections 2.3.4.1 - 2.3.4.16 are in SER Sections 2.3.4.1 -
2.3.4.16, respectively.
2.3.4.1 Steam Generator Blowdown System 2.3.4.1.1 Summary of Technical Information in the Application LRA Section 2.3.4.1 describes the steam generator blowdown system, which removes contaminants and corrosion product accumulations from the steam generators to maintain secondary water chemistry within prescribed limits. The steam generator blowdown system includes CIVs, a blowdown flash tank, a blowdown drain tank, a heat exchanger, pre-filter, three demineralizers, resin traps, blowdown flow instrumentation, control valves, thermowells, venturis, nozzles, and piping; however, not all of these components are within the scope of license renewal. The steam generator blowdown system constitutes a potential radioactivity release path even with two barriers between the fission products and the environment. The system portion from the steam generator to and including the CIVs extends the steam generator boundary. These valves and piping also constitute part of the containment boundary.
The isolation valves close automatically on an AFW actuation signal or an safety-injection signal. The system includes components required for containment isolation. CIV position indication is an RG 1.97 Category 1 function.
The steam generator blowdown system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the steam generator blowdown system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the steam generator blowdown system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.4-1 identifies steam generator blowdown system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* piping, piping components, and piping elements 2-199
 
The intended function of the steam generator blowdown system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.1.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.1 and FSAR Section 10.4.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.3.4.1 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as discussed below.
In RAI 2.3.4.1-1 dated August 20, 2007, the staff noted that in LRA Section 2.3.4.1, the applicant identifies the steam generator blowdown system as within the scope of license renewal; because, in part, it contains components that are relied on during postulated fires and SBO events, and components that are part of the EQ Program. In FSAR Section 10.4.8, the applicant describes the steam generator blowdown system, but does not identify how the system is credited in fire protection, SBO, and EQ.
The staff asked the applicant to provide a list of all the components and their intended function(s) within this system that are within the scope of license renewal and are relied on during postulated fires, SBO events, or part of the EQ Program.
In its response dated September 18, 2007, the applicant stated that the steam generator blowdown system components relied on during postulated fires and SBO events consist of components associated with CIVs. The applicant stated that those containment isolation components are depicted on license renewal scoping drawing 5-G-0051-LR near containment penetrations M-51, M-52, and M-53. The applicant identified that the intended function for the component/commodity type containment isolation piping and components in LRA Table 2.3.4-1 was listed as M-1, Pressure Boundary.
The applicant further explained that the steam generator blowdown system contains certain electrical equipment (e.g., CIV position switches, required to be environmentally qualified to mitigate a design basis accident). The applicant explained that this electrical equipment is part of the EQ Program, electrical equipment is maintained on the EQML, and that electrical equipment on the EQML satisfies the scoping requirements of 10 CFR 54.4(a)(3).
Based on its review, the staff finds the applicant's response to RAI 2.3.4.1-1 acceptable because the applicant clarified those components in the steam generator blowdown system that are credited by fire protection, SBO, and EQ. Therefore, the staff's concern described in RAI 2.3.4.1-1 is resolved.
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2.3.4.1.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the steam generator blowdown system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.2 Steam Generator Chemical Addition System 2.3.4.2.1 Summary of Technical Information in the Application LRA Section 2.3.4.2 describes the steam generator chemical addition system, which supplies various chemical additives to the steam and power conversion systems. The addition of these chemicals controls oxygen concentration and maintains proper pH limits to minimize corrosion.
Chemical feed to secondary water is based on all-volatile treatment involving injection of an amine and hydrazine or equivalent solutions to the effluent header of the condensate polishing demineralizer. An added amine solution establishes and maintains alkaline pH conditions throughout the secondary cycle. Hydrazine or equivalent solution added to scavenge dissolved oxygen in the cycle and maintain adequate residual concentration ensures that a minimal amount of dissolved oxygen enters the steam generator. The all-volatile treatment method reduces general corrosion and minimizes the transport of corrosion products to the steam generator. The steam generator chemical addition system has tanks, heaters, mixers, metering pumps, valves, piping (safety-related) and level alarms necessary for chemical delivery. Not all of these components are within the scope of license renewal. The system has piping segments conservatively assumed to meet 10 CFR 54.4(a)(1) criteria based on their historical quality class designation.
The steam generator chemical addition system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the steam generator chemical addition system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.4-2 identifies steam generator chemical addition system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the steam generator chemical addition system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2-201
 
2.3.4.2.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.2 and FSAR Section 10.3.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.2.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the steam generator chemical addition system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.3 Main Steam Supply System 2.3.4.3.1 Summary of Technical Information in the Application LRA Section 2.3.4.3 describes the main steam supply system designed for the following functions:
* Deliver steam from the secondary side of the steam generators to the turbine generator stop valves at the required steam conditions
* Dissipate heat generated by the reactor by use of the steam dump system when the turbine generator is not in service
* Provide steam for turbine gland seals, reheaters, and other plant auxiliary components
* Dissipate heat to atmosphere through the main steam safety or main steam PORVs when the main condenser is not available
* Isolate the steam generators from the remainder of the main steam supply system and from each other as described in the plant accident analysis
* Provide adequate overpressure protection for the steam generators and main steam supply system
* Supply steam to the AFW pump turbine Steam flow from each steam generator is measured across a flow limiter in the steam generator steam outlet nozzle to restrict the steam flow from the affected steam generator in an MSLB.
Each steam line from an steam generator has five main steam safety valves, one 2-202
 
electrohydraulic PORV, and one main steam isolation valve. The steam supply to the AFW pump turbine drive is from two of the three steam supply pipes upstream of the main steam isolation valves. The system also supplies steam to the moisture separator reheaters. The PORVs are controlled automatically by main steam pressure. The valves are designed to fail closed on loss of power and are connected to safety buses for maximum reliability. The system has components required for containment isolation. CIV position indication is an RG 1.97 Category 1 function. The system also has RG 1.97 Category 1 steam line pressure transmitters.
The main steam supply system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the main steam supply system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the main steam supply system performs functions that support fire protection, ATWS, SBO, and EQ.
LRA Table 2.3.4-3 identifies main steam supply system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* flow-restricting elements
* piping insulation
* piping, piping components, and piping elements The intended functions of the main steam supply system component types within the scope of license renewal include:
* pressure-retaining boundary
* thermal insulation
* flow regulation 2.3.4.3.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.3 and FSAR Sections 7.4.1.7 and 10.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.3.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff 2-203
 
concludes that there is reasonable assurance that the applicant has adequately identified the main steam supply system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.4 Steam Dump System 2.3.4.4.1 Summary of Technical Information in the Application LRA Section 2.3.4.4 describes the steam dump system, which reduces the magnitude of transients on the NSSS following large load reductions. The system performs the following functions:
* permits the plant to accept sudden load rejections
* removes stored energy and residual heat from the primary system following a turbine or reactor trip
* maintains the plant in hot standby condition
* permits manually-controlled cool-down of the plant to the point where the RHR system can be placed in service The steam dump system can accommodate an abnormal load rejection and reduce the effects of the transient imposed upon the RCS. Bypassing main steam directly to the condenser or the atmosphere or both maintains an artificial load on the RCS. The RCS then can reduce the reactor temperature to a new equilibrium value without causing overtemperature, overpressure conditions, or both. The system consists of eight atmospheric steam dump valves which dump steam directly to atmosphere and six condenser steam dump valves which allow steam to bypass the turbine and dump to the condenser. Steam dump valves are connected to the main steam piping downstream of the main steam isolation valves. Isolation of the steam dump valves is permissible as the steam dump system is not essential to safe plant operation. The system has no safety-related function and is designed to nonnuclear safety standards; however, the system has control switches conservatively assumed to meet 10 CFR 54.4(a)(1) criteria based on their historical quality class designation. In addition, failure of the steam dump system high-energy lines has no detrimental effect on safety-related systems.
The steam dump system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the steam dump system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.4-4 identifies steam dump system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the steam dump system component types within the scope of license renewal is to provide a pressure-retaining boundary.
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2.3.4.4.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.4 and FSAR Section 10.4.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.4.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the steam dump system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.5 Auxiliary Boiler/Steam System 2.3.4.5.1 Summary of Technical Information in the Application LRA Section 2.3.4.5 describes the auxiliary boiler/steam system, which supplies saturated steam for nonsafety-related use in various balance of plant and reactor support systems mainly during plant start-ups, shutdowns, and refueling outages. The system includes Auxiliary Boiler B located in the yard, normally maintained in a shutdown condition, and manually started by an operator. When online, the auxiliary boiler operates automatically. The auxiliary boiler/steam system is not safety-related and is not required to operate during or following design-basis accidents; however, it can be the sole source of steam supply to the plant during certain conditions and its reliability can be important to certain plant recovery operations. The auxiliary steam supply system normally is supplied by the main steam supply or the extraction steam system and, when these systems are unavailable, by the auxiliary boiler.
The auxiliary condensate system is designed to receive the condensed steam from the process equipment supplied with auxiliary steam. The auxiliary boiler fuel oil system is designed to receive and store fuel for the auxiliary boiler. System mechanical components include a boiler, chemical tanks, chemical feed pumps, piping, valves, and steam traps. Other components include instrumentation, breakers, transmitters, and controllers required to operate the system.
Two excess-flow check valves in the turbine building isolate steam to the RAB in an RAB piping failure.
The failure of nonsafety-related SSCs in the auxiliary boiler/steam system potentially could prevent the satisfactory accomplishment of a safety-related function.
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LRA Table 2.3.4-5 identifies auxiliary boiler/steam system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the auxiliary boiler/steam system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.5.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.5 and FSAR Section 10.3.1 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.5.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary boiler/steam system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.6 Feedwater System 2.3.4.6.1 Summary of Technical Information in the Application LRA Section 2.3.4.6 describes the feedwater system, which provides feedwater at the proper flow rate, temperature, and pressure to the steam generators as required by the NSSS to generate steam during normal plant operating conditions. The principal components of the feedwater system are the feedwater pumps, two high-pressure feedwater heaters, feedwater regulating valves, feedwater regulating bypass valves, MFIVs, piping, valves, and electrical components required to support the system. Each MFIV is equipped with a pneumatic actuator using an accumulator with a stored source of nitrogen as the motive force for operation of the valves. The MFIVs are CIVs. A main feedwater isolation signal will close MFIVs and trip the feedwater pumps. The feedwater regulating and regulating bypass valves close in response to a main feedwater isolation signal upon a loss of power signal from the reactor protection system or upon loss of control air or loss of direct current to the solenoid valves.
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The system serves no safety function other than containment isolation integrity and is therefore generally nonsafety-related. The safety-related system portion is from the feedwater header check valves to the steam generators.
The feedwater system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the feedwater system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the feedwater system performs functions that support fire protection, SBO, and EQ.
LRA Table 2.3.4-6 identifies feedwater system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* MFIV accumulators
* piping, piping components, and piping elements The intended function of the feedwater system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.6.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.6 and FSAR Section 10.4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In LRA Section 2.3.4.6, Feedwater System, the applicant did not identify the feedwater isolation function in scope for license renewal under 10 CFR 54.4 (a)(1). In Section 15.1.5 of the applicants FSAR, it states that the feedwater isolation valves and regulating valves provide a safety-related function, isolation of feedwater in the event of a main steam line break. The staffs position is that the FSAR description of the feedwater isolation and regulating valves meet the criteria defined by 10 CFR 54.4(a)(1). In response to RAI 2.1.1.2-1, the applicant stated that based on their evaluation the feedwater regulating and bypass valves, these valves do not meet the license renewal definition of safety-related as stated in 10 CFR 54.4(a)(1);
however, the components are included within the scope of license renewal for 10 CFR 54.4(a)(2). The staff found the applicants answer to RAI response 2.1.1.2-1 inconsistent with 10 CFR 54.4 (a)(1).
In RAI 2.3.4.6-2 the staff asked the applicant to further evaluate the classification of this equipment and justify their position. The applicants response, dated January 22, 2008, maintains that these valves are important to safety, but are not safety-related; therefore, they only meet the criteria of 10 CFR 54.4(a)(2). The staffs position remains that the main feedwater regulating and bypass valves, by definition, fulfill a safety-related function; therefore, 2-207
 
they should be included in scope under 10 CFR 54.4(a)(1). In addition, the function to provide main feedwater isolation should be included in scope under 10 CFR 54.4(a)(1) for Section 2.3.4.6, to include the main feedwater isolation valves and the regulating and bypass valves.
This is open item (OI) 2.2. This is OI 2.2.
2.3.4.6.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff has identified an open item requiring resolution prior to final approval of this safety evaluation.
2.3.4.7 Feedwater Heater Drains & Vents System 2.3.4.7.1 Summary of Technical Information in the Application LRA Section 2.3.4.7 describes the feedwater heater drains & vents system, which improves overall plant efficiency by preheating condensate and feedwater pumped from the condenser hotwell to the steam generators. The feedwater heater drains & vents system functions:
* To maintain a proper water level in the feedwater heaters and drain tanks of the moisture separator reheaters (MSRs)
* To provide an alternate drain path directly to the main condenser from each MSR feedwater heater and drain tank
* To improve steam cycle thermal efficiency by either cascading feedwater heater drains to the next lower heater or, in the case of Feedwater Heater 4, by pumping drains forward into the feedwater pump suction
* To remove noncondensable gases during start-up and normal operation from each feedwater heater and MSR
* To provide operational and start-up venting of the feedwater heaters and MSRs
* To drain feedwater heater shells and MSRs during start-up and shutdown The system equipment includes two heater drain pumps, level control instrumentation, MSR drain tanks, piping, valves, breakers, controllers, and transmitters. The feedwater heater drains
& vents system has components conservatively assumed to meet 10 CFR 54.4(a)(2) criteria based on their quality class designation and, therefore, included within the scope of license renewal. These are nonsafety-related civil and electrical components.
The failure of nonsafety-related SSCs in the feedwater heater drains & vents system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.4.7.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.7 and FSAR Section 10.4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to 2-208
 
verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.7.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the feedwater heater drains & vents system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.8 Auxiliary Feedwater System 2.3.4.8.1 Summary of Technical Information in the Application LRA Section 2.3.4.8 describes the AFW system, a backup for supplying feedwater to the secondary side of the steam generators when the normal feedwater system is not available to maintain steam generator heat sink capabilities. The system is an alternative to the feedwater system during start-up, hot standby, and cool-down and also functions as an engineered safeguards system. In the latter function, the AFW system is directly relied upon to prevent core damage in transients like loss of normal feedwater or a secondary system pipe rupture. The AFW system has one turbine-driven and two motor-driven pumps with valves, piping, controls, electrical components, and instrumentation. The system components are located in the RAB except a portion of the supply piping to the steam generators in the containment building.
The AFW system I&Cs are designed for automatic operation during emergency situations (e.g.,
steam line rupture, loss of normal feedwater, loss of offsite power) and manual operation as parts of the safe shutdown systems. The motor-driven AFW pumps are started automatically by any one of the following signals: safety injection signal, low-low water level in any steam generator, loss of power (undervoltage) on the emergency bus, loss of both feedwater pumps, or ATWS mitigating system actuation circuitry. The turbine-driven AFW Pump is started automatically by any one of the following signals: loss of power (undervoltage) on the emergency bus, low-low water level in two of three steam generators, or ATWS mitigating system actuation circuitry.
The AFW system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the AFW system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the AFW system performs functions that support fire protection, ATWS, SBO, and EQ.
LRA Table 2.3.4-7 identifies AFW system component types within the scope of license renewal and subject to an AMR:
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* AFW pump turbine
* AFW pump turbine lube oil cooler components
* AFW pump turbine lube oil cooler tubes
* AFW pump turbine lube oil pump
* AFW pump turbine lube oil tank
* AFW pumps
* closure bolting
* containment isolation piping and components
* flow-restricting elements
* piping, piping components, and piping elements The intended functions of the AFW system component types within the scope of license renewal include:
* heat transfer
* pressure-boundary
* throttle 2.3.4.8.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.8 and FSAR Section 10.4.9 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.8.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the AFW system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.9 Auxiliary Steam Condensate System 2.3.4.9.1 Summary of Technical Information in the Application LRA Section 2.3.4.9 describes the auxiliary steam condensate system designed to receive the condensed steam from the process equipment supplied with auxiliary steam. The system consists of two condensate tanks in the WPB, each with one condensate pump, and one condensate tank in the RAB with two condensate pumps. The pumps discharge to the auxiliary 2-210
 
boiler deaerator or, if the boiler is not in operation, to the main condenser. The auxiliary steam condensate tanks are maintained at approximately atmospheric pressure by a vent header connected to the main condenser. The demineralized water system provides to the system makeup water which the system mixes with condensate from the auxiliary steam CSTs, deaerates, heats, and then pumps into the auxiliary boiler. To detect radioactivity leakage from other systems, the system has radiation monitors. Receipt of a high radiation alarm alerts the operator to the presence of leakage so additional radiation surveys, sampling, and equipment isolation can locate and repair the leakage source. The auxiliary steam condensate system performs no safety-related function, has no impact on plant power production, and is not required to operate during or following design-basis accidents.
The failure of nonsafety-related SSCs in the auxiliary steam condensate system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.4-8 identifies auxiliary steam condensate system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the auxiliary steam condensate system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.9.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.9 and FSAR Section 10.4.1.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.9.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary steam condensate system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.10 Condensate System 2.3.4.10.1 Summary of Technical Information in the Application 2-211
 
LRA Section 2.3.4.10 describes the condensate system, which by two 50-percent capacity motor-driven condensate pumps returns water from the main condenser hotwell to the feedwater system through the gland seal steam condenser and the full-flow condensate demineralizer to the suction of two 50-percent condensate booster pumps. The condensate system has a bypass between the condensate demineralizer inlet and outlet headers. The condensate booster pumps discharge through two trains of four low-pressure feedwater heaters to the feedwater pumps. The condenser hotwell has a storage capacity of approximately five minutes of full-load operation, sufficient to allow condensate supply for the make-up of steam generator inventory during a full external electrical load rejection. Condensate make-up is supplied to the condenser hotwell from the CST through a level control valve. Excess condensate is discharged to the CST through a level control valve from the discharge of either the condensate pumps or the condensate booster pumps. Condensate pumps, condensate booster pumps, and main feedwater pumps are protected against flashing at the pump suction by electrical interlocks which trip the respective pumps on low-suction pressure. System equipment includes condensate pumps, condensate booster pumps, level and flow instrumentation, piping, valves, breakers, transmitters, and controllers.
The failure of nonsafety-related SSCs in the condensate system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.4-9 identifies condensate system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the condensate system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.10.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.10 and FSAR Section 10.4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.10.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the condensate system components within the scope of license renewal, as required by 2-212
 
10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.11 Condensate Storage System 2.3.4.11.1 Summary of Technical Information in the Application LRA Section 2.3.4.11 describes the condensate storage system, which supplies condensate to the condenser hotwell from the CST through a level control valve from the discharge of either the condensate pumps or the condensate booster pumps. The CST is designed:
* To provide makeup and surge capacity for secondary system inventory changes due to various plant conditions
* To store sufficient water for reactor shutdown decay heat removal by the AFW system
* To provide flush water for radwaste treatment equipment During initial fill of the condensate system, the condensate transfer pump discharges into the condenser hotwell. During normal plant operation, condensate flows by gravity and differential pressure from the CST to the condenser hotwell. Two level control valves maintain the water level in the hotwell automatically. To preserve the minimum CST inventory for operation of the AFW system, all nonseismic piping connections are above the minimum water level required for AFW supply. Water is added to the tank by a control valve in the CST makeup line.
Safety-related CST water level indicators and alarms are in the control room. CST level transmitters are RG 1.97 Category 1 components. The condensate storage system consists of one 100-percent capacity condensate transfer pump, one safety-related, stainless steel CST, piping, valves, and instrumentation.
The CST below the elevation of the condensate transfer pump suction nozzle and the supply piping between the tank and the AFW pumps are Safety Class 3 and seismic Category I. A concrete enclosure protects the tank from tornado, hurricane, and missile damage and from postulated pipe breaks. The CLB dictates that in a loss of offsite power sufficient CST usable inventory must be available to bring the plant from full-power to hot standby conditions, maintain the plant at hot standby conditions for six hours, and then cool the RCS to 325 &deg;F in six hours. The condensate storage system has nonsafety-related components that could cause an adverse physical interaction with safety-related equipment, nonsafety-related piping components connected to and supporting the safety-related functional boundary of the system, or both. These components are within the scope of license renewal as determined by the 10 CFR 54.4(a)(2) review. The system also has components conservatively assumed to meet 10 CFR 54.4(a)(2) criteria based on their quality class and, therefore, included within the scope of license renewal.
The condensate storage system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the condensate storage system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the condensate storage system performs functions that support fire protection, SBO, and EQ.
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LRA Table 2.3.4-10 identifies condensate storage system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* CST
* piping, piping components, and piping elements The intended function of the condensate storage system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.11.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.11 and FSAR Sections 9.2.6 and 10.4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.11.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the condensate storage system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.12 Secondary Sampling System 2.3.4.12.1 Summary of Technical Information in the Application LRA Section 2.3.4.12 describes the secondary sampling system, which continuously monitors liquid and steam purity in the steam cycle systems, including the condensate, heater drains and vents, feedwater, steam generator blowdown, and main steam systems, and the CST. The secondary sampling system sets the sample temperature and pressure to allow proper sample parameter analysis, maintains the sample flow at proper velocity, signals alarms when required, continuously displays and records selected parameters, and provides grab sampling. The secondary sampling system is designed to analyze most sample points continuously for specific chemical parameters and record the results for trending purposes.
The system provides a central location to obtain samples from the secondary cycle during startup, power operation, and plant shutdown operations for chemical and radiochemical analyses. Chemical analyses are the bases for proper secondary chemistry control to eliminate 2-214
 
loss of turbine capacity, to detect steam generator, feedwater heater, and condenser tube failures, and to treat corrosion problems. The secondary sampling system is not essential for safe plant shutdown and serves no safety function as it is not required to achieve safe shutdown or mitigate the consequences of an accident.
The secondary sampling system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the secondary sampling system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the secondary sampling system performs functions that support EQ.
LRA Table 2.3.4-11 identifies secondary sampling system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* containment isolation piping and components
* heat exchanger shell side components
* piping, piping components, and piping elements The intended function of the secondary sampling system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.12.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.12 and FSAR Section 9.3.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.12.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the secondary sampling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.3.4.13 Steam Generator Wet Lay Up System 2.3.4.13.1 Summary of Technical Information in the Application LRA Section 2.3.4.13 describes the steam generator wet lay up system, which maintains chemistry conditions only during wet lay up of the steam generators to reduce steam generator corrosion during inactive periods. The system is nonsafety; however, several instrument valves of level transmitters have a safety-related quality classification. The steam generator wet lay up system consists of three centrifugal pumps in the RAB, piping and valves, a wet lay up grab sample panel, and a local control panel. System crossties to the feedwater, AFW, and steam generator blowdown systems allow the steam generator wet lay up system to circulate water through the steam generator. The steam generator chemical addition system in conjunction with the steam generator wet lay up system maintains wet lay up chemistry. As use of the steam generator wet lay up system during shutdown conditions only involves several unusual system connections, piping spool pieces connect to other systems for positive isolation before normal steam generator operation commences.
The steam generator wet lay up system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the steam generator wet lay up system potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.3.4-12 identifies steam generator wet lay up system component types within the scope of license renewal and subject to an AMR:
* closure bolting
* piping, piping components, and piping elements The intended function of the steam generator wet lay up system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.13.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.13 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.13.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components 2-216
 
subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the steam generator wet lay up system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.14 Turbine System 2.3.4.14.1 Summary of Technical Information in the Application LRA Section 2.3.4.14 describes the turbine system, which includes the tandem compound, four-flow exhaust, 1800-rpm turbine unit. The steam produced in the steam generators passes first through the high-pressure turbine, which is a double-flow design where steam from the four governor valves enters the turbine through four inlet pipes that feed four double-flow nozzle chambers. Steam passes through the single control stage and flows through reaction blading where it is expanded and then exhausted to the moisture separator reheaters located alongside the low-pressure turbines on the turbine building operating floor. The MSRs remove the moisture content and superheat the steam before it enters the low-pressure turbines, taking steam for reheating from the main steam system header. From the low-pressure turbines the steam is exhausted to the main condenser.
The turbine system includes turbine bearings, rupture diaphragms, covers, glands, turning gear, electrical components, and supervisory instrumentation. The system has pressure instrumentation valves with a safety-related quality classification for steam supply to the AFW pump turbine.
The turbine system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the turbine system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the turbine system performs functions that support ATWS.
LRA Table 2.3.4-13 identifies turbine system component types within the scope of license renewal and subject to an AMR:
* piping, piping components, and piping elements The intended function of the turbine system component types within the scope of license renewal is to provide a pressure-retaining boundary.
2.3.4.14.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.14 and FSAR Section 10.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with 2-217
 
intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.14.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.15 Digital-Electric Hydraulic System 2.3.4.15.1 Summary of Technical Information in the Application LRA Section 2.3.4.15 describes the digital-electric hydraulic (DEH) system, which positions the turbine steam inlet valves to regulate the flow of steam through the turbine. The DEH system is divided into three subsystems, the fluid subsystem, the emergency trip subsystem, and a control subsystem. The function of the DEH fluid supply subsystem is to provide high-pressure fluid as a motive force to the turbine steam inlet valve actuators. The actuators position 16 turbine steam valves in response to electric commands from the DEH electronic controller. The fluid subsystem consists of a reservoir assembly with controls, pumps, motors, filters, and heat exchangers. The DEH control fluid is triarylphosphate ester selected for its fire resistance and stability. The main function of the DEH control subsystem is to position the turbine inlet valves to control turbine speed or output. The system has valves, filters, heat exchangers, valve operators, pumps, strainer, reservoir, power supplies, motors, and switches.
The DEH system contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the DEH system potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the DEH system performs functions that support ATWS.
2.3.4.15.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.15 and FSAR Section 10.2.2.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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2.3.4.15.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the DEH system components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3.4.16 Turbine-Generator Lube Oil System 2.3.4.16.1 Summary of Technical Information in the Application LRA Section 2.3.4.16 describes the turbine-generator lube oil system, which supplies clean oil lubrication to the turbine, generator, and turning gear bearings and seal backup oil to the seal oil system. It also interacts with the DEH system high-pressure emergency trip header. The turbine-generator lube oil system includes a main oil pump, seal oil pump, normal bearing oil pump, emergency bearing oil pump, vapor extractors, a lube oil reservoir, a lube oil conditioner, piping, filters, valves, electrical components, and instrumentation. The main oil pump is shaft-driven by the turbine; with the unit online, this pump supplies all required lubricating oil.
The lube oil conditioner removes free water, particulate matter, and other contaminants from the lubrication oil. Lube oil exits an ejector where part of the flow goes back to the main oil pump suction and the remainder goes through a lube oil cooler, which uses service water for cooling. The turbine-generator lube oil system has components conservatively assumed to meet 10 CFR 54.4(a)(2) criteria based on their quality class designation and, therefore, included within the scope of license renewal. These are electrical components; no mechanical components meet the scoping requirements for license renewal.
The failure of nonsafety-related SSCs in the turbine-generator lube oil system potentially could prevent the satisfactory accomplishment of a safety-related function.
2.3.4.16.2 Staff Evaluation The staff reviewed LRA Section 2.3.4.16 and FSAR Section 10.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3.4.16.3 Conclusion The staff reviewed the LRA, FSAR, and drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In 2-219
 
addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine-generator lube oil system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4 Scoping and Screening Results - Structures This section documents the staffs review of the applicants scoping and screening results for structures. Specifically, this section discusses:
* containment building
* other Class I and in-scope structures In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive, long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its methodology, the staffs review focused on the implementation results. This approach allowed the staff to confirm that there were no omissions of SCs that meet the scoping criteria and are subject to an AMR.
The staffs evaluation of the information in the LRA was the same for all structures. The objective was to determine whether the applicant has identified, in accordance with 10 CFR 54.4, components and supporting structures for structures that appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicants screening results to verify that all passive, long-lived SCs were subject to an AMR in accordance with 10 CFR 54.21(a)(1).
In its scoping evaluation, the staff reviewed the applicable LRA sections and drawings, focusing on components that have not been identified as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the FSAR, for each structure to determine whether the applicant has omitted from the scope of license renewal components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed the licensing basis documents to determine whether the LRA specified all intended functions delineated under 10 CFR 54.4(a). The staff requested additional information to resolve any omissions or discrepancies identified.
After its review of the scoping results, the staff evaluated the applicants screening results. For those SCs with intended functions, the staff sought to determine whether (1) the functions are performed with moving parts or a change in configuration or properties or (2) the SCs are subject to replacement after a qualified life or specified time period, as described in 10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that these SCs were subject to an AMR, as required by 10 CFR 54.21(a)(1). The staff requested additional information to resolve any omissions or discrepancies identified.
2.4.1 Containment Building LRA Section 2.4.1 identifies the containment building SCs subject to an AMR for license renewal.
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The applicant described the supporting SCs of the containment building in the following LRA sections:
* 2.4.1.1          containment structure
* 2.4.1.2          containment internal structures
* 2.4.1.3          containment building functions The staffs findings on review of LRA Sections 2.4.1.1 - 2.4.1.3 are in SER Sections 2.4.1.1 -
2.4.1.3, respectively.
2.4.1.1 Containment Structure 2.4.1.1.1 Summary of Technical Information in the Application LRA Section 2.4.1.1 describes the containment structure. The Unit 1 containment structure consists of a steel-lined, reinforced concrete structure in the form of a vertical right cylinder with a hemispherical dome and a flat base with a recess beneath the reactor vessel. The structure is not post-tensioned. The 4.5-ft. thick cylindrical wall measures 160 ft. in height from the liner on the base to the spring line of the dome and has an inside diameter of 130 ft. The inside radius of the 2-ft., 6-in. thick dome is equal to that of the cylinder so the discontinuity at the spring line due to the change in thickness is on the outer surface. The circular base mat is a conventionally-reinforced structural concrete slab of 12 ft. uniform thickness. The top of the mat is 44 ft. below finished grade. The entire mat is structurally independent of adjacent seismic Category I foundations. The mat has recesses in the central portion (i.e., the reactor cavity) to house the reactor pressure vessel and containment sump and in the ESF areas to form the ESF system sumps.
The foundation mat inside the containment and including the reactor cavity and containment sump is covered with carbon steel liner plate. A 5-ft. thick concrete internal mat over the liner protects and supports internal primary and secondary shield walls. The base mat is supported on a concrete working slab supported on a concrete seal mat which is supported on rock and is covered by a waterproofing membrane. The continuous welded steel liner plate functions primarily as a leak-tight membrane to limit the release of radioactive materials into the environment. The nominal liner plate is 3/8 in. thick in the cylinder, 1/4 in. thick on the bottom, 1/2 in. thick in the dome, and 1 in. thick near the crane girder brackets. Ring collars up to 2 in.
thick around penetrations are welded to the penetration sleeves. The liner is anchored to the concrete shell by anchor studs fusion welded to the liner plate to form part of the containment structure.
The one-inch liner plate at the crane girder brackets area is anchored into the concrete wall with shear lugs, anchor bolts connected to embedded plates, special anchorages, and studs. A waterproofing membrane located below the base mat and working slab terminates at water stops at the joints with adjacent structures. The seismic gaps between adjacent structures are cut off from groundwater by double rows of horizontal water stops to prevent intrusion of moisture against the inaccessible portions of the containment structure liner below the base slab and a moisture barrier seal inside containment prevents the intrusion of moisture between the containment liner plate and the concrete floor foundation mat. Piping through penetrations is insulated. Type I mechanical piping hot penetrations have insulation to prevent 2-221
 
high-temperature conditions in the concrete surrounding them. Several Type II cold penetrations have insulation not within the scope of license renewal because the concrete surrounding them always will be below the maximum local area temperature of 200&deg;F.
The containment structure performs functions that support fire protection.
2.4.1.1.2 Staff Evaluation The staff reviewed LRA Section 2.4.1.1 and FSAR Sections 3.8.2, 3.8.2.1.3, and 3.8.2.1.4.1 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4, Scoping and Screening Results: Structures.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staffs review of LRA Section 2.4.1.1 identified areas in which additional information was necessary to complete the review of the applicants scoping and screening results. The applicant responded to the staffs RAIs as discussed below.
In RAI 2.4-1 dated August 7,2007, the staff noted that LRA Section 2.4.1.1 Containment Structure refers to:
The welded attachments to the metallic liner (e.g., floor beams, seismic restraints, leak channels, equipment/pipe supports, etc.) do not perform a pressure retaining function associated with the containment vessel. For this reason, the welded attachments are not included with the liner components.
These welded attachments are evaluated with the specific commodity groups.
From LRA Table 2.4.1-1, it was not clear to the staff what specific commodity groups the applicant referred to. Therefore, the staff requested that the applicant identify these specific component commodity groups, as well as their intended functions, for the welded attachments.
In its response dated September 5, 2007, the applicant provided a table including the component/commodity groups from LRA Table 2.4.1-1 and the specific component and their intended functions for the welded attachments to the metallic liner.
Based on its review, the staff finds the applicants response to RAI 2.4-1 acceptable because it adequately identified the specific component commodity groups and their intended functions for the welded attachments to the metallic liner. Therefore, the staffs concern described in RAI 2.4-1 is resolved.
In RAI 2.4-2 dated August 7, 2007, the staff noted that LRA Section 2.4.1.1 states that the insulation for Type II cold penetrations is not within the scope of license renewal because the concrete surrounding the penetration will always be below the maximum local area temperature of 200 EF. The staff requested that the applicant state the criteria employed for determining the 2-222
 
inclusion of insulation within the scope of license renewal.
In its response dated September 5, 2007, the applicant stated:
The criteria employed for determining the inclusion of insulation within the scope of License Renewal was based on ensuring HNP concrete temperatures did not exceed 150 EF in general areas or 200 EF local areas in order to align with the guidance of NUREG-1801, Item II.AI-1. The review for the Containment Structure determined that insulation was required on the hot piping (>200 EF) in the Type I hot pipe penetrations to maintain the concrete structure cylinder wall temperature below 200 EF (for a License Renewal "C-3" protection intended function) as discussed in FSAR Sections 3.8.1.1.3.3 and Section 3.8.2.1.3. The review for the Containment Structure determined the Type II cold penetrations were provided for low temperature lines (<200 EF) and on some HVAC penetrations and groups of small diameter lines (e.g., instrument and sampling) based on FSAR Sections 3.8.1.1.3.3 and Section 3.8.2.1.4.1. Insulation that was installed on several of these lines was not credited with maintaining the concrete cylinder wall temperature below 200 EF and was therefore not included in the scope of License Renewal. However, after further review of design documents, the operating temperature of several of these small diameter lines in Type II cold penetrations was determined to exceed 200 EF. Therefore, the insulation on these hot small diameter lines in Type II penetrations will be included in the scope of License Renewal within the Component/Commodity group Insulation (Hot Pipe Penetrations) in LRA Table 2.4.1-1. LRA Subsection 2.4.1.1, Page 2.4-7, will be revised to include the insulation on these hot, small diameter lines in Type II penetrations in the scope of License Renewal. LRA Section 3.5 will be revised as required to include the insulation on these hot small diameter lines in Type II cold penetrations. Also, Plant-Specific Note 509 will be revised to include the small diameter lines in Type II penetrations.
By letter dated September 24, 2007, the applicant responded further:
Revise the final paragraph in LRA Subsection 2.4.1.1 on Page 2.4-7 to read:
Insulation is provided on various piping going through pipe penetrations. Type I mechanical piping hot penetrations and several Type II mechanical penetrations with small diameter lines have insulation installed to prevent high temperature conditions in the concrete surrounding the penetrations.
Also revise LRA Subsection 3.5.2.2.1.3 on Page 3.5-31 by deleting the word "hot" from the fourth sentence (two places). In addition, revise Plant-Specific Note 509 to read:
509 The HNP AMR methodology concluded that the insulation for penetrations in the Containment air environment has no aging effects.
Based on its review, the staff finds the applicants response to RAI 2.4-2 acceptable because the applicant adequately explained the criteria employed for determining the inclusion of insulation within the scope of license renewal. The applicant further reviewed the design 2-223
 
documents, and the operating temperature of several of small diameter lines in Type II cold penetrations which were determined to exceed 200 EF. The applicant decided to include the insulation on these hot, small diameter lines in Type II penetrations within the scope of license renewal. The applicant also provided a corresponding revision to the LRA. Therefore, the staffs concern described in RAI 2.4-2 is resolved.
2.4.1.1.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal.
The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.1.2 Containment Internal Structures 2.4.1.2.1 Summary of Technical Information in the Application LRA Section 2.4.1.2 describes the containment internal structures, the concrete and structural steel components of which are enclosed by the containment structure. The containment internal structures support NSSS equipment during all operational phases. In the unlikely event of an accident, these structures mitigate its effects by protecting safety-related equipment. The containment internal structures have masonry walls for radiation shielding and equipment shelter/protection. Main floors in the containment are linked by stairs and one service elevator.
Except in equipment laydown areas, floors and stairs are of grating construction to minimize the effects of pressure differentials across their boundaries in a sudden change in pressure.
Structural steel framing is supported by the secondary shield wall and by steel columns. The structural steel commodity group includes the structural steel which supports the main grating floors and the concrete areas, the bolting, exposed portions of anchorages, the monorails that support monorail hoists and polar crane support girders and brackets, and the support steel and monorail for the integrated reactor vessel head cable bridge hoist on the operating floor.
Other steel commodity groups include the following commodities and supports: cable tray and conduit, HVAC ducts, racks, panels, cabinets, floor drains, fire hose stations, fuel transfer tube bellows assembly, refueling pool liner, nonfire doors, support members and anchorages, the integrated reactor vessel head steel assemblies, and HVAC damper mountings.
2.4.1.2.2 Staff Evaluation The staff reviewed LRA Section 2.4.1.2 and FSAR Section 5.4.14 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with 2-224
 
the requirements of 10 CFR 54.21(a)(1).
2.4.1.2.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment internal structures SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.1.3 Containment Building Functions 2.4.1.3.1 Summary of Technical Information in the Application LRA Section 2.4.1.3 describes the containment building functions of shelter and support for plant equipment within the scope of license renewal and, for the containment structure and containment internal structures, a passive heat sink in containment pressure-temperature analyses. The containment building is a barrier to fission product release following postulated design-basis accidents. Containment building structures are barriers to fire, flooding, water spray, high-energy fluid release, and potential missiles.
The containment building functions contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the containment building functions potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the containment building performs functions that support fire protection.
LRA Table 2.4.1-1 identifies containment building function component types within the scope of license renewal and subject to an AMR:
* anchorage and embedment
* cable tray, conduit HVAC ducts, tube track
* concrete: above grade - dome, wall, ring girder, basement
* concrete: below grade - wall, basement
* concrete: containment internal
* concrete: foundation
* concrete: foundation, subfoundation
* damper mountings
* expansion bellows
* fire hose stations
* floor drains
* insulation (hot pipeline penetrations) 2-225
* integrated reactor vessel head steel assemblies
* jib cranes
* masonry walls
* nonfire doors
* penetration bellows
* penetration sleeves
* personnel airlock; equipment hatch; personnel emergency airlock (includes passive components)
* platforms, pipe-whip restraints, jet impingement shields, masonry wall supports, and other miscellaneous structures
* polar crane
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* reactor cavity manipulator crane
* seals and gaskets
* seals, gaskets, and moisture barriers
* steel components: all structural steel
* steel components: fuel pool liner (including attachments)
* steel elements: liner, liner anchors, integral attachments
* sump screens
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components
* supports for RCS primary components (includes reactor vessel, steam generator, pressurizer, RCP)
The intended functions of the containment building functions component types within the scope of license renewal include:
* spray shield or curbs for directing flow
* thermal expansion, seismic separation, or both
* rated fire barrier to confine or retard plant fire from spreading
* flood protection barrier
* SBO or design-basis accident heat sink
* missile barrier
* pipe whip restraint/high-energy line break shielding
* safety-related component shelter/protection 2-226
* radiation shielding
* pressure boundary or essentially leak-tight barrier to protect public health and safety in postulated design-basis events
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.1.3.2 Staff Evaluation The staff reviewed LRA Section 2.4.1.3 and FSAR Sections 3.8.1, 3.8.2. 3.8.3, and 6.2.1 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.1.3.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment building function SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2 Other Class I and In-Scope Structures LRA Section 2.4.2 identifies the other Class I and in-scope structure SCs subject to an AMR for license renewal.
The applicant described the supporting SCs of the other Class I and in-scope structures in the following LRA sections:
* 2.4.2.1        RAB
* 2.4.2.2        auxiliary reservoir channel
* 2.4.2.3        auxiliary dam and spillway
* 2.4.2.4        auxiliary reservoir
* 2.4.2.5        auxiliary reservoir separating dike
* 2.4.2.6        cooling tower
* 2.4.2.7        CTMU water intake channel
* 2.4.2.8        circulating water intake structure
* 2.4.2.9        diesel generator building
* 2.4.2.10        main dam and spillway 2-227
* 2.4.2.11        diesel fuel oil storage tank building
* 2.4.2.12        ESW & CTMU intake structure
* 2.4.2.13        ESW discharge channel
* 2.4.2.14        ESW discharge structure
* 2.4.2.15        ESW intake channel
* 2.4.2.16        FHB
* 2.4.2.17        HVAC equipment room
* 2.4.2.18        outside the power block structures
* 2.4.2.19        main reservoir
* 2.4.2.20        security building
* 2.4.2.21        ESW screening structure
* 2.4.2.22        NSW intake structure
* 2.4.2.23        switchyard relay building
* 2.4.2.24        transformer and switchyard structures
* 2.4.2.25        turbine building
* 2.4.2.26        tank area/building
* 2.4.2.27        WPB
* 2.4.2.28        yard structures The staffs findings on review of LRA Sections 2.4.2.1 - 2.4.2.28 are in SER Sections 2.4.2.1 -
2.4.2.28, respectively.
2.4.2.1 Reactor Auxiliary Building 2.4.2.1.1 Summary of Technical Information in the Application LRA Section 2.4.2.1 describes the RAB, which consists of the Unit 1 RAB (RAB-1), the common building (RAB-Common), and the completed part of the Unit 2 RAB (RAB-2). The RAB-Common building includes the control room at floor elevation 305 ft. designed as an envelope with positive pressure and minimum air leakage during normal plant operation and design-basis accidents. Control room openings (i.e., doors and penetrations) have a low-leakage design. An access to RAB-Common from the RAB-2 area was provided at elevation 236 ft. via an access bay. The access bay structure and the retaining walls are seismically designed. Seismic analysis of the as-built RAB-2 was performed to obtain seismic response spectra for the structure to verify the design of safety-related piping and systems within the structure. An ESW pipe tunnel is at elevation 216 ft. and runs within RAB-1 and RAB-Common through RAB-2. A steam tunnel approximately 40 ft. wide with a pipe restraint steel frame and a steel platform houses main steam, feedwater, and AFW system piping and runs from the containment penetration area through the RAB-1 roof slab. RAB-1, RAB-2, and RAB-Common are independent and separated by sufficient gaps to preclude any interaction due to seismic events. The buildings are also separated by gaps from adjacent structures except where the containment building mat and the RAB mat at elevation 190 ft. are against each other to prevent movement of the containment building mat vertical cantilevered leg.
There are no adjacent non-Category I buildings to impair the integrity of the seismic Category I RAB.
The RAB contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the RAB potentially could prevent the 2-228
 
satisfactory accomplishment of a safety-related function. In addition, the RAB performs functions that support fire protection.
LRA Table 2.4.2-1 identifies RAB component types within the scope of license renewal and subject to an AMR:
* anchorage and embedment
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* control room ceiling
* damper mountings
* fire barrier assemblies
* fire barrier penetration seals
* fire hose stations
* fire-rated doors
* floor drains
* masonry walls
* nonfire doors
* phase bus enclosure assemblies
* platforms, pipe-whip restraints, jet impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* raised floor
* roof: membrane/built-up
* seals and gaskets
* seismic joint filler
* steel components: all structural steel
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components The intended functions of the RAB component types within the scope of license renewal include:
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* spray shield or curbs for directing flow
* rated fire barrier to confine or retard plant fire from spreading
* flood protection barrier
* SBO or design-basis accident heat sink
* heat transfer
* missile barrier
* pipe whip restraint/high-energy line break shielding
* pressure-retaining boundary
* safety-related component shelter/protection
* radiation shielding
* pressure boundary or essentially leak-tight barrier to protect public health and safety in postulated design-basis events
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.1.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.1 and FSAR Sections 3.8.4.1.2 and 3.8.4.9 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.1.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RAB SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.2 Auxiliary Reservoir Channel 2.4.2.2.1 Summary of Technical Information in the Application LRA Section 2.4.2.2 describes the approximately 1,570-ft. long and 140-ft. wide auxiliary 2-230
 
reservoir channel located northwest of the plant within the auxiliary reservoir with a wall slope of two horizontal to one vertical in soil and one horizontal to four vertical in rock. The auxiliary reservoir channel connects the east and west arms of the auxiliary reservoir so ESW discharge can flow from the east to the west before circulating back to the intake area for a longer flow path and more cooling for the water. The auxiliary reservoir channel, designed and constructed to seismic Category I criteria, is included in the flow path for water circulating in the auxiliary reservoir and has the same functions as the auxiliary reservoir, which supplies water for the fire protection system and is the primary source of cooling water during emergency operation and the ultimate heat sink to dissipate the ESW system heat load.
The auxiliary reservoir channel contains safety-related components relied upon to remain functional during and following DBEs. In addition, the auxiliary reservoir channel performs functions that support fire protection.
LRA Table 2.4.2-2 identifies auxiliary reservoir channel component types within the scope of license renewal and subject to an AMR:
* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds The intended functions of the auxiliary reservoir channel component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both to safety-related components 2.4.2.2.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.2 and FSAR Sections 2.4.8, 2.5.0.6, and 9.2.5 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.2.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary reservoir channel SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.4.2.3 Auxiliary Dam and Spillway 2.4.2.3.1 Summary of Technical Information in the Application LRA Section 2.4.2.3 describes the auxiliary dam and spillway located across the Tom Jack Creek arm of the main reservoir adjacent to the southwest boundary of the plant site. The auxiliary dam impounds a reservoir with a minimum normal water level at elevation 250 ft. and a surface area of approximately 317 acres. A random rockfill dam approximately 3,903 ft. long with a maximum structural height of approximately 72 ft. and a crest at elevation 260 ft., the auxiliary dam has a core of compacted silty clay and clayey silt material protected on each side by a transition filter zone and a random rockfill shell. The downstream shell has two horizontal drainage blankets, each 3 ft. thick, connected to the transition filter zone adjacent to the core of the dam and a 200-ft. wide, 3-ft. thick drainage layer under the shell in each of two areas where pre-existing creeks had been located. The spillway is an uncontrolled concrete ogee section with a crest length of 170 ft. and crest at elevation 252 ft. The ogee crest of the spillway is joined to the stilling basin by a sloping apron. The auxiliary reservoir serves the ESW system and supplies water for the fire protection system. The auxiliary reservoir must remain operational under the safe shutdown earthquake condition; consequently, the auxiliary dam is a seismic Category I structure.
The auxiliary dam and spillway contains safety-related components relied upon to remain functional during and following DBEs. In addition, the auxiliary dam and spillway performs functions that support fire protection.
LRA Table 2.4.2-3 identifies auxiliary dam and spillway component types within the scope of license renewal and subject to an AMR:
* concrete: exterior above grade
* concrete: exterior below grade
* earthen water-control structure: dams, embankments, reservoirs, channels, canals, and ponds The intended functions of the auxiliary dam and spillway component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.3.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.3 and FSAR Sections 2.5.0.6, 2.5.6, and 9.2.5 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any 2-232
 
SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.3.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary dam and spillway SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.4 Auxiliary Reservoir 2.4.2.4.1 Summary of Technical Information in the Application LRA Section 2.4.2.4 describes the auxiliary reservoir, which is impounded by the auxiliary dam across the Tom Jack Creek basin and is located to the west of the plant site. It has a minimum normal water level at elevation 250 ft. and a surface area of approximately 317 acres. An auxiliary separating dike across the east arm of this reservoir acts as a barrier to prevent discharged ESW from flowing directly back to the ESW intake area. The auxiliary reservoir channel conveys ESW from the east arm into the west arm of the reservoir so that maximum cooling can be attained before the discharged water circulates back to the intake area. The auxiliary reservoir must remain operative under the safe shutdown earthquake condition. The auxiliary reservoir is the primary sources of cooling water during emergency operation to dissipate the ESW system heat load and serves as the UHS for the plant.
The auxiliary reservoir contains safety-related components relied upon to remain functional during and following DBEs. In addition, the auxiliary reservoir performs functions that support fire protection.
LRA Table 2.4.2-4 identifies auxiliary reservoir component types within the scope of license renewal and subject to an AMR:
* earthen water-control structures: dams, embankments, reservoirs, channels, canals and ponds The intended functions of the auxiliary reservoir component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2-233
 
2.4.2.4.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.4 and FSAR Sections 2.4.8, 2.5.0.6, and 2.5.6 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.4.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary reservoir SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.5 Auxiliary Reservoir Separating Dike 2.4.2.5.1 Summary of Technical Information in the Application LRA Section 2.4.2.5 describes the auxiliary reservoir separating dike located west of the power plant within the auxiliary reservoir and about 1,700 ft. north of the auxiliary dam between the ESW intake area and the ESW discharge area. The auxiliary reservoir separating dike is approximately 1,200 ft. long with a maximum height of approximately 55 ft. and outside slopes of 2.5 horizontal to one vertical. The dike has a core of compacted silty clay and clayey silt material protected by a random rockfill shell graded near the core with adjacent finer materials.
The auxiliary reservoir separating dike along with the auxiliary reservoir channel control the flow of discharged ESW through the east and west arms of the auxiliary reservoir. The dike, designed and constructed across the east arm of the reservoir to seismic Category I criteria, prevents discharged ESW from flowing directly back to the ESW intake area. The auxiliary reservoir separating dike is in the flow path of water circulating in the auxiliary reservoir and has the same functions as the auxiliary reservoir.
The auxiliary reservoir separating dike contains safety-related components relied upon to remain functional during and following DBEs. In addition, the auxiliary reservoir separating dike performs functions that support fire protection.
LRA Table 2.4.2-5 identifies auxiliary reservoir separating dike component types within the scope of license renewal and subject to an AMR:
* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds 2-234
 
The intended functions of the auxiliary reservoir separating dike component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.5.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.5 and FSAR Sections 2.5.0.6 and 2.5.6 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.5.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary reservoir separating dike SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.6 Cooling Tower 2.4.2.6.1 Summary of Technical Information in the Application LRA Section 2.4.2.6 describes the cooling tower located east of the turbine building and approximately 550 ft. from the closest seismic Category I structure, the diesel generator building. The cooling tower is a 523-ft. tall, hyperbolic, natural draft, counterflow, evaporative-type tower. Its basin has an internal diameter of 405 ft., is constructed of 10-in.
thick concrete, and has a working capacity of approximately 5,400,000 gallons. The maximum depth, approximately 7.5 ft, is at the basin walls. Normal water level is approximately one foot below the top of the basin side walls.
The cooling tower is a heat sink for the CWS and the NSW system. Heated circulating water and service water are cooled by the counterflow, natural-draft, hyperbolic cooling tower. The cooling tower makeup water pumps deliver water from the main reservoir to restore losses due to drift, evaporation, and blowdown. The cooling tower is a major CWS component. Cooling water is routed from the cooling tower basin to the circulating water pump intake structure. The 2-235
 
NSW pumps also take suction from the cooling tower basin via a concrete intake box. The cooling tower is not a Class I structure and supports no safety-related functions.
The cooling tower also performs functions that support fire protection.
LRA Table 2.4.2-6 identifies cooling tower component types within the scope of license renewal and subject to an AMR:
* anchorage and embedment
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* pipe
* supports for non-ASME piping and components The intended functions of the cooling tower component types within the scope of license renewal are structural support, functional support, or both for nonsafety-related components.
2.4.2.6.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.6 and FSAR Section 10.4.5 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.6.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the cooling tower SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.7 Cooling Tower Makeup Water Intake Channel 2.4.2.7.1 Summary of Technical Information in the Application LRA Section 2.4.2.7 describes the CTMU water intake channel, which extends from the main reservoir to the ESW & CTMU intake structure located southeast of the plant. The CTMU water intake channel is approximately 2,500 ft. long and 45 ft. wide. Its walls have a slope of two horizontal to one vertical in soil and one horizontal to four vertical in rock on the north side and 2-236
 
two horizontal to one vertical in rock on the south side. The CTMU water intake channel is a Class I structure. During normal operation, the main reservoir is a storage reservoir primarily as the source for CTMU water and an alternative source of ESW supply.
The CTMU water intake channel contains safety-related components relied upon to remain functional during and following DBEs.
LRA Table 2.4.2-7 identifies CTMU water intake channel component types within the scope of license renewal and subject to an AMR:
* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds The intended functions of the CTMU water intake channel component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components 2.4.2.7.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.7 and FSAR Sections 2.5.6 and 3.8.4.1.12 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.7.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the CTMU water intake channel SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.8 Circulating Water Intake Structure 2.4.2.8.1 Summary of Technical Information in the Application LRA Section 2.4.2.8 describes the circulating water intake structure located east of the power block and attached to the cooling tower basin. Constructed of reinforced concrete, the structure 2-237
 
includes the reinforced concrete canal that extends to it from the cooling tower basin. The canal is approximately 104 feet wide at the basin and narrows to 66 ft. wide at the structure. The structure supports the circulating water pumps and includes the reinforced concrete slab and containment wall for the sodium hypochlorite tank and dispersant tank adjoining the outside of the south wall of the canal. The circulating water intake structure is not Class I and supports no safety-related functions.
The circulating water intake structure also performs functions that support fire protection.
LRA Table 2.4.2-8 identifies circulating water intake structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedment
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation The intended functions of the circulating water intake structure component types within the scope of license renewal are structural support, functional support, or both for nonsafety-related components.
2.4.2.8.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.8 and FSAR Section 10.4.5 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.8.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the circulating water intake structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.9 Diesel Generator Building 2.4.2.9.1 Summary of Technical Information in the Application LRA Section 2.4.2.9 describes the diesel generator building located east of the turbine building 2-238
 
as a reinforced concrete structure approximately 153 ft. long and 114 ft. wide and constructed on concrete fill founded on suitable rock. The diesel generator building is constructed of concrete cast in place with reinforced concrete exterior and interior shear walls and floors.
Nonshear interior walls of reinforced concrete or concrete masonry (block) are not load-bearing.
The diesel generator building houses the two stand-by diesel generators, day tanks, silencers, and associated equipment.
The diesel generator building contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel generator building potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the diesel generator building performs functions that support fire protection.
LRA Table 2.4.2-9 identifies diesel generator building component types within the scope of license renewal and subject to an AMR:
* anchorage and embedment
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* damper mountings
* fire barrier penetration seals
* fire hose stations
* fire-rated doors
* floor drains
* masonry walls
* nonfire doors
* phase bus enclosure assemblies
* platforms, pipe-whip restraints, jet impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up
* seals and gaskets
* steel components: all structural steel 2-239
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for EDG, HVAC system components, and other miscellaneous mechanical equipment
* supports for non-ASME piping and components The intended functions of the diesel generator building component types within the scope of license renewal include:
* spray shield or curbs for directing flow
* rated fire barrier to confine or retard plant fire from spreading
* flood protection barrier
* missile barrier
* safety-related component shelter/protection
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.9.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.9 and FSAR Section 3.8.4.1.5 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.9.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel generator building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.10 Main Dam and Spillway 2.4.2.10.1 Summary of Technical Information in the Application LRA Section 2.4.2.10 describes the main dam and spillway located on Buckhorn Creek approximately 0.7 miles south of its confluence with White Oak Creek, 4.5 miles south of the plant site, and about 2.5 miles north of the Cape Fear River. The dam is a seismic Category I, zone embankment, rockfill structure. The main dam is approximately 1,550 ft. long, founded on rock, and has a maximum height of approximately 108 ft. and a core of compacted silty clay 2-240
 
and clayey silt material protected on each side by two 8-ft. thick fine and coarse filter zones and a rockfill shell. The primary purpose of the main dam is to impound water for the CWS and NSW systems. The main dam impounds a reservoir with a normal water level at elevation 220 ft. and a water surface area of approximately 4,000 acres. During normal operation, the main reservoir functions as a storage reservoir, the source of CTMU water, and an alternative source of ESW supply.
The main dam and spillway contain safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the main dam and spillway potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.4.2-10 identifies main dam and spillway component types within the scope of license renewal and subject to an AMR:
* anchorage and embedment
* concrete: exterior above grade
* concrete: exterior below grade
* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds
* platforms, pipe-whip restraints, jet impingement shields, masonry wall supports, and other miscellaneous structures
* structural steel (water control structures)
The intended functions of the main dam and spillway component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.10.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.10 and FSAR Sections 2.5.0.6 and 2.5.6 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.10.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the 2-241
 
applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the main dam and spillway SCs within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.11 Diesel Fuel Oil Storage Tank Building 2.4.2.11.1 Summary of Technical Information in the Application LRA Section 2.4.2.11 describes the diesel fuel oil storage tank building located north of the FHB and consisting of a below-grade reinforced concrete structure with two reinforced concrete diesel oil tanks (or compartments) and two transfer pumps. The structure is 94 ft. long, 86 ft.
wide, and 24 ft. high including the foundation mat; the top slab is at elevation 263 ft. Access to the pumps is by two stairwells located at each corner of one end of the building. The building is supported on a reinforced concrete foundation mat founded on sound rock.
The diesel fuel oil storage tank building contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the diesel fuel oil storage tank building potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the diesel fuel oil storage tank building performs functions that support fire protection.
LRA Table 2.4.2-11 identifies diesel fuel oil storage tank building component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* damper mountings
* fire barrier penetration seals
* fire-rated doors
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up
* supports for ASME Classes 1, 2, and 3 piping and components 2-242
* supports for non-ASME piping and components The intended functions of the diesel fuel oil storage tank building component types within the scope of license renewal include:
* rated fire barrier to confine or retard plant fire from spreading
* missile barrier
* safety-related component shelter/protection
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.11.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.11 and FSAR Sections 3.8.4.1 and 3.8.4.9 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.11.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the diesel fuel oil storage tank building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.12 Emergency Service Water and Cooling Tower Makeup Intake Structure 2.4.2.12.1 Summary of Technical Information in the Application LRA Section 2.4.2.12 describes the ESW & CTMU intake structure located at the northern end of the CTMU water intake channel. Cooling water may be drawn from either the auxiliary or the main reservoir to the ESW & CTMU intake structure. The ESW & CTMU intake structure extends to include the retaining walls at its south end but not the electrical manholes at its east and west ends or the CTMU strainer pit at its northeast end.
The ESW & CTMU intake structure contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the ESW &
CTMU intake structure potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the ESW & CTMU intake structure performs functions that support fire protection.
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LRA Table 2.4.2-12 identifies ESW & CTMU intake structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* damper mountings
* fire barrier penetration seals
* nonfire doors
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* seals and gaskets
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components The intended functions of the ESW & CTMU intake structure component types within the scope of license renewal include:
* rated fire barrier to confine or retard plant fire from spreading
* flood protection barrier
* missile barrier
* safety-related component shelter/protection
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.12.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.12 and FSAR Section 3.8.4.1.12 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
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The staffs review of LRA Section 2.4.2.12 identified an area in which additional information was necessary to complete the review of the applicants scoping and screening results. The applicant responded to the staffs RAI as discussed below.
In RAI 2.4-3 dated August 7, 2007, the staff noted that LRA Table 2.4.2-12 does not include screens and stop logs. Therefore, the staff requested that the applicant clarify whether screens and stop logs are within the scope of license renewal. If screens and stop logs are not within the scope of license renewal, the staff further requested that the applicant provide justification for their exclusion from within the scope of license renewal.
In its response dated September 5, 2007, the applicant stated:
Stop logs are not in the scope of License Renewal. Stop logs have a non-safety related classification and are not normally installed unless there is a need to dewater one of the bays during an outage. They have no License Renewal intended function.
Traveling screens which are installed in four of the bays in the Emergency Service Water and Cooling Tower Makeup Intake Structure were reviewed as mechanical components. Refer to response to RAI 2.3.3.31-4.
Coarse screens (or trash racks) are installed in each of the bays in the Emergency Service Water and Cooling Tower Makeup Intake Structure. The coarse screens are included in the scope of License Renewal as "Other Miscellaneous Structure" in the commodity/component group "Platforms, Pipe Whip Restraints, Jet Impingement Shields, Masonry Wall Supports, and Other Miscellaneous Structures (includes support members, welds, bolted connections, support anchorage to building structure)" in LRA Table 2.4.2-12 with a C-7 intended function.
The Fine screens are not in the scope of License Renewal. The Fine screens have a non-safety related classification, are installed only for limited time periods during out of structure maintenance of the traveling screens, and have no License Renewal intended function.
As additional information, the Emergency Service Water Screening Structure also has stop logs and fine screens which are not in the scope of License Renewal and coarse screens which are in the scope of License Renewal. The traveling screens were reviewed as mechanical components.
As a result of this RAI, a revision to the LRA is required to incorporate a line item into the AMR tables for the Emergency Service Water and Cooling Tower Makeup Intake Structure and the Emergency Service Water Screening Structure to address the coarse screens in a raw water environment.
In its response dated September 27, 2007, the applicant responded further:
Revise LRA Table 3.5.2-13 and 3.5.2-22 to add for component/commodity 2-245
 
        "Platforms, Pipe Whip Restraints, Jet Impingement Shields, Masonry Wall Supports, and Other Miscellaneous Structures (includes support members, welds, bolted connections, support anchorage to building structure)" a new material/environment for carbon steel in a raw water environment as follows:
Raw Water    Loss of Material    Structures Monitoring  III.A6-11  3.5.1-47    E, 515, (T-21)                575 Add new Plant-Specific Note 575 to read:
575 HNP utilizes the Structures Monitoring Program instead of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program for inspections of the coarse screens in a Raw Water environment.
Add the following after the first sentence in the discussion column of LRA Table 3.5.1, Item 3.5.1-47:
However, HNP uses the Structures Monitoring Program for the coarse screens in raw water at the Emergency Service Water and Cooling Tower Makeup Intake Structure and Emergency Service Water Screening Structure.
Based on its review, the staff finds the applicants response to RAI 2.4-3 acceptable because the applicant adequately identified screens and stop logs in the ESW and CTMU intake structure. The applicant also provided a revision to the LRA as a result of RAI 2.4-3. Therefore, the staffs concerns described in RAI 2.4-3 are resolved.
2.4.2.12.3 Conclusion The staff reviewed the LRA, FSAR, RAI responses, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal.
The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW & CTMU intake structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.13 Emergency Service Water Discharge Channel 2.4.2.13.1 Summary of Technical Information in the Application LRA Section 2.4.2.13 describes the ESW discharge channel located northwest of the plant. The ESW discharge channel is approximately 2,170 ft. long and varies in width from 50 to 80 ft. The channel walls have a slope of two horizontal to one vertical in soil and one horizontal to four vertical in rock. The ESW discharge channel is designed conservatively to carry the service flow 2-246
 
required for normal and emergency shutdown of the plant. Water is returned to the auxiliary reservoir through the ESW discharge channel over a weir located in the ESW discharge structure. The ESW discharge channel is designed and constructed to seismic Category I criteria and included in the flow path for water circulating back to the auxiliary reservoir; therefore, it has some of the same cooling water functions as the auxiliary reservoir.
The ESW discharge channel contains safety-related components relied upon to remain functional during and following DBEs. In addition, the ESW discharge channel performs functions that support fire protection.
LRA Table 2.4.2-13 identifies ESW discharge channel component types within the scope of license renewal and subject to an AMR:
* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds The intended functions of the ESW discharge channel component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.13.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.13 and FSAR Sections 2.4.8, 2.5.0.6, 2.5.6, and 3.8.4.1.12 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.13.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW discharge channel SCs within the scope of license renewal, as required by 2-247
 
10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.14 Emergency Service Water Discharge Structure 2.4.2.14.1 Summary of Technical Information in the Application LRA Section 2.4.2.14 describes the ESW discharge structure located at the east end of the ESW discharge channel. The seismic Category I, missile-proof, reinforced concrete ESW discharge structure is founded on sound rock. The structure is as designed with four bays; however, only two bays are in use for the single-unit plant. The pipe penetrations in the east wall for the other bays are closed off. The bottom mat is at elevation 240 ft. with a concrete curb to elevation 242 ft. and a concrete wall or weir to elevation 256 ft. The walls extend to elevation 262 ft. The overall dimensions are approximately 26.5 ft. by 51 ft. Cooling water from the plant is returned to the auxiliary reservoir over a weir in the ESW discharge structure through the ESW discharge channel. The ESW discharge structure is included in the flow path for water circulating back to the auxiliary reservoir and, therefore, has some of the same cooling water functions as the auxiliary reservoir.
The ESW discharge structure contains safety-related components relied upon to remain functional during and following DBEs. In addition, the ESW discharge structure performs functions that support fire protection.
LRA Table 2.4.2-14 identifies ESW discharge structure component types within the scope of license renewal and subject to an AMR:
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation The intended functions of the ESW discharge structure component types within the scope of license renewal include:
* flood protection barrier
* SBO or design-basis accident heat sink
* missile barrier
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.14.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.14 and FSAR Sections 3.8.4.1.12 and 3.8.4.9 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
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During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.14.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW discharge structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.15 Emergency Service Water Intake Channel 2.4.2.15.1 Summary of Technical Information in the Application LRA Section 2.4.2.15 describes the ESW intake channel located southwest of the plant and extending from the auxiliary reservoir to the ESW screening structure. The intake channel is approximately 3,580 ft. long and 50 ft. wide. The channel bottom slopes down to elevation 231 ft at the intake screening structure. The channel walls have a slope of two horizontal to one vertical in soil and one horizontal to four vertical in rock. Designed and constructed to seismic Category I criteria, the ESW intake channel also is designed conservatively to carry the water flow required for normal and emergency shutdown of the plant. The channel is included in the flow path for water circulating from the auxiliary reservoir to the ESW screening structure and has the same cooling water functions as the auxiliary reservoir. The auxiliary reservoir functions as the plant UHS and as the primary source of cooling water during emergency operation to dissipate the ESW system heat load.
The ESW intake channel contains safety-related components relied upon to remain functional during and following DBEs. In addition, the ESW intake channel performs functions that support fire protection.
LRA Table 2.4.2-15 identifies ESW intake channel component types within the scope of license renewal and subject to an AMR:
* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds The intended functions of the ESW intake channel component types within the scope of license renewal include:
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* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.15.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.15 and FSAR Sections 2.4.8, 2.5.0.6, 2.5.6, and 3.8.4.1.12 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.15.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW intake channel SCs within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.16 Fuel Handling Building 2.4.2.16.1 Summary of Technical Information in the Application LRA Section 2.4.2.16 describes the FHB, a reinforced concrete, seismic Category I structure supported on a 10-ft. thick foundation mat founded on suitable rock. The exterior walls, shear walls, interior columns, and floor slabs are reinforced concrete structures cast in place.
Nonshear interior shielding or partition walls of either reinforced concrete or concrete block are not load-bearing. Changes to plant configuration as results of the cancellation of Units 2, 3, and 4 were as described in FSAR Section 3.8.4.9. To retain the seismic characteristics and to maintain the structural integrity of the building, its major structural components, namely foundation mat, floor slabs, and shear and load bearing walls, were constructed as designed for four units. Only the internal nonload-bearing walls and some penetrations and openings in the slabs and walls have been modified in the area reserved for Units 2, 3 and 4. As RABs and containment buildings for Units 2, 3, and 4 have been cancelled, the FHB has been isolated from the plant grade fill by a retaining wall on the west side and a series of retaining walls on the east side where required. The building stability and structural design have been reviewed for additional wind and tornado loads to satisfy design criteria. The retaining walls west and 2-250
 
east of the FHB are designed seismically.
The FHB contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the FHB potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the FHB performs functions that support fire protection and contains component parts of the EQ Program.
LRA Table 2.4.2-16 identifies FHB component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* canal and pool gates
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* damper mountings
* expansion bellows
* fire barrier assemblies
* fire barrier penetration seals
* fire hose stations
* fire-rated doors
* floor drains
* fuel cask handling crane
* fuel handling bridge crane
* FHB auxiliary crane
* masonry walls
* new fuel storage rack
* nonfire doors
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up 2-251
* seals and gaskets
* seismic joint filler
* spent fuel storage racks
* steel components: fuel pool liner (including attachments)
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components The intended functions of the FHB component types within the scope of license renewal include:
* neutron absorption
* thermal expansion, seismic separation, or both
* rated fire barrier to confine or retard plant fire from spreading
* missile barrier
* safety-related component shelter/protection
* radiation shielding
* pressure boundary or essentially leak-tight barrier to protect public health and safety in postulated design-basis events
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.16.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.16 and FSAR Sections 3.8.4.1.3, 3.8.4.9, and 3.8.5.1.3 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of LRA Section 2.4.2.16 identified an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as discussed below.
In RAI 2.4-4 dated August 7, 2007, the staff noted that LRA Section 2.4.2.16 "Fuel Handling Building" states:
Design criteria have been used to assure that the collapse of adjacent 2-252
 
non-seismic Category I structures would not impair the integrity of the seismic Category I structures or components should an earthquake occur.
The staff requested that the applicant specify what design criteria have been used and explain how these design criteria can assure that the collapse of adjacent non-seismic Category I structures would not impair the integrity of the seismic Category I structures or components.
In its response dated September 5, 2007, the applicant stated:
As stated in FSAR Section 3.7.2.8A, The following criteria were used to assure that the collapse of non-Seismic Category I structures would not impair the integrity of adjacent Seismic Category I structures or components:
a) Sufficient separation has been maintained between Seismic Category I and non-Seismic Category I structures, or b) The partial or complete collapse of these structures will not impair the integrity of any of the neighboring Seismic Category I structures or components, or c) The failure or collapse of non-Seismic Category I structures is prevented under SSE conditions.
As discussed in FSAR Section 3.7.2.8A, the plant arrangement provides for sufficient distance between Seismic Category I structures, systems, and components and non-Seismic Category I structures, except for the Turbine Building, the retaining wall west of the Fuel Handling Building, and the retaining wall east of the Fuel Handling Building by the Unit 2 Reactor Auxiliary Building.
The Turbine Building, the retaining wall west of the Fuel Handling Building, and the retaining wall east of the Fuel Handling Building are seismically designed in accordance with Regulatory Guide 1.29, Positions C.2 and C.4. More detail is provided in FSAR Sections 3.7.2.8A and 3.8.4.9.
Based on its review, the staff finds the applicant's response to RAI 2.4-4 acceptable because it adequately explained the design criteria used to assure that the collapse of non-Seismic Category I structures would not impair the integrity of adjacent Seismic Category I structures or components. Therefore, the staff's concern described in RAI 2.4-4 is resolved.
2.4.2.16.3 Conclusion The staff reviewed the LRA, FSAR, RAI response, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal.
The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the FHB SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.4.2.17 HVAC Equipment Room 2.4.2.17.1 Summary of Technical Information in the Application LRA Section 2.4.2.17 describes the HVAC equipment room located on the roof of the RAB-Common structure. The HVAC equipment room is a pre-engineered metal siding building housing HVAC equipment for the computer and communications rooms and for the emergency response facility information system. Battery racks and batteries are located within a masonry enclosure in the building. The steel framing is anchored to the roof slab at elevation 324 ft. on the RAB Common area roof. There is a fire protection hose rack inside; however, the HVAC equipment room is supported on a fire barrier slab which isolates it from the control room area.
The building is not a Class I structure and supports no safety-related functions. The collapse of any nonseismic Category I structure like the HVAC equipment room would not impair the integrity of adjacent seismic Category I structures or components.
The HVAC equipment room performs functions that support fire protection and SBO.
LRA Table 2.4.2-17 identifies HVAC equipment room component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* concrete: interior
* fire hose stations
* masonry walls
* nonfire doors
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up
* siding
* steel components: all structural steel
* supports for non-ASME piping and components The intended functions of the HVAC equipment room component types within the scope of license renewal are structural support, functional support, or both for nonsafety-related components.
2.4.2.17.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.17 and FSAR Section 9.4.9 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any 2-254
 
SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.17.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the HVAC equipment room SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.18 Outside the Power Block Structures 2.4.2.18.1 Summary of Technical Information in the Application LRA Section 2.4.2.18 describes the OPB structures created during the license renewal review to refer to safety-related main plant structure portions that have no safety-related components in them. OPB structures are defined as power block structure portions west of column line N between column lines 27 and 73 and east of column line L between column lines 45 and 73.
The common N, L, and 45 line walls between the OPB and the FHB are included and scoped as part of the FHB in LRA Section 2.4.2.16. No safety-related equipment is located west of the N line wall or east of the L line wall north of column line 45. The OPB structures have no safety-related components within their boundaries but OPB structural components are required to maintain the structural design conditions of the FHB, the RAB, and the WPB.
In addition, the failure of nonsafety-related SCs in the OPB structures potentially could prevent the satisfactory accomplishment of a safety-related function.
LRA Table 2.4.2-18 identifies OPB structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures; this commodity group includes only the tie rods on the west retaining wall 2-255
 
The intended functions of the OPB structures component types within the scope of license renewal include:
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.18.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.18 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.18.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the OPB structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.19 Main Reservoir 2.4.2.19.1 Summary of Technical Information in the Application LRA Section 2.4.2.19 describes the main reservoir formed by the construction of a seismic Category I dam and spillway on Buckhorn Creek to form a lake of approximately 4,000 acres at the normal water level of 220 ft. During normal operation, the main reservoir is a storage reservoir in use primarily as the source for CTMU water and as the alternative source of ESW supply or UHS cooling water. The technical specification minimum main reservoir level is 215 ft.
to meet water requirements for safety-related heat exchangers cooled by the ESW system. The unit is shut down if the main reservoir water level falls below 215 ft.
The main reservoir contains safety-related components relied upon to remain functional during and following DBEs.
LRA Table 2.4.2-19 identifies main reservoir component types within the scope of license renewal and subject to an AMR:
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* earthen water-control structures: dams, embankments, reservoirs, channels, canals, and ponds The intended functions of the main reservoir component types within the scope of license renewal include:
* SBO or design-basis accident heat sink
* cooling water source for plant shutdown
* structural support, functional support, or both for safety-related components 2.4.2.19.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.19 and FSAR Sections 2.4.8, 2.5.0.6, 2.5.6 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.19.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the main reservoir SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.20 Security Building 2.4.2.20.1 Summary of Technical Information in the Application LRA Section 2.4.2.20 describes the security building, a nonseismic Category I structure located southeast of the turbine building and the entrance to the protected area. The building is approximately 72 ft. wide by 246 ft. long, constructed on a concrete footing and a concrete slab, and has masonry walls, a structural steel support system, and a combination of stone and metal siding as the fascia. The building houses the security metal detection, explosive detection, x-ray equipment, turnstiles for processing personnel into the protected area, the personnel and security systems for protecting the plant, and self-survey personnel monitoring equipment for health physics. The east portion of the building is built over an electrical cable trench that supports and protects cables required for restoration from an SBO.
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The security building also performs functions that support fire protection.
LRA Table 2.4.2-20 identifies security building component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* masonry walls
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* steel components: all structural steel
* supports for EDG, HVAC system components, and other miscellaneous mechanical equipment
* supports for non-ASME piping and components The intended functions of the security building component types within the scope of license renewal are structural support, functional support, or both for nonsafety-related components.
2.4.2.20.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.20 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.20.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the security building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and 2-258
 
those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.21 Emergency Service Water Screening Structure 2.4.2.21.1 Summary of Technical Information in the Application LRA Section 2.4.2.21 describes the ESW screening structure located at the eastern end of the ESW intake channel and constructed of reinforced concrete. It contains eight bays separated by reinforced concrete walls. Only two bays are used for the ESW system. Each ESW bay is 8 ft. 2 in. wide and sized for a 7-ft. wide traveling screen. In addition to a traveling screen, each bay contains one coarse screen, one stop log guide, two fine screen guides, and access manholes. A valve pit with butterfly valves and expansion joints is at the rear of the structure. A reinforced concrete enclosure covers the deck to protect the traveling screens and valve pit from tornado missiles. A reinforced concrete skimmer wall at the front of the intake structure extends to elevation 247.5 ft. and prevents ice and floating trash from entering the intake structure. Water drawn from the ESW intake channel through the ESW screening structure is transported by gravity through steel pipes to the ESW & CTMU intake structure.
The pipe penetrations against yard fill in the other bays are closed off. One electric motor-driven fire pump and one diesel engine-driven fire pump suitable for outdoor operation are installed outdoors at opposite ends of the ESW screening structure. Two fire service screen wash pumps installed on the ESW screening structure take suction from the auxiliary reservoir.
Two fire protection jockey pumps are located on the structure. Also included in this structure are (1) the concrete foundation, slab, and dike for the diesel engine-driven fire pump and its diesel oil storage tank located south of the ESW screening structure, (2) the foundation and wall for the motor-driven fire pump and valve pit north of the ESW screening structure, and (3) the retaining walls at each end of the ESW screening structure. The dike around the diesel fuel oil storage tank is designed to contain fuel oil and direct the flow to a sump.
The ESW screening structure contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the ESW screening structure potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the ESW screening structure performs functions that support fire protection.
LRA Table 2.4.2-21 identifies ESW screening structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab 2-259
* fire barrier penetration seals
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* seals and gaskets
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components The intended functions of the ESW screening structure component types within the scope of license renewal include:
* spray shield or curbs for directing flow
* rated fire barrier to confine or retard plant fire from spreading
* flood protection barrier
* missile barrier
* safety-related component shelter/protection
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.21.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.21 and FSAR Section 3.8.4.1.12 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.21.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESW screening structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.22 Normal Service Water Intake Structure 2.4.2.22.1 Summary of Technical Information in the Application 2-260
 
LRA Section 2.4.2.22 describes the reinforced concrete NSW intake structure located east of the diesel generator building and north of the cooling tower. The NSW intake structure is approximately 50 ft. by 44 ft. with four bays and supports two NSW pumps. Water is drawn from the cooling tower basin to the NSW intake structure via a 6-ft. diameter underground concrete pipe that in the vicinity of the NSW intake structure branches into three separate lines, two of which are routed to the NSW intake structure via 6 ft. by 10 ft. connections. The third pipe, which would have connected to HNP Unit 2, terminates at a concrete plug and block.
The normal service water intake structure also performs functions that support fire protection.
LRA Table 2.4.2-22 identifies NSW intake structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* supports for non-ASME piping and components The intended function of the NSW intake structure component types within the scope of license renewal is to provide structural support, functional support, or both for nonsafety-related components.
2.4.2.22.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.22 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.22.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the NSW intake structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a),
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and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.23 Switchyard Relay Building 2.4.2.23.1 Summary of Technical Information in the Application LRA Section 2.4.2.23 describes the prefabricated metal switchyard relay building located on a concrete slab southeast of the turbine building inside the fenced 230kV switchyard and supporting, housing, and protecting electrical equipment. Supervisory control systems in the 230kV switchyard relay building continuously transmit 230kV parameters to the Progress Energy Carolinas Control Center. The control of all 230kV circuit breakers for the generator and start-up transformers is administered from the plant control room. The switchyard has in the switchyard relay building two 125-volt direct current systems independent of the plant direct current systems, each with a 125-volt battery and battery charger to furnish the control power for the circuit breakers, and one additional battery charger as a spare.
The switchyard relay building also performs functions that could be relied on during postulated SBO events.
LRA Table 2.4.2-23 identifies switchyard relay building component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: foundation
* concrete: interior
* nonfire doors
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up
* siding
* steel components: all structural steel The intended function of the switchyard relay building component types within the scope of license renewal is structural support, functional support, or both for nonsafety-related components.
2.4.2.23.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.23 and FSAR Section 8.2 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA 2-262
 
and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.23.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the switchyard relay building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.24 Transformer and Switchyard Structures 2.4.2.24.1 Summary of Technical Information in the Application LRA Section 2.4.2.24 describes the transformer and switchyard structures, which include the 230kV switchyard and transformer structures, the isolated phase bus system support structures, and the 6.9kV nonsegregated phase bus support structures. The transformer yard structures located east of the turbine building include the foundations for the main, start-up, and unit auxiliary transformers and the foundations and miscellaneous structural steel for supporting high-voltage insulators, the 230kV low-pressure oil-filled cables, and the isolated phase bus system between the transformers and the turbine building. The transformer and switchyard structures include the concrete trenches for the 230kV low-pressure oil-filled cable from the start-up transformers to the 230kV switchyard.
The failure of nonsafety-related SCs in the transformer and switchyard structures potentially could prevent the satisfactory accomplishment of a safety-related function. The transformer and switchyard structures also perform functions that support fire protection and SBO events.
LRA Table 2.4.2-24 identifies transformer and switchyard structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* phase bus enclosure assemblies
* platforms, pipe-whip restraints, jet impingement shields, masonry wall supports, and 2-263
 
other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* steel components: all structural steel The intended functions of the transformer and switchyard structures component types within the scope of license renewal include:
* rated fire barrier to confine or retard plant fire from spreading
* structural support, functional support, or both for nonsafety-related components 2.4.2.24.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.24 and FSAR Sections 8.1 and 8.2 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.24.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the transformer and switchyard structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.25 Turbine Building 2.4.2.25.1 Summary of Technical Information in the Application LRA Section 2.4.2.25 describes the turbine building, which is approximately 400 ft. long, 166 ft.
wide, and 74 ft. high from the top of the foundation mat. Below elevation 261 ft., the structure is of reinforced concrete slab and wall construction. Above elevation 261 ft. the building is constructed of steel and concrete slab on steel frame and metal decking and has no walls or roof. The reinforced concrete turbine pedestal is the dominant structural feature of the building.
The turbine building has a 215-ton gantry crane with a 50-ton auxiliary hoist. The gantry crane with auxiliary hoist is classified as nonsafety-related, augmented-quality equipment not within the scope of license renewal.
2-264
 
The turbine building contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the turbine building potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the turbine building performs functions that support fire protection, ATWS, and SBO.
LRA Table 2.4.2-25 identifies turbine building component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* battery rack
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* damper mountings
* fire barrier penetration seals
* fire hose stations
* fire-rated doors
* floor drains
* masonry walls
* nonfire doors
* phase bus enclosure assemblies
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* steel components: all structural steel
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components The intended functions of the turbine building component types within the scope of license renewal include:
* spray shield or curbs for directing flow
* rated fire barrier to confine or retard plant fire from spreading
* missile barrier
* pipe whip restraint/high-energy line break shielding
* safety-related component shelter/protection
* radiation shielding
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2-265
 
2.4.2.25.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.25 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.25.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.26 Tank Area/Building 2.4.2.26.1 Summary of Technical Information in the Application LRA Section 2.4.2.26 describes the tank area/building, which includes the Unit 1 and Unit 2 tank area/buildings. The Unit 1 tank area/building, a reinforced concrete seismic Category I structure approximately 142 ft. long by 63 ft. wide, and 83 ft. high, is adjacent to and south of the RAB-1 and east of the WPB. The top of the roof, which protects against missiles, is at approximately elevation 319 ft. The foundation mat is 8 ft. thick, founded on suitable rock, and located 24 ft. below the finished grade elevation of 260 ft. The Unit 1 tank area/building has cast-in-place reinforced concrete exterior walls, interior shear walls, and floors supported on shear walls, beams, and columns. Nonshear interior shielding or partition walls of either reinforced concrete or concrete block walls are not load-bearing.
The exterior walls are waterproofed on the backfill face from the top of the mat to one foot below grade level; the waterproofing membrane terminates in reglets. All construction joints in exterior walls in contact with backfill have water stops. The tank area/building structures are separated from other buildings by sufficient gaps to preclude any interaction due to seismic events. There are no adjacent non-seismic Category I buildings to impair the integrity of the seismic Category I tank area/building structures or components.
The tank area/building contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the tank area/building potentially could prevent the satisfactory accomplishment of a safety-related function. In 2-266
 
addition, the tank area/building performs functions that support fire protection and SBO and has component parts of the EQ program.
LRA Table 2.4.2-26 identifies tank area/building component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* fire barrier penetration seals
* fire hose stations
* fire-rated doors
* masonry walls
* platforms, pipe-whip restraints, jet impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up
* supports for ASME Classes 1, 2, and 3 piping and components
* supports for non-ASME piping and components The intended functions of the tank area/building component types within the scope of license renewal include:
* rated fire barrier to confine or retard plant fire from spreading
* missile barrier
* safety-related component shelter/protection
* radiation shielding
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.26.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.26 and FSAR Sections 3.8.4.1.6 and 3.8.4.9 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with 2-267
 
the requirements of 10 CFR 54.21(a)(1).
2.4.2.26.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the tank area/building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4.2.27 Waste Processing Building 2.4.2.27.1 Summary of Technical Information in the Application LRA Section 2.4.2.27 describes the WPB, a reinforced concrete, seismic Category I structure with reinforced concrete exterior walls and interior shear walls cast in place. Nonshear interior shielding or partition walls of either reinforced concrete or concrete block are not load-bearing.
The WPB is 289 ft. long, 191 ft. wide, and 110 ft. high. Reinforced concrete floors are at elevations 236 ft., 261 ft., 276 ft., and 291 ft. and the roof at 321 ft. The building is supported on a 10-ft. thick reinforced concrete foundation mat founded on suitable rock. The exterior walls below grade are waterproofed on the backfilled faces. Construction joints in exterior walls in contact with backfill except for a portion of the northwest corner of the building are waterproofed with water stops. The WPB provides barriers to fire, flooding, water spray, high-energy fluid release, and potential missile barriers.
The WPB contains safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the WPB potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the WPB performs functions that support fire protection.
LRA Table 2.4.2-27 identifies WPB component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* concrete: roof slab
* damper mountings
* fire barrier penetration seals
* fire hose stations 2-268
* fire-rated doors
* masonry walls
* nonfire doors
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* roof: membrane/built-up
* seals and gaskets
* seismic joint filler
* steel components: all structural steel
* supports for non-ASME piping and components The intended functions of the WPB component types within the scope of license renewal include:
* spray shield or curbs for directing flow
* rated fire barrier to confine or retard plant fire from spreading
* missile barrier
* radiation shielding
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.27.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.27 and FSAR Sections 3.8.4.1.4 and 3.8.4.9 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.27.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the WPB SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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2.4.2.28 Yard Structures 2.4.2.28.1 Summary of Technical Information in the Application LRA Section 2.4.2.28 describes the yard structures, which comprise the civil structures and structural components within the scope of license renewal identified by review of the HNP FSAR, drawings, and equipment database and by onsite walkdowns resulting in a list of structures evaluated for license renewal as either yard structures or miscellaneous structures.
The yard structures include:
* underground electrical duct banks, protective mats, and manholes
* yard lighting poles, electrical duct banks, and manholes
* the oil separator area
* the diesel fuel unloading area
* fire hose cabinet support structures
* NSW gate structure
* NSW concrete pipe
* cooling tower blowdown system weir structure
* CWS concrete pipe
* CWS discharge block With the exception of the Class I duct banks, manholes, and protective mats, the yard structures listed are not Class I or seismic Category I structures and support no safety-related functions. There is sufficient distance between them that collapse of any of the listed nonseismic Category I structures would not impair the integrity of adjacent seismic Category I structures or components.
The yard structures contain safety-related components relied upon to remain functional during and following DBEs. In addition, the yard structures perform functions that support fire protection.
LRA Table 2.4.2-28 identifies yard structure component types within the scope of license renewal and subject to an AMR:
* anchorage and embedments
* cable tray, conduit, HVAC ducts, tube track
* concrete: exterior above grade
* concrete: exterior below grade
* concrete: foundation
* concrete: interior
* fire hose stations
* lighting poles
* pipe
* platforms, pipe-whip restraints, jet-impingement shields, masonry wall supports, and 2-270
 
other miscellaneous structures
* racks, panels, cabinets, and enclosures for electrical equipment and instrumentation
* seals and gaskets
* siding
* steel components: all structural steel
* supports for non-ASME piping and components The intended functions of the yard structure component types within the scope of license renewal include:
* missile barrier
* safety-related component shelter/protection
* structural support, functional support, or both for safety-related components
* structural support, functional support, or both for nonsafety-related components 2.4.2.28.2 Staff Evaluation The staff reviewed LRA Section 2.4.2.28 and FSAR Section 3.8.4.1.11 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.
During its review, the staff evaluated the structural component functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any SCs with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those SCs that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived SCs subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.4.2.28.3 Conclusion The staff reviewed the LRA, FSAR, and related structural components to determine whether the applicant failed to identify any SCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the yard structure SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.5 Scoping and Screening Results - Electrical and Instrumentation and Controls (I&C)
Systems This section documents the staffs review of the applicants scoping and screening results for electrical and I&C systems. Specifically, this section discusses:
* electrical and I&C component commodity groups 2-271
 
In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive, long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its methodology, the staffs review focused on the implementation results. This focus allowed the staff to confirm that there were no omissions of electrical and I&C system components that meet the scoping criteria and are subject to an AMR.
The staffs evaluation of the information in the LRA was the same for all electrical and I&C systems. The objective was to determine whether the applicant has identified, in accordance with 10 CFR 54.4, components and supporting structures for electrical and I&C systems that appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicants screening results to verify that all passive, long-lived components were subject to an AMR in accordance with 10 CFR 54.21(a)(1).
In its scoping evaluation, the staff reviewed the applicable LRA sections, focusing on components that have not been identified as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the FSAR, for each electrical and I&C system to determine whether the applicant has omitted from the scope of license renewal components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed the licensing basis documents to determine whether the LRA specified all intended functions delineated under 10 CFR 54.4(a).
After its review of the scoping results, the staff evaluated the applicants screening results. For those SCs with intended functions, the staff sought to determine whether (1) the functions are performed with moving parts or a change in configuration or properties or (2) the SCs are subject to replacement after a qualified life or specified time period, as described in 10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that these SCs were subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.5.1 Electrical and I&C Component Commodity Groups 2.5.1.1 Summary of Technical Information in the Application LRA Section 2.5.1 describes the electrical and I&C component commodity groups, which include:
* non-EQ insulated cables and connections
* metal enclosed bus and connections
* high-voltage insulators
* switchyard buses and connections
* transmission conductors and connections
* uninsulated ground conductors and connections An insulated cable is an assembly of an electrical conductor (e.g., wire) with an insulation 2-272
 
covering or a combination of conductors insulated from one another with overall coverings.
Connections or terminations connect the cable conductors to other cables or electrical devices.
Connections include connectors, splices, and terminal blocks. Fuse holders are a type of electrical connection similar to a terminal block. Insulated cables and connections inside the enclosure of an active device (e.g., motor leads and connections and cables and connections internal to relays, chargers, switchgear, transformers, power supplies, etc.) maintained along with the other subcomponents and piece-parts inside the enclosure are not included in the non-EQ insulated cables and connections commodity group.
Metal enclosed buses and their connections connect two or more elements (e.g., electrical equipment like switchgear and transformers) of an electrical circuit. The metal enclosed buses and connections commodity group includes iso-phase and nonsegregated 6.9 kV and 480 V phase buses. Iso-phase is electrical bus in which each phase conductor is enclosed by an individual metal housing separated from adjacent conductor housings by an air space.
Nonsegregated bus is electrical bus constructed with all phase conductors in a common enclosure without barriers (only air space) between the phases.
High-voltage insulators on the circuits supply power from the switchyard to plant buses during recovery from an SBO. The function of high-voltage insulators is to insulate and support electrical conductors. High-voltage insulators are passive, long-lived components.
The switchyard bus provides a portion of the circuits supplying power from the switchyard to plant buses during recovery from an SBO. The function of switchyard bus is to provide electrical connections to specified sections of an electrical circuit to deliver voltage, current, or signals.
The switchyard bus is a passive, long-lived component.
Transmission conductors provide a portion of the circuits that supply power from the switchyard to plant buses during recovery from an SBO. The function of transmission conductors is to provide electrical connections to specified sections of an electrical circuit to deliver voltage, current, or signals. Transmission conductors are passive, long-lived components.
Uninsulated ground conductors in lightning protection applications protect structures and equipment from lightning strikes by providing a low-resistance path to ground. Uninsulated ground conductors consist of air terminals, ground rods, stranded uninsulated (bare) electrical cable, and connections. Common connections are by welds or mechanical-type connectors (e.g., compression, bolted, and wedge-type devices). The function of uninsulated ground conductors is to provide electrical connection to specified sections of an electrical circuit to deliver current to ground. The lightning protection and site grounding systems are credited for compliance with a fire protection function of lightning protection. The uninsulated ground conductors commodity consists of passive, long-lived components The electrical and I&C component commodity groups perform functions that include supporting fire protection and SBO. LRA Table 2.5.1-1 identifies electrical and I&C component commodity groups within the scope of license renewal and subject to an AMR:
* non-EQ insulated cables and connections 2-273
* metal enclosed buses and connections
* high-voltage insulators
* switchyard buses and connections
* transmission conductors and connections
* uninsulated ground conductors and connections The intended functions of the electrical and I&C component commodity groups within the scope of license renewal include:
* electrical connections for voltage, current, or signal delivery to specified electrical circuit sections
* electrical conductor insulation and support 2.5.1.2 Staff Evaluation The staff reviewed LRA Section 2.5.1 and the FSAR using the evaluation methodology described in SER Section 2.5 and the guidance in SRP-LR Section 2.5, Scoping and Screening Results: Electrical and Instrumentation and Controls Systems.
During its review, the staff evaluated the system functions described in the LRA and FSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
Interim Staff Guidance (ISG)-2, "Staff Guidance on Scoping of Equipment Relied on to Meet the Requirements of the Station Blackout Rule (10 CFR 50.63) for License Renewal (10 CFR 54.4(a)(3))," dated April 1, 2002, states:
For purposes of the license renewal rule, the staff has determined that the plant system portion of the offsite power system that is used to connect the plant to the offsite power source should be included within the scope of the rule. This path typically includes switchyard circuit breakers that connect to the offsite system power transformers (startup transformers), the transformers themselves, the intervening overhead or underground circuits between circuit breaker and transformer and transformer and onsite electrical system, and the associated control circuits and structures. Ensuring that the appropriate offsite power system long-lived passive structures and components that are part of this circuit path are subject to an aging management review will assure that the bases underlying the SBO requirements are maintained over the period of extended license.
LRA Section 2.1.1.3.4 indicates that the preferred path of offsite power when recovering from a SBO is through the two start-up transformers (SUTs) from the power grid via the 230 kV switchyard, and the 230 kV power circuit breakers represent the scoping boundary.
Figure 2.1-2, "Power Path for Recovery of Offsite Power Following a Station Blackout Event" 2-274
 
shows that 230 kV circuit breakers 52-2 and 52-3 for SUT 1A and for SUT 1B, circuit breakers 52-13 and 52-14 represent the boundary. This drawing did not specify the offsite lines but the audit team, while onsite (documented in the Audit Report), verified that drawing No. PD-5165-B-C-0001 provides the connections (i.e. offsite lines) past the circuit breakers. In terms of SBO paths, for SUT 1A, the associated offsite line is Cape Fear North, and for SUT 1B, it is Apex US #1. Therefore, the scoping boundary is in accordance with ISG-2, and the staff finds this acceptable.
2.5.1.3 Conclusion The staff reviewed the LRA and FSAR to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the electrical and I&C component commodity groups components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.6 Conclusion for Scoping and Screening The staff reviewed the information in LRA Section 2, Scoping and Screening Methodology for Identifying Structures and Components Subject to Aging Management Review and Implementation Results, and determined that the applicants scoping and screening methodology was consistent with 10 CFR 54.21(a)(1) and the staffs positions on the treatment of safety-related and nonsafety-related SSCs within the scope of license renewal and on SCs subject to an AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1).
On the basis of its review, the staff concludes that the applicant has adequately identified those systems and components within the scope of license renewal, as required by 10 CFR 54.4(a),
and those subject to an AMR, as required by 10 CFR 54.21(a)(1).
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SECTION 3 AGING MANAGEMENT REVIEW RESULTS This section of the safety evaluation report (SER) evaluates aging management programs (AMPs) and aging management reviews (AMRs) for Shearon Harris Nuclear Power Plant (HNP)
Unit 1 by the staff of the United States (US) Nuclear Regulatory Commission (NRC) (the staff).
In Appendix B of its license renewal application (LRA), Carolina Power & Light Company (CP&L or the applicant) described the 39 AMPs that it relies on to manage or monitor the aging of passive, long-lived structures and components (SCs).
In LRA Section 3, the applicant provided the results of the AMRs for those SCs identified in LRA Section 2 as within the scope of license renewal and subject to an AMR.
3.0 Applicants Use of the Generic Aging Lessons Learned Report In preparing its LRA, the applicant credited NUREG-1801, Revision 1, Generic Aging Lessons Learned (GALL) Report, dated September 2005. The GALL Report contains the staffs generic evaluation of the existing plant programs and documents the technical basis for determining where existing programs are adequate without modification and where existing programs should be augmented for the period of extended operation. The evaluation results documented in the GALL Report indicate that many of the existing programs are adequate to manage the aging effects for particular license renewal SCs. The GALL Report also contains recommendations on specific areas for which existing programs should be augmented for license renewal. An applicant may reference the GALL Report in its LRA to demonstrate that its programs correspond to those reviewed and approved in the report.
The purpose of the GALL Report is to provide a summary of staff-approved AMPs to manage or monitor the aging of SCs subject to an AMR. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources for LRA review will be greatly reduced, improving the efficiency and effectiveness of the license renewal review process. The GALL Report also serves as a quick reference for applicants and staff reviewers to AMPs and activities that the staff has determined will adequately manage or monitor aging during the period of extended operation.
The GALL Report identifies: (1) systems, structures, and components (SSCs), (2) SC materials, (3) environments to which the SCs are exposed, (4) the aging effects of the materials and environments, (5) the AMPs credited with managing or monitoring the aging effects, and (6) recommendations for further applicant evaluations of aging management for certain component types.
To determine whether use of the GALL Report would improve the efficiency of LRA review, the staff conducted a demonstration of the GALL Report process in order to model the format and content of safety evaluations based on it. The results of the demonstration project confirmed that the GALL Report process will improve the efficiency and effectiveness of LRA review while 3-1
 
maintaining the staffs focus on public health and safety. NUREG-1800, Revision 1, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR),
dated September 2005, was prepared based on both the GALL Report model and lessons learned from the demonstration project.
The staff s review was in accordance with Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants, and the guidance of the SRP-LR and the GALL Report.
In addition to its review of the LRA, the staff conducted an onsite audit of selected AMRs and associated AMPs during the weeks of April 23-27, May 21-25 and June 25-29, 2007. The onsite audits and reviews are designed for maximum efficiency of the staffs LRA review. The applicant can respond to questions, the staff can readily evaluate the applicants responses, the need for formal correspondence between the staff and the applicant is reduced, and the result is an improvement in review efficiency.
3.0.1 Format of the License Renewal Application The applicant submitted an application that follows the standard LRA format agreed to by the staff and the Nuclear Energy Institute (NEI) by letter dated April 7, 2003. This revised LRA format incorporates lessons learned from the staffs reviews of the previous five LRAs, which used a format developed from information gained during a staff-NEI demonstration project conducted to evaluate the use of the GALL Report in the LRA review process.
The organization of LRA Section 3 parallels that of SRP-LR Chapter 3. LRA Section 3 presents AMR results information in the following two table types:
(1)  Table 1s: Table 3.x.1 - where 3 indicates the LRA section number, x indicates the subsection number from the GALL Report, and 1 indicates that this table type is the first in LRA Section 3.
(2)  Table 2s: Table 3.x.2-y - where 3 indicates the LRA section number, x indicates the subsection number from the GALL Report, 2 indicates that this table type is the second in LRA Section 3, and y indicates the system table number.
The content of the previous LRAs and of the HNP application is essentially the same. The intent of the revised format of the LRA was to modify the tables in LRA Section 3 to provide additional information that would assist in the staffs review. In its Table 1s, the applicant summarized the portions of the application that it considered to be consistent with the GALL Report. In its Table 2s, the applicant identified the linkage between the scoping and screening results in LRA Section 2 and the AMRs in LRA Section 3.
3.0.1.1 Overview of Table 1s Each Table 1 compares in summary how the facility aligns with the corresponding tables in the GALL Report. The tables are essentially the same as Tables 1 through 6 in the GALL Report, except that the Type column has been replaced by an Item Number column and the Item 3-2
 
Number in GALL column has been replaced by a Discussion column. The Item Number column is a means for the staff reviewer to cross-reference Table 2s with Table 1s. In the Discussion column the applicant provided clarifying information. The following are examples of information that might be contained within this column:
* further evaluation recommended - information or reference to where that information is located
* The name of a plant-specific program
* exceptions to GALL Report assumptions
* discussion of how the line is consistent with the corresponding line item in the GALL Report when the consistency may not be obvious
* discussion of how the item is different from the corresponding line item in the GALL Report (e.g., when an exception is taken to a GALL Report AMP)
The format of each Table 1 allows the staff to align a specific row in the table with the corresponding GALL Report table row so that the consistency can be checked easily.
3.0.1.2 Overview of Table 2s Each Table 2 provides the detailed results of the AMRs for components identified in LRA Section 2 as subject to an AMR. The LRA has a Table 2 for each of the systems or structures within a specific system grouping (e.g., reactor coolant system, engineered safety features, auxiliary systems, etc.). For example, the engineered safety features group has tables specific to the containment spray system, containment isolation system, and emergency core cooling system. Each Table 2 consists of nine columns:
* Component Type - The first column lists LRA Section 2 component types subject to an AMR in alphabetical order.
* Intended Function - The second column identifies the license renewal intended functions for the listed component types. Definitions of intended functions are in LRA Table 2.0-1.
* Material - The third column lists the particular construction material(s) for the component type.
* Environment - The fourth column lists the environments to which the component types are exposed. Internal and external service environments are indicated with a list of these environments in LRA Table 3.0-1.
* Aging Effect Requiring Management - The fifth column lists aging effects requiring management (AERMs). As part of the AMR process, the applicant determined any AERMs for each combination of material and environment.
* Aging Management Programs - The sixth column lists the AMPs that the applicant uses to manage the identified aging effects.
* NUREG-1801 Volume 2 Item - The seventh column lists the GALL Report item(s) identified in the LRA as similar to the AMR results. The applicant compared each combination of component type, material, environment, AERM, and AMP in LRA Table 2 with the GALL Report items. If there are no corresponding items in the GALL Report, the applicant leaves the column blank in order to identify the AMR results in the LRA 3-3
 
tables corresponding to the items in the GALL Report tables.
* Table 1 Item - The eighth column lists the corresponding summary item number from LRA Table 1. If the applicant identifies in each LRA Table 2 AMR results consistent with the GALL Report, the Table 1 line item summary number should be listed in LRA Table 2. If there is no corresponding item in the GALL Report, column eight is left blank.
In this manner, the information from the two tables can be correlated.
* Notes - The ninth column lists the corresponding notes used to identify how the information in each Table 2 aligns with the information in the GALL Report. The notes, identified by letters, were developed by an NEI work group and will be used in future LRAs. Any plant-specific notes identified by numbers provide additional information about the consistency of the line item with the GALL Report.
3.0.2 Staffs Review Process The staff conducted three types of evaluations of the AMRs and AMPs:
(1)  For items that the applicant stated were consistent with the GALL Report, the staff conducted either an audit or a technical review to determine consistency.
(2)  For items that the applicant stated were consistent with the GALL Report with exceptions, enhancements, or both, the staff conducted either an audit or a technical review of the item to determine consistency. In addition, the staff conducted either an audit or a technical review of the applicants technical justifications for the exceptions or the adequacy of the enhancements.
The SRP-LR states that an applicant may take one or more exceptions to specific GALL AMP elements; however, any deviation from or exception to the GALL AMP should be described and justified. Therefore, the staff considers exceptions as being portions of the GALL AMP that the applicant does not intend to implement.
In some cases, an applicant may choose an existing plant program that does not meet all the program elements defined in the GALL AMP. However, the applicant may make a commitment to augment the existing program to satisfy the GALL AMP prior to the period of extended operation. Therefore, the staff considers these augmentations or additions to be enhancements. Enhancements include, but are not limited to, activities needed to ensure consistency with the GALL Report recommendations. Enhancements may expand, but not reduce, the scope of an AMP.
(3)  For other items, the staff conducted a technical review to verify conformance with 10 CFR 54.21(a)(3) requirements.
Staff audits and technical reviews of the applicants AMPs and AMRs determine whether the aging effects on SCs can be adequately managed to maintain their intended function(s) consistent with the plants current licensing basis (CLB) for the period of extended operation, as required by 10 CFR Part 54.
3.0.2.1 Review of AMPs For AMPs for which the applicant claimed consistency with the GALL AMPs, the staff conducted either an audit or a technical review to verify the claim. For each AMP with one or more 3-4
 
deviations, the staff evaluated each deviation to determine whether the deviation was acceptable and whether the modified AMP would adequately manage the aging effect(s) for which it was credited. For AMPs not evaluated in the GALL Report, the staff performed a full review to determine their adequacy. The staff evaluated the AMPs against the following 10 program elements defined in SRP-LR Appendix A.
(1)  Scope of the Program - Scope of the program should include the specific SCs subject to an AMR for license renewal.
(2) Preventive Actions - Preventive actions should prevent or mitigate aging degradation.
(3) Parameters Monitored or Inspected - Parameters monitored or inspected should be linked to the degradation of the particular structure or component intended function(s).
(4) Detection of Aging Effects - Detection of aging effects should occur before there is a loss of structure or component intended function(s). This includes aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection, and timing of new/one-time inspections to ensure timely detection of aging effects.
(5) Monitoring and Trending - Monitoring and trending should provide predictability of the extent of degradation as well as timely corrective or mitigative actions.
(6) Acceptance Criteria - Acceptance criteria, against which the need for corrective action will be evaluated, should ensure that the structure or component intended function(s) are maintained under all CLB design conditions during the period of extended operation.
(7) Corrective Actions - Corrective actions, including root cause determination and prevention of recurrence, should be timely.
(8) Confirmation Process - Confirmation process should ensure that preventive actions are adequate and that appropriate corrective actions have been completed and are effective.
(9) Administrative Controls - Administrative controls should provide for a formal review and approval process.
(10) Operating Experience - Operating experience of the AMP, including past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.
Details of the staffs audit evaluation of program elements (1) through (6) are documented in SER Section 3.0.3.
The staff reviewed the applicants quality assurance (QA) program and documented its evaluations in SER Section 3.0.4. The staffs evaluation of the QA program included assessment of the corrective actions, confirmation process, and administrative controls program elements.
The staff reviewed the information on the operating experience program element and documented its evaluation in SER Section 3.0.3.
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3.0.2.2 Review of AMR Results Each LRA Table 2 contains information concerning whether or not the AMRs identified by the applicant align with the GALL Report AMRs. For a given AMR in a Table 2, the staff reviewed the intended function, material, environment, AERM, and AMP combination for a particular system component type. Item numbers in column seven of the LRA, NUREG-1801 Volume 2 Item, correlate to an AMR combination as identified in the GALL Report. The staff also conducted onsite audits to verify these correlations. A blank in column seven indicates that the applicant was unable to identify an appropriate correlation in the GALL Report. The staff also conducted a technical review of combinations not consistent with the GALL Report. The next column, Table 1 Item, refers to a number indicating the correlating row in Table 1.
3.0.2.3 FSAR Supplement Consistent with the SRP-LR for the AMRs and AMPs that it reviewed, the staff also reviewed the FSAR supplement, which summarizes the applicants programs and activities for managing aging effects for the period of extended operation, as required by 10 CFR 54.21(d).
3.0.2.4 Documentation and Documents Reviewed In its review, the staff used the LRA, LRA supplements, the SRP-LR, and the GALL Report.
During the onsite audit, the staff also examined the applicants justifications to verify that the applicants activities and programs will adequately manage the effects of aging on SCs. The staff also conducted detailed discussions and interviews with the applicants license renewal project personnel and others with technical expertise relevant to aging management.
3.0.3 Aging Management Programs SER Table 3.0.3-1 presents the AMPs credited by the applicant and described in LRA Appendix B. The table also indicates the SSCs that credit the AMPs and the GALL AMP with which the applicant claimed consistency and shows the section of this SER in which the staffs evaluation of the program is documented.
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Table 3.0.3-1 HNP Aging Management Programs AMP          New or  GALL Report    GALL  LRA Systems or Structures          Staffs (LRA Section)      Existing  Comparison      Report    That Credit the AMP        SER Section AMP                    AMPs ASME Section XI,      Existing Consistent with XI.M1  reactor vessel, reactor vessel 3.0.3.2.1 Inservice Inspection,          exception              internals, and reactor coolant Subsections IWB,                                      system IWC and IWD Program (B.2.1)
Water Chemistry      Existing Consistent      XI.M2  reactor vessel, reactor vessel 3.0.3.1.1 Program                                                internals, and reactor coolant (B.2.2)                                                system / engineered safety features / auxiliary systems /
steam and power conversion system / containments, structures, and component supports Reactor Head          Existing Consistent with XI.M3  reactor vessel, reactor vessel 3.0.3.2.2 Closure Studs                  exception              internals, and reactor coolant Program                                                system (B.2.3)
Boric Acid Corrosion  Existing Consistent      XI.M10  reactor vessel, reactor vessel 3.0.3.1.2 Program                                                internals, and reactor coolant (B.2.4)                                                system / engineered safety features / auxiliary systems /
steam and power conversion system / containments, structures, and component supports Nickel-Alloy          Existing Consistent with XI.M11A reactor vessel, reactor vessel 3.0.3.2.3 Penetration Nozzles            enhancement            internals, and reactor coolant Welded to the Upper                                    system Reactor Vessel Closure of Pressurized Water Reactors Program (B.2.5)
Thermal Aging and    New      Consistent      XI.M13  reactor vessel, reactor vessel 3.0.3.1.3 Neutron Irradiation                                    internals, and reactor coolant Embrittlement of                                      system Cast Austenitic Stainless Steel (CASS) Program (B.2.6)
Flow-Accelerated      Existing Consistent with XI.M17  reactor vessel, reactor vessel 3.0.3.2.4 Corrosion Program              enhancement            internals, and reactor coolant (B.2.7)                                                system / engineered safety features / auxiliary systems /
steam and power conversion system 3-7
 
AMP        New or  GALL Report    GALL  LRA Systems or Structures          Staffs (LRA Section)    Existing  Comparison      Report    That Credit the AMP        SER Section AMP                    AMPs Bolting Integrity  Existing Consistent with XI.M18  reactor vessel, reactor vessel 3.0.3.2.5 Program                      exceptions and          internals, and reactor coolant (B.2.8)                      enhancement            system / engineered safety features / auxiliary systems /
steam and power conversion system Steam Generator    Existing Consistent with XI.M19  reactor vessel, reactor vessel 3.0.3.2.6 Tube Integrity              exceptions and          internals, and reactor coolant Program                      enhancements            system (B.2.9)
Open-Cycle Cooling  Existing Consistent      XI.M20  auxiliary systems              3.0.3.1.4 Water System Program (B.2.10)
Closed-Cycle        Existing Consistent with XI.M21  reactor vessel, reactor vessel 3.0.3.2.7 Cooling Water                exceptions              internals, and reactor coolant System Program                                      system / engineered safety (B.2.11)                                            features / auxiliary systems Boraflex Monitoring Existing Consistent with XI.M22  containments, structures,      3.0.3.2.8 Program                      enhancements            and component supports (B.2.12)
Inspection of      Existing Consistent with XI.M23  containments, structures,      3.0.3.2.9 Overhead Heavy              enhancements            and component supports Load and Light Load Handling Systems Program (B.2.13)
Fire Protection    Existing Consistent with XI.M26  auxiliary systems              3.0.3.2.10 Program                      enhancements (B.2.14)
Fire Water System  Existing Consistent with XI.M27  auxiliary systems              3.0.3.2.11 Program                      enhancements (B.2.15)
Fuel Oil Chemistry  Existing Consistent with XI.M30  auxiliary systems              3.0.3.2.12 Program                      enhancements (B.2.16)
Reactor Vessel      Existing Consistent with XI.M31  reactor vessel, reactor vessel 3.0.3.2.13 Surveillance                enhancements            internals, and reactor coolant Program                                              system (B.2.17) 3-8
 
AMP          New or  GALL Report    GALL  LRA Systems or Structures          Staffs (LRA Section)    Existing  Comparison      Report    That Credit the AMP        SER Section AMP                    AMPs One-Time Inspection  New      Consistent      XI.M32  reactor vessel, reactor vessel 3.0.3.1.5 Program                                              internals, and reactor coolant (B.2.18)                                              system / engineered safety features / auxiliary systems /
steam and power conversion system / containments, structures, and component supports Selective Leaching  New      Consistent with XI.M33  auxiliary systems / steam      3.0.3.2.14 of Materials Program          exceptions              and power conversion (B.2.19)                                              system Buried Piping and    New      Consistent      XI.M34  auxiliary systems /            3.0.3.1.6 Tanks Inspection                                      containments, structures, Program                                              and component supports (B.2.20)
One-Time Inspection  New      Consistent with XI.M35  reactor vessel, internals, and 3.0.3.2.15 of ASME Code                  exceptions              reactor coolant system Class 1 Small-Bore Piping Program (B.2.21)
External Surfaces    Existing Consistent with XI.M36  reactor vessel, reactor vessel 3.0.3.2.16 Monitoring Program            enhancements            internals, and reactor coolant (B.2.22)                                              system / engineered safety features / auxiliary systems /
steam and power conversion system / containments, structures, and component supports Flux Thimble Tube    Existing Consistent with XI.M37  reactor vessel, reactor vessel 3.0.3.2.17 Inspection Program            enhancements            internals, and reactor coolant (B.2.23)                                              system Inspection of        New      Consistent      XI.M38  auxiliary systems / steam      3.0.3.1.7 Internal Surfaces in                                  and power conversion Miscellaneous                                        system / containments, Piping and Ducting                                    structures, and component Components                                            supports Program (B.2.24)
Lubricating Oil      Existing Consistent with XI.M39  reactor vessel, reactor vessel 3.0.3.2.18 Analysis Program              enhancement            internals, and reactor coolant (B.2.25)                                              system / auxiliary systems /
steam and power conversion system ASME Section XI,    Existing Consistent with XI.S1  containments, structures,      3.0.3.2.19 Subsection IWE                exception and          and component supports Program                      enhancements (B.2.26) 3-9
 
AMP        New or  GALL Report      GALL  LRA Systems or Structures          Staffs (LRA Section)  Existing  Comparison      Report    That Credit the AMP        SER Section AMP                      AMPs ASME Section XI,    Existing Consistent with  XI.S2  containments, structures,      3.0.3.2.20 Subsection IWL              exception                and component supports Program (B.2.27)
ASME Section XI,    Existing Consistent with  XI.S3  containments, structures,      3.0.3.2.21 Subsection IWF              exceptions              and component supports Program (B.2.28) 10 CFR Part 50,    Existing Consistent with  XI.S4  containments, structures,      3.0.3.2.22 Appendix J Program          exception                and component supports (B.2.29)
Masonry Wall        Existing Consistent with  XI.S5  containments, structures,      3.0.3.2.23 Program                      enhancement              and component supports (B.2.30)
Structures          Existing Consistent with  XI.S6  containments, structures,      3.0.3.2.24 Monitoring Program          enhancements            and component supports (B.2.31)
RG 1.127,          Existing Consistent with  XI.S7  containments, structures,      3.0.3.2.25 Inspection of                enhancements            and component supports Water-Control Structures Associated with Nuclear Power Plants Program (B.2.32)
Electrical Cables  New      Consistent      XI.E1  electrical and instrumentation 3.0.3.1.8 and Connections not                                  and controls Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (B.2.33)
Electrical Cables  New      Consistent      XI.E2  electrical and instrumentation 3.0.3.1.9 and Connections not                                  and controls Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits Program (B.2.34) 3-10
 
AMP          New or    GALL Report      GALL  LRA Systems or Structures          Staffs (LRA Section)      Existing  Comparison      Report    That Credit the AMP        SER Section AMP                      AMPs Inaccessible          New      Consistent      XI.E3  electrical and instrumentation 3.0.3.1.10 Medium-Voltage                                          and controls Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (B.2.35)
Metal Enclosed Bus    New      Consistent      XI.E4  electrical and instrumentation 3.0.3.1.11 Program                                                  and controls (B.2.36)
Electrical Cable      New      Consistent      XI.E6  electrical and instrumentation 3.0.3.1.12 Connections Not                                          and controls Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (B.2.37)
Reactor Coolant      Existing  Consistent with  X.M1    reactor vessel, internals, and 3.0.3.2.26 Pressure Boundary              enhancements            reactor coolant system Fatigue Monitoring Program (B.3.1)
Environmental        Existing  Consistent      X.E1    electrical and instrumentation 3.0.3.1.13 Qualification (EQ)                                      and controls Program (B.3.2) 3.0.3.1 AMPs Consistent with the GALL Report In LRA Appendix B, the applicant identified the following AMPs as consistent with the GALL Report:
* Water Chemistry Program
* Boric Acid Corrosion Program
* Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program
* Open-Cycle Cooling Water System Program
* One-Time Inspection Program
* Buried Piping and Tanks Inspection Program
* Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program 3-11
* Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program
* Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program
* Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program
* Metal Enclosed Bus Program
* Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program
* Environmental Qualification (EQ) Program 3.0.3.1.1 Water Chemistry Program Summary of Technical Information in the Application. LRA Section B.2.2 describes the existing Water Chemistry Program as consistent with GALL AMP XI.M2, :Water Chemistry.
The applicant's Water Chemistry Program consists of two parts, water chemistry for both the primary and the secondary water systems, implemented with different water chemistry control requirements, procedures, and acceptance criteria.
To mitigate aging effects on component surfaces exposed to water as process fluid, chemistry programs control water chemistry and impurities (e.g., dissolved oxygen, chlorides, fluorides, and sulfates) that accelerate corrosion and cracking. This program monitors and controls water chemistry to keep peak levels of various contaminants below system-specific limits.
Alternatively, introduction of chemical agents (e.g., corrosion inhibitors, oxygen scavengers, and biocides) may prevent some aging mechanisms. The HNP Water Chemistry Program is based on the latest version of the Electric Power Research Institute (EPRI) guidelines, Pressurized Water Reactor Primary Water Chemistry Guidelines, Revision 5, EPRI, Palo Alto, CA, 2003, 1002884, and Pressurized Water Reactor Secondary Water Chemistry Guidelines -
Revision 6, EPRI, Palo Alto, CA: 2004, 1008224. The HNP Water Chemistry Program will be updated as revisions to the guidelines are released.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
During the audit, the staff reviewed the existing Water Chemistry Program license renewal calculation, the applicants bases document for this AMP directly comparing its ten program elements to those defined and described in GALL AMP XI.M2, Water Chemistry. The staff also interviewed the applicant's technical personnel and reviewed program implementation and administrative control documents listed in the Audit Report for this LRA review issued in March 2008.
The staff reviewed the program element descriptions in the applicants license renewal calculation and noted that the Water Chemistry Program is a preventive/mitigative AMP that periodically samples and tests chemical assays of plant coolants to keep contaminant concentrations in the coolants within specified programmatic limits. The staff also noted that the 3-12
 
contaminants include, but are not limited to, dissolved oxygen, sulfate, fluoride, chloride, and hydrogen peroxide. The staff noted that the applicants Water Chemistry Program also maintains concentrations of plant pH-control compounds, reactivity control compounds, oxygen scavengers, and biocides. Examples of these additives are hydrazine, sodium hypochorite, lithium, and boron. Based on its review of the license renewal calculation for the Water Chemistry Program, the staff determines that these activities are consistent with the recommended guidelines of GALL AMP XI.M2, Water Chemistry, and acceptable.
The staff also noted that the license renewal calculation for the Water Chemistry Program indicates implementation in accordance with recommended guidelines of EPRI Report No. TR-1002884, PWR Primary Water Chemistry Guidelines (October 2003), and EPRI Report No. TR-102134, Revision 3, PWR Secondary Water Chemistry Guidelines (October 2003), for sampling and quality testing (i.e., chemical assay testing) of plant coolants, the same water quality guideline references of GALL AMP XI.M2, Water Chemistry. These guidelines also recommend contaminant maximum limits for such coolants. The contaminants recommended for management in these reports include, but are not limited to, those in the previous paragraph. Based on this review, the staff concludes that the applicants implementation of the guidelines, practices, and activities recommended in these reports is consistent with the program elements defined and described in GALL AMP XI.M2, Water Chemistry, and acceptable.
The staff also noted that the applicant has credited either the One-Time Inspection Program or the ASME Code Section XI, Subsection IWB, IWC, and IWD Inservice Inspection Program to verify Water Chemistry Program effectiveness in accomplishing its mitigative function for AMR commodity groups or components for which it is credited. LRA Sections B.2.1 and B.2.18 describe the applicants ASME Code Section XI, Subsection IWB, IWC, and IWD Inservice Inspection Program and its One-Time Inspection Program, respectively. SER Sections 3.0.3.2.1 and 3.0.3.1.5 evaluate the ability of the ASME Code Section XI, Subsection IWB, IWC, and IWD Inservice Inspection Program and of the One Time Inspection Program, respectively, to manage aging.
Based on its review, the staff finds the Water Chemistry Program consistent with the program elements in GALL AMP XI.M2, Water Chemistry, and acceptable Operating Experience. LRA Section B.2.2 states that the EPRI guideline documents have been developed based on plant experience and shown to be effective over time with their widespread use in the industry; however, there is potential for stress corrosion cracking (SCC) due to inadvertent introduction of contaminants into the primary coolant system from unacceptable contaminant levels in the boric acid or through the free surface of the spent fuel pool (which can be a natural collector of airborne contaminants) or introduction of oxygen during cooldown.
Ingress of demineralizer resins into the primary system has caused intergranular stress corrosion cracking (IGSCC) of Alloy 600 vessel head penetrations. Inadvertent introduction of sodium thiosulfate into the primary system has caused IGSCC of steam generator tubes. SCC has occurred in safety injection lines, charging pump casing cladding, instrument nozzles in safety-injection tanks, and stainless steel piping systems that contain oxygenated, stagnant, or essentially stagnant borated coolant. Steam generator tubes and plugs and Alloy 600 penetrations have experienced primary water SCC. Steam generator tubes have experienced 3-13
 
SCC, intergranular attack, wastage, and pitting. Carbon steel support plates in steam generators have experienced general corrosion. The steam generator shell has experienced pitting and stress corrosion cracking.
The applicant has reviewed the industry operating experience with maintenance of a benign environment described in the GALL Report for applicable recommendations.
A review of systematic assessment of applicant performance reports from 1988 through 1998 concluded that the Water Chemistry Program was well maintained with performance well within regulatory limits. Review of integrated inspection reports from 1999 through 2006 indicated no adverse trends or violations for the Water Chemistry Program.
The applicant has assessed the Water Chemistry Program ten times from 1997 through 2005.
These assessments have found issues and weaknesses to be addressed but have concluded that the Water Chemistry Program is effective in the support of the plant.
The operating experience review of the Water Chemistry Program concluded that this program is upgraded continually based on industry experience and research. These continual upgrades assure Water Chemistry Program capability to support the safe plant operation throughout the period of extended operation.
During the audit, the staff reviewed Water Chemistry Program operation records, interviewed plant chemistry personnel responsible for program implementation, and determined that, in addition to taking water chemistry samples, performing the defined chemistry assays and tests on them, and recording the test results, such personnel are also responsible for detecting and addressing in nuclear condition reports (NCRs) any adverse chemistry events or excursions that could impact program effectiveness or plant safety.
The staff reviewed six Water Chemistry Program NCRs for whether the applicant had addressed operational program implementation data, focusing particularly on the following safety-related aspects of nuclear operations:
* one NCR on maintenance of a minimum required sodium hydroxide concentration in containment spray additive tank
* one NCR on maintenance of a minimum required boric acid concentration in the boric acid tank
* one NCR on maintenance of an acceptably low oxygen concentration in the reactor coolant
* three NCRs on maintenance of an acceptable lithium concentration in the reactor coolant for pH control The staff determined that in each of these NCRs the applicant had analyzed the adverse 3-14
 
condition sufficiently to identify the root cause or causes and had taken appropriate corrective actions to bring the chemistry parameter within an acceptable range defined in water chemistry control procedures. Based on this review, the staff concludes that the applicant has appropriate controls in effect to detect water chemistry events that could impact plant safety or the effectiveness of the Water Chemistry Program in accomplishing its intended function of preventing or mitigating corrosion-induced aging effects and that the applicant takes appropriate actions to correct any such events.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.2, the applicant provided the FSAR supplement for the Water Chemistry Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Water Chemistry Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.2 Boric Acid Corrosion Program Summary of Technical Information in the Application. LRA Section B.2.4 describes the existing Boric Acid Corrosion Program as consistent with GALL AMP XI.M10, Boric Acid Corrosion.
The Boric Acid Corrosion Program implements systematic measures to prevent leaking borated coolant from leading to degradation of the leakage source or of adjacent mechanical, electrical, and structural components susceptible to boric acid corrosion. The program consists of (1) visual inspection of external surfaces potentially exposed to borated water leakage, (2) timely discovery of leak paths and removal of boric acid residues, (3) assessment of damage, and (4) follow-up inspection for adequacy of corrective actions. The Boric Acid Corrosion Program includes plant-specific reactor coolant pressure boundary (RCPB) boric acid leakage identification and inspection procedures to prevent leaking borated coolant from leading to degradation of the leakage source or adjacent structures and assures for the RCPB an extremely low probability of abnormal leakage, rapidly propagating failure, or gross rupture. The program was developed in response to recommendations of NRC Generic Letter 88-05.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
During the audit, the staff reviewed the Boric Acid Corrosion Program and compared its 3-15
 
program elements to those defined and described in GALL AMP XI.M10, Boric Acid Corrosion Program. The staff also reviewed the license renewal basis calculation for the applicants Boric Acid Corrosion Program and interviewed the applicants personnel responsible for its implementation.
In Generic Letter (GL) 88-05, "Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants, the staff informed the US nuclear power industry that borated water leakage is a safety issue for pressurized-water reactor (PWR) reactor coolant pressure boundaries and recommended to PWR facility licensees visual examinations of their borated water systems to monitor leakage that could impact the integrity of plant systems made from ferritic (i.e., carbon or low-alloy) steel materials. The program elements of GALL AMP XI.M10, Boric Acid Corrosion Program, are based on the leakage examinations recommended in GL 88-05.
The license renewal basis calculation for this AMP indicates that the applicant developed its Boric Acid Corrosion Program in accordance with GL 88-05 recommendations for system walkdowns. The staff determined, from review of the scope of program and detection of aging effects program element descriptions in the license renewal basis calculation, that (1) the existing Boric Acid Corrosion Program has procedures for condition monitoring, (2) the applicant based the AMP on GL 88-05, (3) the scope of the AMP incorporates system walkdowns and visual VT-2 examinations of ferritic (i.e. carbon or alloy) steel components that could be exposed to leakage of borated water or to boric acid residues or precipitates of such leakage, and (4) the supplemented scope of the program incorporates industry or plant-specific operating experience. Such incorporation is consistent with the scope of program and detection of aging effects program elements of GALL AMP XI.M10, Boric Acid Corrosion, and acceptable.
The staff noted that the Boric Acid Corrosion Program is not preventive or mitigative; therefore, it does not include activities defined in accordance with the preventive actions program element of Branch Technical Position (BTP) RSLB-1.
The staff determined from its review of the parameters monitored program element in the license renewal basis calculation that the program monitors for loss of material (wastage) to boric acid corrosion. Such monitoring is consistent with the parameters monitored program element of GALL AMP XI.M10, Boric Acid Corrosion, and acceptable.
The staff determined, from its review of the monitoring and trending and acceptance criteria program elements and the supporting procedures in the license renewal basis calculation, that the AMPs system walkdowns at every refueling outage include appropriate acceptance criteria for component sources of borated water leakage and for ferritic steel components exposed to borated water leakage. Specifically, the program states the evidence of leakage is unacceptable and requires entry of any components impacted by borated water leakage into the applicants 10 CFR Part 50, Appendix B Corrective Action Program. This practice is consistent with the monitoring and trending and acceptance criteria program elements of GALL AMP XI.M10, Boric Acid Corrosion, and acceptable.
The staff determined, from its review of the corrective actions program element and 3-16
 
supporting procedures in the license renewal basis calculation, that the program also includes corrective actions to remove boric acid residues from components exposed to borated water leaks and to repair or replace component sources of the leaks. The program controls these corrective actions in accordance with the applicants 10 CFR Part 50, Appendix B Program.
These activities are consistent with the corrective actions program element of GALL AMP XI.M10, Boric Acid Corrosion, and acceptable.
HNP technical specifications establish limits for RCPB leakage, unidentified RCS leakage, and identified RCS non-RCPB leakage. The staff asked the applicant to clarify what activities or actions distinguish the different types of leakage upon discovery of RCS leakage and whether the Boric Acid Corrosion Program implementation procedure incorporates such activities.
In its response dated August 20, 2007, the applicant stated:
Attachment 2 to HNP Correspondence, Serial: HNP-07-015, Shearon Harris Nuclear Power Plant, Unit No. 1 Inspection and Mitigation of Alloy 82/182 Pressurizer Butt Welds, provides a discussion of reactor coolant system (RCS) leakage monitoring. Additionally, HNP FSAR, Section 5.2.5, Detection of Leakage Through Reactor Coolant Pressure Boundary, provides a detailed discussion of this topic.
The applicant's response indicates that CP&L Letter No. HNP-07-015, Shearon Harris Power Plant, Unit No. 1 Inspection and Mitigation of Alloy 82/182 Pressurizer Butt Welds, dated January 31, 2007, states the basis for enhanced monitoring for RCS leakage (a source of borated water leakage) and for differentiation between RCPB leakage, unidentified RCS leakage, and identified RCS non-RCPB leakage. CP&L Letter No. HNP-07-015 defined the applicants programmatic method for enhanced system leakage monitoring of its RCS, established trigger points for corrective actions upon detection of RCS leakage, and made regulatory commitments for implementing this program.
The applicant amended CP&L Letter No. HNP-07-015 in CP&L Letter No. HNP-07-026, Shearon Harris Power Plant, Unit No. 1 Inspection and Mitigation of Alloy 82/182 Pressurizer Butt Welds, dated February 27, 2007, which supplemented both the applicants response to the staffs questions on RCS leakage monitoring and the commitments in CP&L Letter No. HNP-07-015 with additional commitments on RCS system leakage monitoring and implementation of weld overlays on nickel alloy pressurizer welds susceptible to primary water stress corrosion cracking (a source of RCS leakage if an existing crack propagated throughwall).
The applicants response to the staffs question is acceptable because (1) the response indicates that CP&L Letter No. HNP-07-015, as amended in CP&L Letter No. HNP-07-026, states the applicants basis for enhanced monitoring for RCS leakage (a source of borated water leakage) and for differentiation between RCPB leakage, unidentified RCS leakage, and identified RCS non-RCPB leakage and (2) the staff approved the applicants basis for enhanced leakage monitoring in a letter dated March 22, 2007. The staffs question is resolved.
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The relevant information in LRA Section B.2.4, the license renewal basis calculation for this AMP, the applicants response to GL 88-05, and the applicants response to the staffs question as well as the applicants additional commitments for enhanced leakage monitoring demonstrate that the applicant will continue to implement appropriate system walkdowns, monitor for borated water leakage and evidence of wastage, and correct any adverse conditions caused by such leakage. Based on this information, the staff concludes that the program elements for the applicants Boric Acid Corrosion Program are consistent with those of GALL AMP XI.M10, Boric Acid Corrosion Program, without exception and acceptable. The staffs evaluation of how this AMP incorporates borated water leakage operating experience is in the following Operating Experience section.
Operating Experience. LRA Section B.2.4 states that the Boric Acid Corrosion Program is implemented and maintained in accordance with the general requirements for engineering programs for assurance of effective implementation to meet regulatory and procedural requirements, including periodic assessments and reviews of operating experience. Qualified personnel assigned as program managers have authority and responsibility to implement the Boric Acid Corrosion Program and commit adequate resources to program activities.
A review of responses to NRC generic correspondence, plant condition reports, and self-assessments and inspections showed the Boric Acid Corrosion Program as critically monitored and continually improving. These results of the operating experience review prove that Boric Acid Corrosion Program practices will continue to assure the integrity of subject components.
The staff noted that the applicant controls its system walkdowns of the borated systems by a corporate boric acid leakage control program and a designated program manger responsible for managing, controlling, and implementing borated water system monitoring. These activities review any plant-specific experience and industry operating experience on boric acid leakage events and factor such experience into the visual examinations scheduled and implemented by the program. The staff noted that this industry experience includes NRC generic communications on borated coolant leakage, including:
* NRC Order EA-03-009 and its first revision (collectively NRC Order EA-03-009"): This order states NRC augmented ISI requirements for monitoring for reactor coolant leakage from upper reactor pressure vessel head (RPVH) penetration nozzles.
* NRC Bulletin 2003-02: This bulletin states NRC augmented inspection recommendations for monitoring for reactor coolant leakage from lower RPVH nozzles and their nickel alloy welds in PWRs
* NRC Bulletin 2004-01: This bulletin states NRC augmented inspection recommendations for monitoring for reactor coolant leakage from nickel alloy components and nickel alloy weld materials in PWR pressurizers.
The staff asked the applicant whether the Boric Acid Corrosion Program incorporated industry operating experience and the applicants commitments to enhanced leakage monitoring of the 3-18
 
upper reactor vessel closure head (RVCH) penetration nozzles (including their nickel-alloy J-groove welds), lower RVCH bottom-mounted instrumentation nozzles (including their nickel-alloy J-groove welds), and nickel-alloy penetration welds in the pressurizer system.
The applicants response dated August 20, 2008, indicated that the AMP makes these commitments in the following documents:
* CP&L Letter No. HNP-03-023, Shearon Harris Nuclear Power Plant, Unit No. 1, Docket No. 50-400 / License No. NPF-63, Twenty-Day Response to Order for Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, as amended in CPL Letter No. HNP-04-045, dated May 9, 2004.
* CP&L Letter No. HNP-03-118, 90-Day Response to NRC Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity, November 13, 2003.
* CP&L Letter No. HNP-04-097, 60-Day Response to Bulletin 2004-01 for the Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors, July 27, 2004.
Based on the applicants response to the question, the staff determined that the scope of the Boric Acid Corrosion Program includes the applicants responses to these generic communications and any commitments made to the NRC for enhanced RCS leakage monitoring of the nickel-alloy components in or attached to the upper RVCH, lower RVCH, or pressurizer system, including nickel-alloy structural welds. The staff also determined that the applicants bare metal examinations of those components are as recommended in generic communications. SER Section 3.0.3.2.1 documents the staffs summary of the applicants responses to these generic communications and the staffs evaluation of the applicants activities and commitments to inspect these components for leakage. Based on this review, the staff concludes that the applicant has factored industry experience with borated water leakage into the scope of the Boric Acid Corrosion Program to include enhanced RCS leakage monitoring from ASME Class 1 nickel-alloy components more comprehensive than that of the original commitment to the NRC in the applicants response to GL 88-05. The staffs question is resolved.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.4, the applicant provided the FSAR supplement for the Boric Acid Corrosion Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Boric Acid Corrosion Program, the staff finds all program elements consistent with the GALL Report. The staff 3-19
 
concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.3 Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Summary of Technical Information in the Application. LRA Section B.2.6 describes the new Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
Program as consistent with GALL AMP XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS).
The Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will be implemented as an augmented inservice inspection (ISI) program to detect the effects of loss of fracture toughness due to thermal aging and/or neutron irradiation embrittlement of CASS reactor vessel internals. These inspections will be augmented visual inspections already required by American Society of Mechanical Engineers (ASME) Code Section XI, Subsection IWB, Category B-N-3. Components within the scope of this augmented inspection program include CASS reactor vessel internals components potentially susceptible to thermal aging and/or subjected to neutron fluence of greater than 1017 n/cm2 (E>1 MeV).
Susceptibility to loss of fracture toughness due to thermal embrittlement is based on the criteria stated in the May 19, 2000, letter from Christopher Grimes, NRC, to Mr. Douglas Walters, NEI.
For components susceptible to loss of fracture toughness due to thermal embrittlement and/or neutron irradiation embrittlement, the program provides for a component-specific evaluation, including a mechanical loading assessment, to determine whether the loading is compressive or low enough to preclude fracture.
Component inspections and/or evaluations must consider the recommendations of GALL AMP XI.M13. The Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will manage loss of fracture toughness due to thermal aging and/or neutron irradiation embrittlement in CASS reactor vessel internals components within the scope of license renewal to maintain system intended function through the period of extended operation. This program will be implemented and required inspections completed and evaluated during the last 10-year ISI Interval prior to the period of extended operation. Inspections of potentially susceptible components will continue during the period of extended operation.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
During the audit, the staff interviewed the applicant's technical personnel and reviewed Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program documentation, including the license renewal program evaluation report, which assesses consistency of the program elements with GALL AMP XI.M13 elements.
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During the review, the staff noted the applicants statement, in the description section of the program, that, Susceptibility to loss of fracture toughness due to thermal embrittlement is based on the criteria stated in the May 19, 2000, letter from Christopher Grimes, NRC, to Mr. Douglas Walters, NEI. During the audit, the staff asked the applicant whether such criteria had screened out any component/commodity from program management.
The applicant responded that the screening criteria in the Christopher Grimes letter dated May 19, 2000, have screened out no components from management by this program.
During the audit, the staff reviewed the ten program elements described in the applicants license renewal program evaluation report and interviewed the applicants technical personnel to confirm the applicants claim of consistency with the GALL Report. The staff noted that the corrective actions program element of GALL AMP XI.M13 states that repair is in conformance with IWA-4000 and IWB-4000 and replacement in accordance with IWA-7000 and IWB-7000; however, the applicant's calculation states that repairs and replacements will be in accordance with Subsection IWA as required by the 1989 Edition of ASME Code Section XI. The staff considered this statement an exception to the GALL AMP corrective actions program element and asked the applicant to explain this inconsistency and to clarify whether an LRA revision would address it as LRA Section B.2.6 claims consistency (with no exception) with GALL AMP XI.M13.
The applicants response dated August 20, 2007, stated that HNP uses the 1989 Edition of ASME Code Section XI (the Code) to determine repair/replacement requirements. Repairs are in accordance with Article IWA-4000 and the corresponding IWX-4000 of the IWB/C/D portions of the Code, replacements with Article IWA-7000 and the corresponding IWX-7000 of the IWB/C/D portions. HNP is updating the ISI program to the ASME Code Section XI, 2001 Edition with addenda through 2003, per 10 CFR 50.55a. Article IWA-4000 controls all repairs/replacements in this Code edition and its addenda. ASME Code Section XI states, The term repair/replacement activity includes those activities previously known as repair, replacements, modification, or alteration. IWA-4000 has incorporated all ASME Code Section XI IWX-4000 and IWX-7000 articles. The response added that an amended LRA would address this exception.
The same letter dated August 20, 2007, proposed an amendment to LRA Section B.2.2 to add such an exception to the corrective actions program element.
On the basis of the applicants clarification in its response that IWA-4000 has incorporated all of the Section XI IWX-4000 and IWX-7000 articles, the staff finds the response and the exception to the corrective actions element of this program acceptable.
Operating Experience. LRA Section B.2.6 states that this AMP for thermal aging and neutron irradiation embrittlement of CASS is new. There is no plant-specific operating experience to validate the effectiveness of this program.
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The GALL Report is based on industry operating experience through January 2005. The applicant has reviewed more recent industry operating experience for applicability through the normal operating experience review process, which will continue through the period of extended operation.
The staff reviewed a sample (NCRs) of plant-specific operating experience and interviewed the applicants technical personnel to confirm that it revealed no degradation not bounded by industry experience.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.6, the applicant provided the FSAR supplement for the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program. This section states that the new Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will manage loss of fracture toughness of CASS reactor vessel internals due to thermal aging, neutron irradiation embrittlement, or both.
In Enclosure 1 of its response dated November 14, 2006, the applicant committed (Commitment No. 4) to implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program prior to the period of extended operation. The staff reviewed this commitment and LRA Section A.1.1.6 and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program, the staff finds all program elements, with the exception noted in the August 20, 2007, letter for the corrective actions, consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.4 Open-Cycle Cooling Water System Program Summary of Technical Information in the Application. LRA Section B.2.10 describes the existing Open-Cycle Cooling Water System Program as consistent with GALL AMP XI.M20, Open-Cycle Cooling Water System.
The Open-Cycle Cooling Water System Program implements the recommendations of Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, and the guidance in its supplement, Generic Letter 89-13, Supplement 1, to manage the effects of 3-22
 
aging on open-cycle cooling water (OCCW) systems for the period of extended operation. The programs surveillance and control techniques manage aging effects caused by biofouling, corrosion, erosion, and silting in the OCCW systems or structures and components serviced by the OCCW systems. The Open-Cycle Cooling Water System Program addresses the emergency service water (ESW) system and safety-related portion of the normal service water (NSW) system (i.e., piping and components of its containment isolation). The program scope includes safety-related components and flow paths in the ESW and NSW systems subjected to a raw water environment.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed an HNP plant program document stating commitments to address GL 89-13 and confirmed that the applicant has processes in place to implement GL 89-13 recommendations, that system components are either coated internally or constructed of corrosion-resistant material, and that the program periodically flushes small-bore carbon steel piping in stagnant flow locations or periodically replaces the lines with stainless steel piping.
The staff further confirmed that in accordance with plant procedures the program periodically inspects the intake structure, applies a chemical treatment to mitigate microbiologically-influenced corrosion (MIC) and the buildup of biological fouling, inspects heat exchangers and other components, and takes corrective actions, including ultrasonic testing, when inspections detect loss of material. The GL 89-13 plant program document requires eddy current testing of heat exchanger tubes to detect wall thinning. Finally, the staff reviewed the plant procedure for raw water system inspections and confirmed that their criteria maintain coating integrity, detect and repair corrosion and heat exchanger fouling, and remove flow blockages due to fouling.
Operating Experience. LRA Section B.2.10 states that recent system operating history shows that the Open-Cycle Cooling Water System Program has been effective in detecting and mitigating leaks as well as in preventing equipment failures related to fouling and flow blockage.
Plant-specific and industry operating experience show the following aging effects and/or mechanisms: (a) localized pin-hole leakage, (b) erosion of system components (e.g., pumps and pump discharge strainers), (c) corrosion, (d) flow blockage in small-bore, stagnant lines due to silting and corrosion products, (d) partial blockage from silting in cooling header to diesel jacket water coolers, and (e) minor amounts of biological organisms and silt deposits in the intake bays. Fouling due to manganese deposits has been detected in system heat exchangers. Initiated chemistry control measures (e.g., addition of manganese dispersants) have ameliorated this concern to a large extent. These measures are still parts of the ongoing inspections and cleaning efforts of this program. Requirements for addressing these issues are formalized in the Open-Cycle Cooling Water System Program and these items are included in the Correction Action Program.
The staffs audit and review of a series of operating experience documents included GL 89-13 program self-assessments which provided an overview of program effectiveness. As the foundation of the Open-Cycle Cooling Water Program addressing service water fouling concerns in general, this particularly relevant self-assessment concluded that the GL 89-13 program effectively meets GL 89-13 commitments, maintains service water system 3-23
 
safety-related function capability, and translates the commitments into the governing plant program document and into plant procedures and processes. The staff also reviewed an internal evaluation report on the applicant's GL 89-13 test/inspection program documenting the evaluation of testing and inspection results from October 16, 2002, to May 16, 2004, indicating issues identified and appropriate corrective actions taken (e.g., replacement of some carbon steel valves with stainless steel valves as well as continued flushing and periodic replacement of small bore piping). Overall, inspection and test results for this period indicated no significant problems or trends other than those already managed by the Corrective Action Program.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.10, the applicant provided the FSAR supplement for the Open-Cycle Cooling Water System Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Open-Cycle Cooling Water System Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.5 One-Time Inspection Program Summary of Technical Information in the Application. LRA Section B.2.18 describes the new One-Time Inspection Program as consistent with GALL AMP XI.M32, One-Time Inspection.
The One-Time Inspection Program uses one-time inspections to verify AMP effectiveness and confirm the absence of an aging effect. The program includes inspections specified by the GALL Report as well as plant-specific inspections where inspection results can be extrapolated reasonably through the period of extended operation.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff interviewed the applicant's technical personnel and reviewed its license renewal basis calculation and other basis documents and procedures for the One-Time Inspection Program to determine whether its program elements are consistent with program element criteria recommended in GALL AMP XI.M32, One-Time Inspection.
From its review of the license renewal basis calculation, the staff determined that the applicant credits its new One-Time Inspection Program to verify whether (1) other preventive- or 3-24
 
mitigative-based AMPs within the scope of license renewal (e.g., the Water Chemistry Control Program) effectively prevent or mitigate the aging effects for which they are credited or (2) aging effects have occurred (initiated) in the components or structures for which this AMP is credited and for which there is no recorded operating experience.
By letter dated August 20, 2007, the applicant amended LRA Section B.2.18 with additional details of the scope of the One-Time Inspection Program and its program elements.
Specifically, the applicant clarified the aging effects to be monitored within the scope of the AMP and the inspection techniques for monitoring for these aging effects as shown in Table 3.0.3.1.5-1:
Table 3.0.3.1.5-1 Aging Effects and Inspection Methods Within the Scope of the One-Time Inspection Program Aging Effect/Mechanism        Inspection Techniques for Detection of Aging Effect Loss of Material due to        Visual (e.g., VT-1), volumetric, or both Crevice/Pitting Corrosion Loss of Material due to General Visual (e.g., VT-3), volumetric, or both or Galvanic Corrosion or to MIC Loss of Material due to Erosion Visual (e.g., VT-3), volumetric, or both Fouling                        Visual (e.g., VT-3), volumetric, or both Cracking                        Enhanced Visual, volumetric, or both The staff compared the aging effects and inspection techniques described in the letter dated August 20, 2007, to those of GALL AMP XI.M32, One-Time Inspection, and determined that the inspection techniques for the applicants One-Time Inspection Program are consistent with those recommended in GALL AMP XI.M32 for comparable aging effects.
The applicant credits the One-Time Inspection Program to manage loss of material due to flow-accelerated corrosion in the steam generator feedwater distribution ring but its table in the parameters monitored/inspected program element in the letter dated August 20, 2007, showed no inspection techniques for managing loss of material due to such corrosion. The staff asked the applicant how it could credit a one-time inspection for these components without defining inspection techniques for managing loss of material due to flow-accelerated corrosion.
Based on this assessment, the staff concluded that the One-Time Inspection Program inspection techniques for monitoring these aging effects are consistent with the techniques recommended in GALL AMP XI.M32, One-Time Inspection, for such aging effects and acceptable.
The staff also noted that the applicants response dated August 20, 2007, amended LRA Section B.2.18 description of the detection of aging effects and monitoring and trending program elements for the One-Time Inspection Program:
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Sample size would be based on considerations, such as, accessibility, leading or bounding locations, safety significance, severity of operating conditions, and design margins. Progress Energy non-destructive examination (NDE) procedures and personnel qualifications meet the requirements of the ASME Code, where applicable. Administrative controls and quality assurance requirements for NDE activities are implemented in accordance with 10 CFR 50, Appendix B. Inspections may be performed together with ASME inservice inspection activities, and they will be designed to ascertain if detrimental aging effects are occurring. In general, inspections will be scheduled to be accomplished no earlier than 10 years prior to the period of extended operation.
The One-Time Inspection Program is not intended to be a monitoring or trending program; should degradation be encountered, it would be evaluated, and if required, monitored or trended, under the Corrective Action Program.
The staff compared these program element descriptions to the corresponding program elements of GALL AMP XI.M32, One-Time Inspection, and determined that the detection of aging effects and monitoring and trending program elements for the One-Time Inspection Program are consistent with the programmatic criteria for detection of aging effects and monitoring and trending recommended in GALL AMP XI.M32. Based on this determination, the staff concluded that the detection of aging effects and monitoring and trending program elements for the One-time Inspection Program are consistent with the recommendations of GALL AMP XI.M32, One-Time Inspection, and acceptable.
The staff also determined that the acceptance criteria and corrective actions program elements for this AMP, as described in the letter dated August 20, 2007, were consistent with the acceptance criteria and corrective actions program elements recommended in GALL AMP XI.M32, One-Time Inspection, and acceptable.
The staff reviewed the applicants letter dated August 20, 2007, and determined that the applicant has committed to implement the One-Time Inspection Program prior to the period of extended operation (Commitment No. 14).
On the basis of its review, the staff concludes that the applicants One-Time Inspection Program is consistent with program elements recommended in GALL AMP XI.M32, One-Time Inspection, and acceptable and that the program can verify the effectiveness of other preventive/mitigative AMPs or confirm whether aging effects have initiated in the components or structures for which it is credited.
Operating Experience. LRA Section B.2.18 states that the One-Time Inspection Program is new and that the AMR process ensures that one-time inspections have been prescribed and developed with consideration of plant-specific and industry operating experience.
On the basis of this review, the staff concludes that the LRA need not address operating experience with new One-Time Inspection Program not yet implemented at the facility; however, as it is within the scope of Commitment No. 14, pending resolution of the staffs 3-26
 
questions on the adequacy of the inspection techniques to manage flow-accelerated corrosion, the staff concludes that the One-Time Inspection Program will adequately manage the aging effects for which it is credited.
Based on this conclusion, the staff confirmed that the operating experience program element for the One-Time Inspection Program is an acceptable exception to the operating experience program element criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.18, the applicant provided the FSAR supplement for the One-Time Inspection Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff reviewed the applicants letter dated August 20, 2007, where Commitment No. 14 refers to the FSAR supplement section for this AMP as stated in LRA Section A.1.1.18. Based on this review, the staff concludes that the FSAR supplement for this AMP is acceptable because it adequately describes the program and because an appropriate commitment reflects the need to implement it.
Conclusion. On the basis of its audit and review of the applicants One-Time Inspection Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and, concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.6 Buried Piping and Tanks Inspection Program Summary of Technical Information in the Application. LRA Section B.2.20 describes the new Buried Piping and Tanks Inspection Program as consistent with GALL AMP XI.M34, Buried Piping and Tanks Inspection.
The Buried Piping and Tanks Inspection Program will manage aging effects on the external surfaces of carbon steel and cast iron piping components buried in soil. There are no buried tanks in the program. The aging effects/mechanisms of concern are loss of material due to general, pitting, crevice, and microbiologically-induced corrosion. To manage the aging effects, this program includes (a) preventive measures (e.g., coatings and wrappings required by design) to mitigate degradation and (b) visual inspections of external surfaces of buried piping components, when excavated, for evidence of coating damage and degradation. The program will manage aging effects on the external surfaces of carbon steel and gray cast iron piping components buried in soil or sand.
Detailed procedural requirements for the program will be developed for (1) an appropriate as-found pipe coating and material condition inspection whenever buried piping within the 3-27
 
scope of this program is exposed with a minimum frequency of at least every 10-year s, (2) an initial inspection within the 10-year period prior to the period of extended operation, (3) development of an inspection checklist, (4) documented inspection, (5) precautions on excavation and use of backfill for license renewal piping, (6) buried piping coating inspection, upon excavation, by personnel qualified to assess its condition, and (7) evaluation of any buried piping coating damage and/or degradation found during inspection by a coating engineer or other qualified individual (e.g., the coatings program manager). Any evidence of damage to the coating or wrapping (e.g., perforations, holidays) will require inspection of the protected components for evidence of loss of material. The program assures effective management of the effects of aging on buried piping components for the period of extended operation.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the HNP engineering change process and confirmed the use of preventive measures like protective coatings/wrappings in buried steel and cast iron piping applications.
The staff also reviewed the plant procedure for excavation and backfill and confirmed that in-process inspections minimize the potential for damage during these activities. The staff further confirmed that the procedural changes outlined in LRA Section B.2.20 to implement the remaining GALL Report recommendations are parts of the implementation plan.
The applicants letter dated August 20, 2007, committed (Commitment No.16) to implementation of this new program prior to the period of extended operation. The staff reviewed the LRA Section A.1.1.20 program description to which Commitment No.16 refers.
Based on review of the program description and information from the audit and review, the staff finds that this commitment will implement a program consistent with GALL Report recommendations.
During the audit and review, the staff asked the applicant for its methodology and criteria for determining inspection locations in areas with the highest likelihood of corrosion problems.
In its response dated August 20, 2007, the applicant stated:
The specific locations and methodology have not been determined. HNP will remain abreast of the industry with regard to technologies in use and use site and industry operating experience reviews and Benchmarking to assist in the selection of an appropriate approach. As described in LRA Section B.2.20, detailed procedural requirements for the program will be developed. Areas with highest likelihood of corrosion may be identified based on review of site specific operating experience in which degradation has occurred.
The staff finds this response acceptable because the applicant will remain cognizant of industry techniques and will apply the most effective approach available.
Operating Experience. LRA Section B.2.20 states that industry operating experience shows that carbon steel and cast iron buried components experience corrosion degradation. Critical areas 3-28
 
include where the component transitions from above to below ground, where coatings are often missing or damaged.
Leaks in HNP buried piping components have been repaired, a demonstration that leaks have been detected and appropriate corrective actions taken to prevent loss of component intended function in the period of extended operation.
Based on plant-specific operating experience, periodic excavations of buried piping for inspection will not be specified; however, a minimum frequency of at least one buried piping inspection each 10-years will be required. The Buried Piping and Tanks Inspection Program is new; therefore, operating experience to verify the effectiveness of the program is not available.
With additional operating experience, lessons learned may adjust this program.
The staff reviewed selected corrective action documents on leaks in buried piping. Some leaks due to soil settlement were not age-related. Where piping from the jockey fire pump discharge leaked at a mechanical joint further review found the carbon steel bolts heavily corroded due to a lack of protective coatings. This condition was an error of omission because HNP procedures require protective coatings on all mechanical joints. There have been no other such failures over 20 years of operation. The staffs review of plant-specific operating experience confirmed that HNP had detected leaks in the underground piping and taken appropriate corrective actions; furthermore, discussions with HNP personnel confirmed that, as part of the operating experience program element, the Buried Piping and Tanks Inspection Program would review new industry experience for potential impact.
During the audit and review, the staff asked the applicant to specify the buried piping systems, locations, and root cause(s) of the leaks experienced and to clarify whether the degraded locations were ASME Code Class and how they had been repaired.
In its response dated August 20, 2007, the applicant stated:
HNP operating experience reviews have identified that underground piping leaks have occurred.
For non-ASME Code Class pipe:
* An underground leak on the discharge line of the diesel driven fire pump.
The one GPM leak originated from a 90 degree elbow mechanical joint.
The cause of the leak appears to be differential settlement of the soil backfill supporting the fire line. This leak is not considered age-related degradation.
* The 3 inch piping of the jockey fire pump discharge was found to be leaking at a mechanical joint. Some of the carbon steel bolts used to connect the flanges together were found to be extremely corroded to the extent that the bolts were no longer structurally functional. All mechanical joints are required to have a protective coating applied (such as Flaketar 3-29
 
coal tar epoxy). These joints did not appear to have any substantial application of protective coating. Flaketar coating was used on the joint prior to backfill.
* The site fire water system contains piping components that are flanged to underground piping, e.g., hydrants, valves, pipe sections. Similar to other piping components, the bolting is required to have protective coatings, e.g., Flaketar coal tar epoxy. The lack of coating in this case was assumed to be an error of omission as no other failures of this nature have been identified in over 20 years of operation.
* A leak was traced to the 12" fire header on the discharge of the motor driven fire pump. The leaks were found at two adjacent mechanical joint flanged connections. This leakage at a buried joint was identified and attributed to soil settlement at a flanged connection and is not considered age-related degradation. A contributing factor is that the gasket loses some of its elasticity due to age and hardens. The leaking flanged connections were replaced using new gaskets and new flanges. Gaskets are considered to be subcomponents of the piping and not credited as pressure boundary components. For license renewal, gaskets are considered to be consumables as discussed in SRP-LR Table 2.1-3.
* A potable water line was installed very close to the yard grade, about one foot below the yard surface north of Unit 2. A forklift carrying materials heavier than a normal forklift traveled over this underground piping. The action of the heavy load movements caused the line to break. This piping leak was due to localized heavy load movements and is not considered age-related degradation.
For ASME Code Class pipe:
* During the 10 year pressure testing of fuel oil system buried piping in Refueling Outage 13, a leak was identified in the diesel fuel oil piping from a main diesel fuel oil storage tank to the day tank. The "A" train piping was unable to hold the required pressure. The leakage was isolated to a section of pipe under the Diesel Generator Building. The section of pipe under the building was abandoned and the underground piping was brought above ground just outside the building. The new piping from the buried line enters the Diesel Generator Building above grade level.
The location of the piping leakage was abandoned in place. The investigation concluded that: Due to the location of the leak underneath the EDG Building, the pipe section with the leak could not be visually inspected; the apparent cause is a piping through-wall leak caused by exterior corrosion at a location where the coating was either defective or damaged during installation.' The subject section of diesel fuel oil piping is ASME Code Class 3.
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The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.20, the applicant provided the FSAR supplement for the Buried Piping and Tanks Inspection Program and by letter dated August 20, 2007, stated Commitment No. 16 to implement the Buried Piping and Tanks Inspection Program prior to the period of extended operation. The staff reviewed this section and determined that, with Commitment No. 16, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Buried Piping and Tanks Inspection Program, the staff finds, with Commitment No. 16, all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.7 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Summary of Technical Information in the Application. LRA Section B.2.24 describes the new Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program as consistent with GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program will be implemented by existing predictive maintenance, preventive maintenance, surveillance testing, and periodic testing work order tasks that provide opportunities for the visual inspection of internal surfaces of piping, piping elements, ducting, and components. Periodic internal inspections of components detect component degradation for timely determination of appropriate corrective actions. The program work activities will monitor parameters (e.g.,
change in material properties, cracking, flow blockage, loss of material, and reduction of heat transfer effectiveness) by visual inspection. The extent and schedule of inspections and testing assure detection of component degradation prior to loss of intended functions.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff interviewed the applicant's technical personnel and reviewed its Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program basis documents assessing program consistency with GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
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In particular, the staff reviewed for this AMP the applicants license renewal basis calculation, which assesses the consistency of the program elements with those recommended in GALL AMP XI.M38. Specifically, the staff compared the program element descriptions (documented in SER Section 3.0.2.1) in the license renewal basis calculation to the program element criteria recommended in GALL AMP XI.M38, Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components, for whether the program elements for the applicants AMP were consistent with the guidelines recommended in the GALL AMP.
During the audit, the staff asked the applicant for the definition of inaccessible components and how it will inspect such components during the period of extended operation.
The applicant stated that a component in a high-radiation area or with some physical restraint or other condition that would render examination impractical by exposing plant personnel to undue hazard is inaccessible. Components inaccessible during power operations are examined during refueling outages. The applicant clarified that, for components inaccessible due to either physical constraint or personnel hazards, components of similar materials and subject to similar environments may be examined as alternatives with documented justification for their use. The applicant stated that, if the examination of an alternate component finds degradation, an evaluation will justify whether the inaccessible component is acceptable for further service.
The staff concluded that examinations of alternate components are acceptable in managing potential aging in inaccessible components because the applicant will examine similarly-fabricated components exposed to similar environments to evaluate the inaccessible components and will apply the experience gained from the examination to evaluate whether the inaccessible component is acceptable for further service. The staffs question is resolved Based on its review of the program elements as described in the license renewal basis calculation for the AMP and for which the applicant claimed consistency with program elements of GALL AMP XI.M38, the staff finds the program elements for this AMP consistent with those of GALL AMP XI.M38 and acceptable.
The staff noted that the LRA and the license renewal basis calculation for this new Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program indicate that it will be implemented prior to the period of extended operation. The staff verified that the applicant had included the need to implement the Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program prior to the period of extended operation (Commitment No. 20).
On the bases that the new Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Program is consistent with the program elements defined in GALL AMP, XI.M38, Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components, and within the scope of LRA Commitment No. 20, the staff concludes that the AMP will adequately manage the aging effects for which the LRA credits it.
Operating Experience. LRA Section B.2.24 states that the new Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program has no operating experience. The 3-32
 
Inspection of Internal Surfaces Program will be implemented via existing predictive maintenance, preventive maintenance, surveillance testing and periodic testing work order tasks that have been in place since the plant began operation and have proven effective at maintaining SSC material condition and detecting unsatisfactory conditions. System engineers review operating experience for possible impact on equipment in their systems. The bases for parameters monitored and inspection intervals are vendor recommendations, historical performance, and industry operating experience. Operating experience is disseminated and evaluated as described in the Operating Experience Program.
The staff reviewed the operating experience in the LRA and interviewed the applicants technical personnel to confirm whether plant-specific operating experience revealed degradation not bounded by industry operating experience. The staff finds that the Corrective Action Program, which records plant-specific and industry operating experience issues, will review incorporate operating experience as objective evidence of adequate management of aging effects.
The applicant stated that there is no operating experience for the new Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program, which is consistent with the corresponding program described in the GALL Report.
The staff asked the applicant for a sample of the plant-specific operating experience for components within the scope of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program even if accumulated under a different AMP. The applicants response listed three action requests written on these components.
The staff reviewed two of the three action requests on the components within the scope of the Inspection of Internal Surfaces In Miscellaneous Piping and Ducting Components Program, which did not monitor and detect the degradation that had occurred: (1) one dated April 24, 2000, on degradation detected in the train A condensate pump suction expansion and (2) another dated March 25, 2001, on detection of an oil leak in the high-pressure seal backup oil pump. The staff determined that the applicants root-cause analyses of the degradation described in these action reports and its actions taken to repair or replace the impacted components prior to returning them to service had been appropriate. Based on this determination, the staff concluded that the applicant has taken appropriate action to correct any previous degradation detected in components within the scope of this AMP, even that detected by implementation of some other program.
Based on this review, the staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.24, the applicant provided the FSAR supplement for the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
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Conclusion. On the basis of its audit and review of the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.8 Electrical Cables and Connections not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Summary of Technical Information in the Application. LRA Section B.2.33 describes the new Electrical Cables and Connections not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program as consistent with GALL AMP XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
The Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is credited for the aging management of cables and connections not included in the Environmental Qualification (EQ) Program. Accessible electrical cables and connections installed in adverse environments are inspected visually at least every 10-years for cable and connection jacket surface anomalies (e.g., embrittlement, discoloration, cracking, swelling, or surface contamination) which are precursor indications of conductor insulation aging degradation from heat, radiation, or moisture. An adverse environment is a plant area condition significantly more severe than the specified service condition for the electrical cable or connection. The aging effects or mechanisms of concern are reduced insulation resistance and electrical failure. The technical basis for selecting the sample of cables and connections for inspection is defined in the implementing program document.
Sample locations will consider the locations of cables and connections inside and outside containment as well as any known adverse environments.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the information in LRA Section B.2.33 describing the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, interviewed the applicant's technical personnel, and reviewed the program basis documents, specifically the program elements basis documents, for consistency with GALL AMP XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
The LRA Section B.2.33 program description states that the technical basis for selecting cable and connection samples for inspection is defined in the program implementing document.
During the audit and review, the staff asked the applicant to explain the sample selection method for cables and connections from accessible areas and to clarify whether they represent, with reasonable assurance, all cables and connections included in the program as in GALL AMP XI.E1. The staff asked the applicant also to explain inspection sample expansion and 3-34
 
corrective actions if an inspection finds an unacceptable cable or connection condition or situation in a sample.
The applicants response dated August 20, 2007, stated, The sample selection method used in the implementing HNP program document follows the guidance of GALL AMP XI.E1, whereby a representative sample of accessible electrical cables and connections installed in adverse localized environments are visually inspected and represent, with reasonable assurance, all cables and connections in that area. An adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service condition for the electrical cable or connection. The HNP program utilizes plant operating experience (OE) to determine the plant areas to be inspected. HNP OE is used to identify past cable failures, cables that exhibited the effects of aging, hot spots, and adverse localized environments.
Part of this OE review includes conversations with maintenance personnel and the use of environmental surveys. Based on this review of OE, the plant areas to be inspected become localized in nature, consisting of a limited area (or subset) of a much larger plant area or zone. The sample selection of cables and connections inspected within the limited plant area bound all cables and connections in the area since the inspection focuses on the worst case environments.
Corrective actions such as expansion of the sample size will be implemented through the HNP Corrective Action Program. The Corrective Action Program is implemented by the HNP QA Program in accordance with 10 CFR 50, Appendix B.
The staff finds the applicant's response acceptable because (1) the applicant has explained that it utilizes operating experience to determine the plant areas to be inspected and the sample selection method for cables and connections from accessible areas so they represent, with reasonable assurance, all cables and connections consistent with the guidance of GALL AMP XI.E1 and (2) the applicant has clarified that when it finds an unacceptable condition or situation its Corrective Action Program determines whether this same condition or situation could apply to other accessible or inaccessible insulated cables and connections.
The staff finds the applicants Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program consistent with the recommended GALL AMP XI.E1 and acceptable.
Operating Experience. LRA Section B.2.33 states that the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program has no plant-specific operating experience; however, as noted in the GALL Report, industry operating experience shows that adverse heat or radiation environments for electrical cables and connections cause visually observable degradation of insulating materials.
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The staff reviewed the operating experience in the LRA and interviewed the applicants technical personnel to confirm whether this program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10.
The LRA states that there is no plant-specific operating experience history for the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. Noting that SRP-LR, Revision 1, Appendix A, Branch Technical Position RLSB-1, states that an applicant may have to submit future operating experience for new programs to confirm their effectiveness, the staff asked the applicant to describe how it would record operating experience to confirm program effectiveness and how it would adjust the program as needed.
The applicants response dated August 20, 2007, stated:
Plant-specific and industry wide operating experience was considered in the development of the Appendix B electrical programs. Industry operating experience that forms the basis for these Appendix B electrical programs is included in the operating experience element of the corresponding GALL Report Chapter XI Programs. Plant-specific operating experience was reviewed to ensure that the GALL Report Chapter XI Programs will be effective AMPs for the period of extended operation (PEO). This review is discussed in calculation HNP-P/LR-0300, Attachment 14. This review confirms that the operating experience discussed in the GALL Report Chapter XI Programs is bounding.
Operating experience going forward will be captured through the HNP Corrective Action and Operating Experience Programs implemented in accordance with Progress Energy Corporate procedures. This ongoing review of operating experience will continue throughout the PEO and the results will be maintained on site. The Corrective Action and Operating Experience Programs are implemented by the HNP QA Program in accordance with 10 CFR 50, Appendix B. This process will verify that the Appendix B electrical programs continue to be effective in the management of aging effects.
In the same August 20, 2007 letter, the applicant proposed to amend LRA Section B.2.33 to add this information to the operating experience program element.
The staff finds the response acceptable because the applicant has considered plant-specific and industry operating experience in the development of this program and has confirmed that the operating experience described in GALL AMP XI.E1 is bounding and that corrective action and operating experience programs implemented in accordance with corporate procedures will record future operating experience.
The staff interviewed the applicant's personnel, reviewed both its calculation and a sample of plant-specific operating experience with program components, and confirmed that plant-specific operating experience revealed no aging effects for components within the scope of this program not bounded by industry operating experience.
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On the basis of its review of operating experience and discussions with the applicants technical personnel, the staff concludes that the applicants Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.33, the applicant provided the FSAR supplement for the Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff also confirmed that the applicants license renewal commitment list shows this new program as Commitment No. 27 to be implemented prior to the period of extended operation.
Conclusion. The staff finds the applicants Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program consistent with all corresponding program elements of the GALL Report.
3.0.3.1.9 Electrical Cables and Connections not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits Program Summary of Technical Information in the Application. LRA Section B.2.34 describes the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits Program as consistent with GALL AMP XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.
The Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program is credited for the aging management of radiation monitoring and nuclear instrumentation cables not included in the Environmental Qualification (EQ) Program. Exposure of electrical cables to adverse environments caused by heat or radiation can result in reduced insulation resistance (IR). An IR reduction is a concern in circuits (e.g., radiation monitoring and nuclear instrumentation circuits) with sensitive high-voltage, low-level signals because it may contribute to signal inaccuracies.
For radiation monitoring circuits and the Regulatory Guide (RG) 1.97 wide range neutron flux monitoring circuits, review of surveillance testing calibration results or findings will detect potential cable system aging degradation. This review will be at least every 10-years with the first review completed before the end of the current license term. Cable systems in excore source, intermediate, and power range nuclear instrumentation circuits will be tested at a frequency not to exceed 10-years based on engineering evaluation with the first testing completed before the end of the current license term. Testing may include IR, time domain reflectometry, current versus voltage, or other testing effective in determining cable system insulation condition. The aging effects of concern are reduced IR and electrical failure.
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The scope of this program applies to non-EQ cable systems in process radiation monitoring instrumentation circuits, area radiation monitoring instrumentation circuits, and neutron flux monitoring instrumentation circuits sensitive to IR reduction. GALL AMP XI.E1 does not apply to cables in these instrumentation circuits.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the information in LRA Section B.2.34 describing the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program, interviewed the applicant's technical personnel, and reviewed the program basis documents, specifically the program elements basis documents, for consistency with GALL AMP XI.E2.
The staff noted that the scope of GALL AMP XI.E2 covers electrical cables and connections.
During the audit and review, the staff asked the applicant to clarify whether the tests include both cables and connections. The applicants response clarified that the Electrical Cables and Connections Not Subject to10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program includes both cables and connections within the scope of license renewal. The staff finds the applicant's response consistent with the GALL Report recommendation and acceptable.
LRA Section B.2.34 states that for radiation-monitoring and RG 1.97 wide-range neutron flux monitoring circuits, review of calibration results or findings of surveillance testing will detect potential cable system aging degradation. During the audit and review, the staff asked the applicant to clarify whether radiation monitoring and wide-range neutron monitoring cables are disconnected during calibration or surveillance testing.
In a letter dated August 20, 2007, the applicant stated that the radiation monitoring cables are connected as part of the overall loop calibration of the system but that the RG 1.97 wide-range neutron flux monitoring cable systems are disconnected during calibration; therefore, the cable systems in the RG 1.97 wide-range neutron flux monitoring circuits require testing to detect potential cable system aging degradation. The RG 1.97 wide-range neutron flux monitoring circuits are parts of the excore nuclear instrumentation system. Similar to the cable systems in the excore source, intermediate, and power range nuclear instrumentation circuits, the RG 1.97 wide-range neutron flux monitoring circuits will be tested at a frequency not to exceed 10 years based on engineering evaluation with the first testing to be completed before the end of the current license term.
In the same August 20, 2007, letter, the applicant proposed to amend LRA Section B.2.34 to add this information to the program description.
The staff finds the applicant's response acceptable because the program will monitor potential cable system aging degradation in radiation-monitoring and RG 1.97 wide-range neutron flux monitoring circuits consistently with the guidance of GALL AMP XI.E2.
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The staff noted that the GALL AMP XI.E2 program description states that exposure of electrical cables to adverse environments caused by heat, radiation, or moisture can reduce IR; however, LRA Section B.2.34 states that exposure of electrical cables to adverse environments caused by heat or radiation can reduce IR. The staff asked the applicant to explain why moisture is not specified as a cause of reduced IR as in GALL AMP XI.E2 and to clarify whether all instrumentation circuits susceptible to moisture and sensitive to signal inaccuracies are included in the Environmental Qualification (EQ) Program.
The applicant responded that the LRA Section B.2.34 summary-level program information does not exclude moisture, that the LRA Section B.2.34 conclusion includes moisture as well as heat and radiation, and that LRA Section 3.6.2.1.1 environments include moisture as a stressor. The applicant also stated that not all instrumentation circuits susceptible to moisture and sensitive to signal inaccuracies are in the Environmental Qualification (EQ) Program. To discover circuits not in that program, the applicant screened against GALL AMP XI.E2 criteria all impedance-sensitive circuits within the scope of license renewal likely to experience reduced IR due to heat, radiation, or moisture. The resultant list of impedance-sensitive neutron and radiation-monitoring signal cables that may experience reduced IR is in LRA Section B.2.34.
The staff reviewed the program basis documents that screened the circuits within the scope of this program. Based on the review, the staff determined that the applicant appropriately considered the adverse environments and specified consistently with GALL Report recommendations the circuits that could experience reduced IR.
The staff finds the applicants Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program consistent with GALL AMP XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, and acceptable.
Operating Experience. LRA Section B.2.34 states that the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program has no operating experience; however, as noted in the GALL Report, industry operating experience shows that exposure of electrical cables to adverse environments caused by heat or radiation can result in reduced IR, which causes an increase in leakage currents between conductors and from conductors to ground. IR reduction is a concern in circuits (e.g., radiation monitoring and nuclear instrumentation circuits) with sensitive high-voltage, low-level signals because it may contribute to signal inaccuracies.
The staff reviewed the operating experience in the LRA and interviewed the applicants technical personnel to confirm whether this program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10.
The LRA states that there is no plant-specific operating experience history for the new Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program. Noting that SRP-LR, Revision 1, Appendix A, Branch Technical Position RLSB-1, states that an applicant may have to submit future operating experience for new programs to confirm their effectiveness, the staff asked the applicant to describe how it would record operating experience to confirm program effectiveness and how it would adjust the program as needed.
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In its response dated August 20, 2007, the applicant stated:
Plant-specific and industry wide operating experience (OE) was considered in the development of the Appendix B electrical programs. Industry operating experience that forms the basis for these Appendix B electrical programs is included in the operating experience element of the corresponding GALL Report Chapter XI Programs. Plant-specific operating experience was reviewed to ensure that the GALL Report Chapter XI Programs will be effective AMPs for the PEO. This review is discussed in calculation HNP-P/LR-0300, Attachment 14.
This review confirms that the operating experience discussed in the GALL Report Chapter XI Programs is bounding. Operating experience going forward will be captured through the HNP Corrective Action and Operating Experience Programs implemented in accordance with Progress Energy corporate procedures. This ongoing review of operating experience will continue throughout the PEO and the results will be maintained on site. The Corrective Action and Operating Experience Programs are implemented by the HNP QA Program in accordance with 10 CFR 50, Appendix B. This process will verify that the Appendix B electrical programs continue to be effective in the management of aging effects.
In the same August 20, 2007 letter, the applicant proposed to amend LRA Section B.2.34 to add this information to the operating experience program element.
The staff finds the response acceptable because the applicant has considered plant-specific and industry operating experience in the development of this program and confirmed that corrective action and operating experience programs implemented in accordance with corporate procedures will record future operating experience.
The staff interviewed the applicant's personnel, reviewed its program basis calculation and a sample of plant-specific operating experience with program components, and confirmed that plant-specific operating experience revealed no aging effects for components within the scope of this program not bounded by industry operating experience.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.34, the applicant provided the FSAR supplement for the Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff also confirmed that the applicants license renewal commitment list shows this new program as Commitment No. 28 to be implemented prior to the period of extended operation.
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Conclusion. On the basis of its audit and review of the applicants Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.10 Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Summary of Technical Information in the Application. LRA Section B.2.35 describes the new Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program as consistent with GALL AMP XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
The Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is credited for aging management of cables not included in the Environmental Qualification (EQ) Program. In-scope, medium-voltage cables exposed to significant moisture and significant voltage are tested at least every 10-years for an indication of the condition of the conductor insulation. The specific type of test to be determined will be proven (e.g., power factor, partial discharge, polarization index) or other state-of-the-art testing at the time of the test for detecting deterioration of the insulation system due to wetting.
Significant moisture is defined as periodic exposures (e.g., cable in standing water) that last more than a few days. Periodic exposures (e.g., normal rain and drain) that last less than a few days are not significant. Significant voltage exposure is defined as subjection to system voltage for more than 25 percent of the time. Manholes for inaccessible non-EQ medium-voltage cables will be inspected for water accumulation and drained as needed. The manhole inspection frequency will be based on actual field data and shall not exceed two years.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the information in LRA Section B.2.35 describing the new Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, interviewed the applicant's technical personnel, and reviewed the program basis documents, specifically the program elements basis documents, for consistency with GALL AMP XI.E3.
During the audit and review, the staff asked the applicant whether the Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program includes all medium-voltage cables within the scope of license renewal and, if not, for a listing of such cables installed at HNP showing how the program screened them out. In response the applicant stated that it had included in the Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program only medium-voltage cables within the scope of license renewal 3-41
 
meeting certain GALL AMP XI.E3 criteria: (1) they are located underground and assumed wet and (2) they are energized at least 25 percent of the time. HNP screened out medium-voltage cables within the scope of license renewal not meeting these criteria and did not include them in the Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff reviewed the program basis calculation and plant drawings showing screening criteria, component and service descriptions, and reasons for exclusion for cables not included in the program. Based on the review, the staff determined that the applicant's program basis calculation appropriately considered, in accordance with GALL AMP XI.E3 recommendations, medium-voltage power cables most likely to be exposed to wet environments.
The staff finds the applicants Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program consistent with the recommended GALL AMP XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, and acceptable.
Operating Experience. LRA Section B.2.35 states that the new Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program has no operating experience; however, as noted in the GALL Report, industry operating experience shows that cross-linked polyethylene or high-molecular-weight polyethylene insulation materials are most susceptible to water tree formation. The formation and growth of water trees vary directly with operating voltage; for example, treeing is much less prevalent in 4kV cables than those operated at 13 or 33kV. Finally, minimizing exposure to moisture minimizes the potential for water tree development.
The LRA states that there is no plant-specific operating experience history for the new Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. Noting that SRP-LR, Revision 1, Appendix A, Branch Technical Position RLSB-1, states that an applicant may have to submit future operating experience for new programs to confirm their effectiveness, the staff asked the applicant to describe how it would record operating experience to confirm program effectiveness and how it would adjust the program as needed.
In its response dated August 20, 2007, the applicant stated:
Plant-specific and industry wide operating experience (OE) was considered in the development of the Appendix B electrical programs. Industry operating experience that forms the basis for these Appendix B electrical programs is included in the operating experience element of the corresponding GALL Report Chapter XI Programs. Plant-specific operating experience was reviewed to ensure that the GALL Report Chapter XI Programs will be effective AMPs for the period of extended operation (PEO). This review is discussed in Calculation HNP-P/LR-0300, Attachment 14. This review confirms that the operating experience discussed in the GALL Report Chapter XI Programs is bounding.
Operating experience going forward will be captured through the HNP Corrective Action and Operating Experience Programs implemented in accordance with Progress Energy corporate procedures. This ongoing review of operating 3-42
 
experience will continue throughout the PEO and the results will be maintained on site. The Corrective Action and Operating Experience Programs are implemented by the HNP QA Program in accordance with 10 CFR 50, Appendix B. This process will verify that the Appendix B electrical programs continue to be effective in the management of aging effects.
In the same August 20, 2007 letter, the applicant proposed to amend LRA Section B.2.35 to add this information to the operating experience program element.
The staff finds the response acceptable because the applicant has considered plant-specific and industry operating experience in the development of this program and has confirmed that the operating experience described in GALL AMP XI.E1 is bounding and that corrective action and operating experience programs implemented in accordance with corporate procedures will record future operating experience.
The staff interviewed the applicant's personnel, reviewed the applicant's calculation and a sample of evaluations of plant-specific and industry operating experience of cables in the program, and confirmed that plant-specific operating experience revealed no aging effects for cables within the scope of this program not bounded by industry operating experience.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.35, the applicant provided the FSAR supplement for the Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff also confirmed that the applicants license renewal commitment list shows this new program as Commitment No. 29 to be implemented prior to the period of extended operation.
Conclusion. On the basis of its audit and review of the applicants Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.11 Metal Enclosed Bus Program Summary of Technical Information in the Application. LRA Section B.2.36 describes the new Metal Enclosed Bus Program as consistent with GALL AMP XI.E4, Metal Enclosed Bus.
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The Metal Enclosed Bus Program is credited for aging management of the isophase bus as well as nonsegregated 6.9 kV and 480 V metal enclosed buses (MEBs) within the scope of license renewal. The program involves various activities conducted at least once every 10-years to identify potential aging degradation. In this AMP a sample of accessible bolted connections will be checked for loose connection by thermography or by connection resistance measurement with a low-range ohmmeter. In addition, internal portions of the bus enclosure will be inspected visually for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of moisture intrusion. The bus insulation will be visually inspected for signs of embrittlement, cracking, melting, swelling, or discoloration which may indicate overheating or aging degradation. Internal bus supports will be visually inspected for structural integrity and signs of cracking.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the information in LRA Section B.2.36 describing the new Metal Enclosed Bus Program, interviewed the applicants technical personnel, and reviewed its Metal Enclosed Bus Program basis documents assessing program consistency with GALL AMP XI.E4.
The staff concludes that the applicants Metal Enclosed Bus Program assures management of aging effects caused by cracked insulation, moisture, debris in the bus enclosure, and loosening of bolted connections consistent with the CLB during the period of extended operation. The staff finds the applicants Metal Enclosed Bus Program consistent with the recommended GALL AMP XI.E4, Metal Enclosed Bus, and acceptable.
Operating Experience. LRA Section B.2.36 states that the new Metal Enclosed Bus Program has no plant-specific operating experience. Industry experience shows that failures on MEBs have been caused by cracked insulation and moisture or internal debris buildup and that MEB bus connections exposed to appreciable ohmic heating during operation may experience loosening due to repeated cycling of connected loads.
The LRA states that there is no plant-specific operating experience history for the new Metal Enclosed Bus Program. Noting that SRP-LR, Revision 1, Appendix A, Branch Technical Position RLSB-1, states that an applicant may have to submit future operating experience for new programs to confirm their effectiveness, the staff asked the applicant to describe how it would record operating experience to confirm program effectiveness and how it would adjust the program as needed.
In its response dated August 20, 2007, the applicant stated:
Plant-specific and industry wide operating experience (OE) was considered in the development of the Appendix B electrical programs. Industry operating experience that forms the basis for these Appendix B electrical programs is included in the operating experience element of the corresponding GALL Report Chapter XI Programs. Plant-specific operating experience was reviewed to ensure that the GALL Report Chapter XI Programs will be effective AMPs for the 3-44
 
period of extended operation (PEO). This review is discussed in Calculation HNP-P/LR-0300, Attachment 14. This review confirms that the operating experience discussed in the GALL Report Chapter XI Programs is bounding.
Operating experience going forward will be captured through the HNP Corrective Action and Operating Experience Programs implemented in accordance with Progress Energy corporate procedures. This ongoing review of operating experience will continue throughout the PEO and the results will be maintained on site. The Corrective Action and Operating Experience Programs are implemented by the HNP QA Program in accordance with 10 CFR 50, Appendix B. This process will verify that the Appendix B electrical programs continue to be effective in the management of aging effects.
In the same August 20, 2007 letter, the applicant proposed to amend LRA Section B.2.36 to add this information to the operating experience program element.
The staff finds the response acceptable because the applicant has considered plant-specific and industry operating experience in the development of this program and has confirmed that the operating experience described in GALL AMP XI.E1 is bounding and that corrective action and operating experience programs implemented in accordance with corporate procedures will record future operating experience.
The staff interviewed the applicant's personnel, reviewed the applicant's calculation and a sample of evaluations of plant-specific and industry operating experience, and confirmed that plant-specific operating experience revealed no aging effects for components within the scope of this program not bounded by industry operating experience.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.36, the applicant provided the FSAR supplement for the Metal Enclosed Bus Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff also confirmed that applicants license renewal commitment list shows this new program as Commitment No. 30 to be implemented prior to the period of extended operation.
Conclusion. On the basis of its audit and review of the applicants Metal Enclosed Bus Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
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3.0.3.1.12 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Summary of Technical Information in the Application. LRA Section B.2.37 describes the new Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program as consistent with GALL AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
The Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is credited for aging management of cable connections not included in the Environmental Qualification (EQ) Program. Samplings of cable connections within the scope of license renewal will be tested at least every 10-years for an indication of cable connection integrity. The specific type of test to be determined will be proven (e.g.,
thermography, contact resistance testing, bridge balance testing) or other appropriate testing for detecting loose connections judged to be effective in determining cable connection integrity.
The aging effect or mechanism of concern is loosening of cable connections. The technical basis for the sample selections of cable connections to be tested will be provided. The scope of this sampling program will include electrical cable connections in power and I&C applications as well as connections in areas with corrosive chemicals and in outdoor structures in uncontrolled environments. In addition, the program will include the bolted connections on the overhead transmission conductors from the high-voltage bushings on the main power transformers to the switchyard bus.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the information in LRA Section B.2.37 describing the new Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, interviewed the applicant's technical personnel, and reviewed the program basis documents, specifically the program elements basis documents, for consistency with GALL AMP XI.E6.
GALL AMP XI.E6 states that an unacceptable condition or situation found in a selected sample requires a determination as to whether the same condition or situation is present in other connections not tested. As the LRA did not refer to this recommendation, the staff asked the applicant to clarify whether it would implement this recommendation for LRA Section B.2.37.
The applicant responded that the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is consistent with GALL AMP XI.E6. If the program finds an unacceptable condition or situation a selected sample, the HNP corrective action program determines whether the same condition or situation is present in other connections not tested. The staff determined that the applicants response is consistent with the GALL AMP XI.E6 recommendation, included in the applicant's program basis calculation, and acceptable.
The applicant's program basis calculation states that the scope of the program and detection of aging effects program elements are not consistent with the corresponding GALL AMP XI.E6 3-46
 
program elements; however, the noting that LRA Section B.2.37 states that all elements of this program are consistent with GALL AMP XI.E6, the staff asked the applicant why LRA Section B.2.37 does not state these exceptions and technical justifications for them.
In a letter dated August 20, 2007, the applicant stated that the program basis calculation followed submission of the LRA in 2006. The basis for this revision was the NRC letter dated March 16, 2007, Staff Response to the Nuclear Energy Institute (NEI) White Paper on Generic Aging Lessons Learned (GALL) Report Aging Management Program (AMP) XI.E6, 'Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirement.
The applicant stated that it would amend LRA Section B.2.37 to show the following exceptions and their bases:
Under the program element scope of the program, GALL AMP XI.E6 states Connections associated with cables within the scope of license renewal are part of this program, regardless of their association with active or passive components.
Consistent with the clarification provided in the NRC letter, this element of Calculation No. HNP-P/LR-0668 was revised to read The HNP AMP applies to cables connections within the scope of license renewal not covered under the existing EQ program. The scope of this program includes only external cable connections terminating at an active device such as motor, motor control center, switchgear or of a passive device such as a fuse cabinet. Wiring connections internal to an active assembly installed by manufacturers are considered a part of the active assembly and therefore are not within the scope of this program.
Under the program element detection of aging effects GALL AMP XI.E6 states Electrical connections within the scope of license renewal will be tested at least once every 10 years. Testing may include thermography, contact resistance testing, or other appropriate testing methods. This is an adequate period to preclude failures of the electrical connections since experience has shown that aging degradation is a slow process. A 10-year testing interval will provide two data points during a 20-year period, which can be used to characterize the degradation rate. The first tests for license renewal are to be completed before the period of extended operation.
Consistent with the test frequency flexibility provided in the NRC letter, this element of Calculation No. HNP-P/LR-0668 was revised to read This program will be implemented as a one-time inspection on a representative sample of non-EQ cable connections within the scope of license renewal prior to the period of extended operation. Inspection methods may include thermography, contact resistance testing, bridge balance testing, or other appropriate testing methods.
This one-time inspection verifies that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation is not an aging effect that requires a periodic aging management program.
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GALL AMP XI.E6 along with the clarification provided in the NRC letter forms the technical basis and justification for the HNP program described in LRA Section B.2.37.
In the same August 20, 2007 letter, the applicant proposed to amend LRA Section B.2.37 to add this information.
The staff reviewed the applicants exceptions to the program elements scope of the program, and detection of aging effects and determined that the scope of the program exception, which includes only external cable connections terminating at an active device (e.g., motor, motor control center, switchgear) or a passive device (e.g., fuse cabinet) is consistent with the staff's proposed revision to the GALL AMP XI.E6, adequate to manage the potential aging of electrical cable connections not subject to 10 CFR 50.49 EQ requirements, and acceptable.
In addition, the staff determined that the detection of aging effects exception, which includes a one-time inspection of a representative sample of non-EQ cable connections within the scope of license renewal prior to the period of extended operation, is consistent with the staff's proposed revision to the GALL AMP XI.E6, adequate to manage the potential aging of electrical cable connections not subject to 10 CFR 50.49 EQ requirements, and acceptable. The staff notes that the applicant will take corrective actions in accordance with the HNP corrective action process when the one-time inspection finds problems. Corrective actions may include but are not limited to sample expansion, increased inspection frequency, and replacement or repair of the affected cable connection components.
Operating Experience. LRA Section B.2.37 states that the new Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program has no operating experience; however, as noted in the GALL Report, industry operating experience shows that circuits exposed to appreciable ohmic or ambient heating during operation may experience loosening due to repeated cycling of connected loads or to the ambient temperature.
The LRA states that there is no plant-specific operating experience history for the new Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. Noting that SRP-LR, Revision 1, Appendix A, Branch Technical Position RLSB-1, states that an applicant may have to submit future operating experience for new programs to confirm their effectiveness, the staff asked the applicant to describe how it would record operating experience to confirm the program effectiveness and how it would adjust the program as needed.
In its response dated August 20, 2007, the applicant stated:
Plant-specific and industry wide operating experience (OE) was considered in the development of the Appendix B electrical programs. Industry operating experience that forms the basis for these Appendix B electrical programs is included in the operating experience element of the corresponding GALL Report Chapter XI Programs. Plant-specific operating experience was reviewed to 3-48
 
ensure that the GALL Report Chapter XI Programs will be effective AMPs for the period of extended operation (PEO). This review is discussed in Calculation No. HNP-P/LR-0300, Attachment 14. This review confirms that the operating experience discussed in the GALL Report Chapter XI Programs is bounding.
Operating experience going forward will be captured through the HNP Corrective Action and Operating Experience Programs implemented in accordance with Progress Energy corporate procedures. This ongoing review of operating experience will continue throughout the PEO and the results will be maintained on site. The Corrective Action and Operating Experience Programs are implemented by the HNP QA Program in accordance with 10 CFR 50, Appendix B. This process will verify that the Appendix B electrical programs continue to be effective in the management of aging effects.
In the same August 20, 2007 letter, the applicant proposed to amend LRA Section B.2.37 to add this information to the operating experience program element.
The staff finds the applicant's response acceptable because the applicant has considered plant-specific and industry wide operating experience in the development of this program and has confirmed that the operating experience described in GALL AMP XI.E6 is bounding and that corrective action and operating experience programs implemented in accordance with corporate procedures will record future operating experience.
The staff interviewed the applicant's personnel, reviewed the applicant's calculation and a sample of applicant's evaluations of plant-specific and industry operating experience, and confirmed that plant-specific operating experience revealed no aging effects for components within the scope of this program not bounded by industry operating experience.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.37, the applicant provided the FSAR supplement for the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff also confirmed that the applicants license renewal commitment list shows this new program as Commitment No. 31 to be implemented prior to the period of extended operation.
Conclusion. On the basis of its audit and review of the applicants Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program, the staff finds all program elements consistent with the GALL Report. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which it is credited. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the 3-49
 
intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.1.13 Environmental Qualification (EQ) Program Summary of Technical Information in the Application. LRA Section B.3.2 describes the existing Environmental Qualification (EQ) Program as consistent with GALL AMP X.E1, Environmental Qualification (EQ) of Electric Components.
The Environmental Qualification (EQ) Program manages component thermal, radiation, and cyclical aging by evaluations based on 10 CFR 50.49(f) qualification methods. As required by 10 CFR 50.49, EQ components not qualified for the current license term must be refurbished or replaced or their qualification must be extended before the aging limits established in the evaluation. Aging evaluations for EQ components that specify a qualification of at least 40-years are time-limited aging analyses (TLAAs) for license renewal.
Staff Evaluation. During its audit and review, the staff reviewed the applicants claim of consistency with the GALL Report.
The staff reviewed the information in LRA Section B.3.2 describing the existing Environmental Qualification (EQ) Program, interviewed the applicant's technical personnel, and reviewed the applicant's program basis documents, specifically, the program elements basis documents, for consistency with GALL AMP X.E1.
The staff noted that the GALL AMP X.E1 program description states that important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).
During the audit and review, the staff asked the applicant why LRA Section B.3.2 does not address these attributes as recommended in GALL AMP X.E1. In response, the applicant stated that LRA Sections 4.4.1 and 4.4.2 address these attributes. The staff reviewed those LRA sections and the program basis calculation and determined that the applicants description of the EQ component reanalysis attributes as specified in GALL AMP X.E1 is adequate and acceptable.
The staff noted that the program basis calculation states that the EQ program conforms to RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, Revision 0, not Revision 1; however, GALL AMP X.E1 recommends RG 1.89, Revision 1, as regulatory guidance for compliance with 10 CFR 50.49. During the audit and review, the staff asked the applicant why LRA Section B.3.2 program elements parameters monitored or inspected and scope of the program do not state this exception and its technical basis. In response, the applicant stated that the Environmental Qualification (EQ) Programs licensing basis is RG 1.89, Revision 0, an exception to GALL AMP X.E1, which recommends RG 1.89, Revision 1, and that the original program licensing basis is not RG 1.89, Revision 1. HNP was licensed originally as a NUREG-0588, Category II plant, and 3-50
 
IEEE Standard 323-1971 was the original EQ program basis. RG 1.89, Revision 1, had not been issued when the HNP construction permit SER was issued. Currently, the EQ program meets 10 CFR 50.49 requirements for electrical components important to safety. The applicant also stated that it will amend LRA Section B 3.2 to state this exception to GALL AMP X.E1.
In a letter dated August 20, 2007, the applicant amended LRA Section B.3.2 to state an exception to the parameters monitored or inspected and scope of the program program elements. The staff determined that this exception is acceptable because the applicant meets 10 CFR 50.49 requirements by implementing the program in accordance with NUREG-0588 guidance, which is consistent with the staff's review guidance in SRP-LR Section 4.4.1.1.2 (which states that the qualification of safety-related electric equipment in accordance with NUREG-0588, Category II, will be reviewed for the period of extended operation to assess the validity of the extended qualification).
On the basis of its review, the staff concludes that the applicants Environmental Qualification (EQ) Program reasonably assures management of thermal, radiation, and cyclical aging effects for safety-related electrical equipment in harsh environments. The staff finds the applicants Environmental Qualification Program consistent with recommended GALL AMP X.E1, Environmental Qualification (EQ) of Electric Components, and acceptable.
Operating Experience. LRA Section B.3.2 states that the Environmental Qualification (EQ)
Program has managed aging effects effectively. As stated in the GALL Report, EQ programs consider operating experience to modify qualification bases and conclusions, including qualified life. Compliance with 10 CFR 50.49 provides reasonable assurance that components can perform intended functions during accident conditions despite the effects of in-service aging.
The excellent operating experience of the systems and components in the program demonstrates its overall effectiveness. Administrative controls continue to require periodic formal internal and external assessments of the Environmental Qualification (EQ) Program by knowledgeable personnel from outside the site EQ group to affect continuous improvement.
The staff reviewed the operating experience in the LRA and interviewed the applicants technical personnel to confirm whether this program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10.
In reviewing examples of applicant's operating experience evaluations, the staff noted that the Environmental Qualification (EQ) Program continuously monitors the qualification basis for all EQ equipment, including aging effects and their impact on equipment qualified life.
For example, the applicant developed a plant change request to evaluate the EQ impact on containment temperature data of 11 resistance temperature detectors installed by a temporary modification to determine actual containment temperatures. As a result of the request, re-calculation of 12 EQ documentation packages ensured that component qualified lives were met.
Another plant change request evaluated the main steam tunnel qualified life calculations based on outdoor temperature. A higher outdoor temperature ultimately changed the technical 3-51
 
specification/FSAR by raising the main steam tunnel ambient temperature. The plant change request revised all EQ documentation impacted by the technical specification/FSAR change.
These examples illustrate the applicants actions to maintain component EQ in accordance with10 CFR 50.49 and its Environmental Qualification (EQ) Program has been effective at managing aging effects. The staff also reviewed a corrective action report of industry operating experience with slow stroke time of solenoid operated valves. As a result of this report, the applicant revised the EQ documentation package for two solenoid operated valves to reflect the accurate service life energization time of these EQ components. This incident is an example of Environmental Qualification (EQ) Program reaction to operating experience to assure continued equipment EQ.
In reviewing a recent self-assessment report, the staff noted a variety of improvement opportunities but no issues or findings impacting EQ program effectiveness.
Based on its review, the staff concluded that the corrective action program, which records plant-specific and industry operating experience issues, will review and incorporate operating experience for objective evidence of adequate management of aging effects.
On the basis of its review of the operating experience and discussions with the applicant's technical personnel, the staff concludes that the applicants Environmental Qualification (EQ)
Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.39, the applicant provided the FSAR supplement for the Environmental Qualification (EQ) Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Environmental Qualification (EQ) Program, the staff finds all program elements consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2 AMPs Consistent with the GALL Report with Exceptions or Enhancements In LRA Appendix B, the applicant stated that the following AMPs are, or will be, consistent with the GALL Report, with exceptions or enhancements:
* ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program
* Reactor Head Closure Studs Program 3-52
* Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure of Pressurized Water Reactors Program
* Flow-Accelerated Corrosion Program
* Bolting Integrity Program
* Steam Generator Tube Integrity Program
* Closed-Cycle Cooling Water System Program
* Boraflex Monitoring Program
* Inspection of Overhead Heavy Load and Light Load Handling Systems Program
* Fire Protection Program
* Fire Water System Program
* Fuel Oil Chemistry Program
* Reactor Vessel Surveillance Program
* Selective Leaching of Materials Program
* One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program
* External Surfaces Monitoring Program
* Flux Thimble Tube Inspection Program
* Lubricating Oil Analysis Program
* ASME Section XI, Subsection IWE Program
* ASME Section XI, Subsection IWL Program
* ASME Section XI, Subsection IWF Program
* 10 CFR Part 50, Appendix J Program
* Masonry Wall Program
* Structures Monitoring Program
* RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program
* Reactor Coolant Pressure Boundary Fatigue Monitoring Program For AMPs that the applicant claimed are consistent with the GALL Report, with exception(s) and/or enhancement(s), the staff performed an audit and review to confirm that those attributes or features of the program for which the applicant claimed consistency were indeed consistent.
The staff also reviewed the exception(s) and/or enhancement(s) to the GALL Report to determine whether they were acceptable and adequate. The results of the staffs audits and reviews are documented in the following sections.
3.0.3.2.1 ASME Section XI, Inservice Inspection, Subsections IWB, IWC and IWD Program Summary of Technical Information in the Application. LRA Section B.2.1 describes the existing ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program as consistent, with exception, with GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD.
The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program consists of periodic volumetric, surface, and/or visual examination and leakage testing of Classes 1, 2, and 3 pressure-retaining components and their attachments to detect component degradation 3-53
 
and determine appropriate corrective actions. The program for the second 10-year interval was developed to meet ASME Code Section XI, 1989 Edition (no addenda) standards.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exception to determine whether the AMP, with the exception, remained adequate to manage the aging effects for which the LRA credits it.
The staff interviewed the applicants technical personnel and reviewed supporting bases documents, procedures, reports, and calculations for the ASME Section XI, Inservice Inspection, Subsections IWB, IWC and IWD Program, including the license renewal basis calculation, the applicants 10-year inservice inspection (ISI) plan, and the applicants administrative control procedures for implementing the ISI plan. Specifically, the staff reviewed the program description and the program elements and bases in the license renewal basis calculation for whether the program elements are consistent with the corresponding program elements of GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD.
The staff noted that the license renewal basis calculation for this AMP establishes how it compares to program elements in GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, and states the bases for any exception to the GALL AMP.
The staff determined that the applicants 10-year ISI plan governs specific ISI examinations and activities required for the current 10-year ISI interval and that the ISI plan (1) establishes which plant systems and components are within the scope of 10 CFR 50.55a and ASME Code Section XI, (2) defines the ASME Code classifications for systems and components within the scope of the ISI plan, (3) establishes visual examinations and non-destructive examination inspections (including surface and volumetric examinations) for these systems and components during the 10-Year ISI Interval in effect, and (4) establishes for ASME Code Class systems and components augmented inspections that go beyond examinations required by ASME Code Section XI.
The staff also noted that the applicants administrative control procedures for the ISI plan define the administrative controls and activities for implementation of the ASME Section XI, Subsections IWB, IWC and IWD Inservice Inspection Program and the ISI plan in accordance with 10 CFR 50.55a and ASME Code Section XI requirements.
Based on this assessment, the staff finds that the applicants ASME Section XI, Subsections IWB, IWC and IWD Inservice Inspection Program assures for the period of extended operation adequate management of the effects of aging on ASME Code Classes 1, 2, and 3 components for which the LRA credits it with the following exception.
Exception. The LRA states an exception to the GALL Report program element parameters monitored/inspected, specifically:
NUREG-1801, XI.M1 describes the ASME Section XI, Subsections IWB, IWC, and IWD, Inservice Inspection Program as conforming to the requirements of the 3-54
 
ASME Code, Section XI, Subsections IWB, IWC and IWD, in the 2001 edition including the 2002 and 2003 Addenda. However, as noted in the description of the NUREG-1801 Section XI.M1 program, 10 CFR 50.55a governs the application of Codes and Standards. In conformance with 10 CFR 50.55a(g)(4)(ii), the ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition and addenda of the Code specified twelve months before the start of the inspection interval. The difference between the HNP Code of record and the Code edition specified in NUREG-1801is considered to be an exception to NUREG-1801 criteria.
Section 50.55a governs the application and implementation of required codes and standards, including ASME Code Section XI. Paragraph (g)(4)(ii) of 10 CFR 50.55a requires an update of the ASME Code Section XI edition of record for an applicants ISI Program to the most recent code edition endorsed in the rule at least twelve months prior to the next successive 10-year (i.e.,120-month) ISI interval. The difference between the HNP code of record and the code edition specified in GALL Report is an exception to GALL Report criteria.
The staff noted that, at the time of the LRA submission, HNP was in its second 10-Year ISI interval. Its ASME Code Section XI edition of record for that interval was the 1989 Edition with no addenda. The staffs review of the license renewal basis calculation indicated also that on May 2, 2007, HNP entered its third 10-year ISI interval, for which the ASME Code Section XI edition of record is the 2001 Edition with 2003 Addenda. GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, refers to this edition.
The applicant has updated its ASME Code Section XI edition of record to the 2001 Edition of the ASME Code Section XI with 2003 Addenda, the same edition recommended for implementation in GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. The staff concludes that the exception to GALL AMP XI.M1 is no longer part of the review of this AMP. Instead, the program elements of the applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program are consistent with the GALL AMP XI.M1 program elements and acceptable.
Operating Experience. LRA Section B.2.1 states that the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program is implemented and maintained in accordance with general requirements for engineering programs for assurance that the program effectively meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have authority and responsibility to implement the program and commit adequate resources to program activities.
Condition reports and ISI history, including self-assessments and inspections, showed the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program critically monitored, effective, and continually improving, evidence that program practices ensure the continued integrity of ISI Classes 1, 2, and 3 components.
The staff reviewed HNPs 10-Year ISI Plan and related documents to assess whether the applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program 3-55
 
factored industry experience into its scope. The staff focused particularly on whether the program provides for augmented ISI examinations of ASME Code Class 1 components made from nickel-based alloys (including Inconel alloys, Alloy 600 and Alloy 690 base metal materials, and Alloy 82, 182, 52,and 152 weld filler metal materials). The staff based this review on the following NRC generic communications:
* NRC Order EA-03-009 and its first revision (collectively NRC Order EA-03-009): This order states NRC augmented ISI requirements for upper reactor pressure vessel head (RPVH) penetration nozzles and their nickel-alloy welds in PWRs
* NRC Bulletin 2003-02: This bulletin states NRC augmented inspection recommendations for lower RPVH nozzles and their nickel alloy welds in PWRs
* NRC Bulletin 2004-01: This bulletin states NRC augmented inspection recommendations for nickel alloy components and nickel alloy weld materials in PWR pressurizers The operating experience summarized in these documents shows that cracking of nickel alloy base metal and weld components is a safety issue requiring management for PWR facilities.
The applicants response dated February 26, 2003, consented to the augmented inspection requirements established for upper RPVH penetration nozzles in NRC Order EA-03-2009. The staffs review of the 10-Year ISI Plan indicates that this AMP requires augmented inspections of the upper RPVH penetration nozzles and welds. Augmented inspections are also within the scope of the applicants Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads Program of Pressurized Water Reactors Program (LRA AMP B.2.5). The staff evaluates the ability of the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads Program to manage age-related degradation in the upper reactor pressure vessel head penetration nozzles in SER Section 3.0.3.2.3.
The applicants response dated November 13, 2003, to Bulletin 2003-02 committed to perform augmented bare metal visual (BMV) examinations of its lower RPVH penetration nozzle welds during Refueling Outage (RFO) 12 (Fall 2004). In reviewing the 10-Year ISI Plan the staff noted that the applicant had completed the BMV examinations of the lower RPVH penetration nozzles per its commitment in the letter of November 13, 2003, addressing the NRC Bulletin 2003-02 recommendations and had found no signs of reactor coolant leakage from the lower RPVH penetrations.
The applicants response dated July 27, 2004, to Bulletin 2004-01 committed to perform augmented BMV examinations of nickel-alloy components in its pressurizer during RFO-12 (Fall 2004) and every subsequent RFO for mitigation. Additional guidance will come from the EPRI Materials Reliability Program or new ASME Code Section XI or NRC requirements imposed for these components. The staff reviewed the 10-Year ISI Plan and noted that the applicant has implemented the BMV examinations of its nickel alloy pressurizer components per its commitment in the letter of July 27, 2004. The 10-Year ISI Plan also demonstrated that the BMV examinations have found no signs of reactor coolant leakage in the nickel alloy 3-56
 
pressurizer components.
Based on this review, the staff finds that the applicant has an acceptable process for augmentation of its ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program based on industry experience.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.1, the applicant provided the FSAR supplement for the ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exception and their justifications and determines that the AMP is adequate to manage the aging effects for which the LRA credits it. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.2 Reactor Head Closure Studs Program Summary of Technical Information in the Application. LRA Section B.2.3 describes the existing Reactor Head Closure Studs Program as consistent, with exception, with GALL AMP XI.M3, Reactor Head Closure Studs.
The Reactor Head Closure Studs Program manages cracking and loss of material for the Reactor Vessel Closure Head Stud Assembly by inspection. In addition to its condition monitoring elements, the Reactor Head Closure Studs Program has certain preventive measures recommended by RG 1.65, Material and Inspection for Reactor Vessel Closure Studs. This AMP is implemented primarily through the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program without the need for program enhancements. The closure head stud assembly comprises the studs and nuts inspected under the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. The inspection schedule is in accordance with ASME Boiler & Pressure Vessel Code Section XI, IWB-2400, and the extent and frequency are in accordance with Table IWB-2500-1, Examination Category B-G-1 to ensure detection and repair of aging effects before loss of intended function.
Examination results are evaluated according to IWB-3100. Acceptance standards are shown in IWB-3400 and IWB-3500. In addition to the examinations under the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program, the Reactor Head Closure Studs 3-57
 
Program credits code-required visual VT-2 examinations to detect leaks during system pressure or function tests. Repair and replacement are in conformance with the requirements of IWB-4000 and IWB-7000 respectively. The Reactor Head Closure Studs Program inspections provide reasonable assurance that the effects of cracking and loss of material would be detected prior to loss of intended function. The preventive measures include use of a manganese base phosphate coating and no use of metal-plated stud bolting.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exception to determine whether the AMP, with the exception, remained adequate to manage the aging effects for which the LRA credits it.
The staff interviewed the applicants technical personnel and reviewed supporting bases documents, procedures, reports, and calculations for the Reactor Head Closure Studs Program, including the applicants license renewal basis document in Calculation HNP-P/LR-0619, Revision 1, License Renewal Aging Management Program Description of the Reactor Head Closure Studs Program (October 19, 2006), NRC guidelines in Regulatory Guide 1.65, Materials and Inspections of Reactor Vessel Closure Studs, Progress Energy Procedure No. ISI-100, Control of Inservice Inspection and Testing Activities, and Progress Energy Procedure HNP-ISI-002, Revision 1, HNP ISI Program Plan - 2nd Interval (May 4, 2005).
The license renewal basis calculation indicates that the applicant implements its Reactor Head Closure Studs Program in accordance with Section 50.55a, ASME Code Section XI, Examination Category B-G-1, and the guidelines of NRC RG 1.65. The specific details of the examinations required for reactor head closure assembly components are in Inspection Items B6.10, B6.20, B6.30, B6.40, and B6.50 for Examination Category B-G-1 and in cover examination requirements for the reactor head closure nuts, reactor head closure studs (both when in place and when removed), threads in the reactor head closure flange, and reactor head closure washers and bushings. The inspection items require a combination of visual and surface or volumetric examinations to monitor for any loss of material or cracking in the reactor head closure stud assembly components. The staff determined that this requirement is consistent with the recommended program elements of GALL AMP XI.M3, Reactor Head Closure Studs, with the following exception. The staff evaluates the acceptability of the applicants exception to GALL AMP XI.M3, Reactor Head Closure Studs, in the following section.
Exception. The LRA states an exception to the GALL Report program element parameters monitored/inspected, specifically:
NUREG-1801, Section XI.M3, describes the Reactor Head Closure Studs Aging Management Program as conforming to the requirements of the ASME Code, Section XI, Subsection IWB, 2001 edition, including the 2002 and 2003 Addenda, Table IWB 2500-1. However, as noted in the description of the NUREG-1801, Section XI.M1, program, 10 CFR 50.55a governs the application of Codes and Standards. In conformance with 10 CFR50.55a(g)(4)(ii), the ISI Program is updated during each successive 120-month inspection interval to 3-58
 
comply with the requirements of the latest edition and addenda of the Code specified twelve months before the start of the inspection interval. The difference between the HNP Code of record and the Code edition specified in NUREG-1801 is considered to be an exception to NUREG-1801 criteria.
Section 10 CFR 50.55a governs the application and implementation of required codes and standards, including ASME Code Section XI. Paragraph (g)(4)(ii) of 10 CFR 50.55a requires an update of the ASME Code Section XI edition of record for an applicants ISI Program to the most recent code edition endorsed in rule at least twelve months prior to the next successive 10-year (i.e.,120-month) ISI interval.
At the time of the LRA submission, HNP was in its second 10-Year ISI Interval. The staff noted that the ASME Code Section XI edition of record for that interval was the 1989 Edition of the ASME Code Section XI with no addenda. In reviewing the license renewal basis calculation, the staff noted that on May 2, 2007, HNP entered its third 10-year ISI interval, for which the ASME Code Section XI edition of record is the 2001 Edition with 2003 Addenda. GALL AMP XI.M1 refers to this edition.
The applicant has updated its ASME Code Section XI edition of record to the 2001 Edition of the ASME Code Section XI with 2003 Addenda, the same edition recommended for implementation in GALL AMP XI.M3, Reactor Head Closure Studs. The staff concludes that the exception to GALL AMP XI.M1 is no longer part of the review of this AMP. Instead, the program elements of the applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program are consistent with the GALL AMP XI.M3, Reactor Head Closure Studs, program elements and acceptable.
Operating Experience. LRA Section B.2.3 states that there have been no aging effects identified for the reactor vessel closure head stud assembly; therefore, operating experience cannot show program effectiveness.
As the GALL Report states, industry operating experience includes cracking in boiling-water reactor pressure vessel head studs. The GALL Report is based on industry operating experience through January 2005. The applicants review of recent industry operating experience revealed no additional reactor head closure stud degradation. The LRA and the license renewal basis calculation indicate that HNP will review any new industry operating experience with reactor head closure stud degradation through the period of extended operation.
The staff interviewed the applicants staff during the license renewal audit. The staff noted the license renewal basis document for this AMP showed no plant-specific operating experience with reactor closure head assembly components but cracking of reactor head closure studs at Dresden Unit 2 as industry operating experience for this AMP. The staff confirmed that there is no plant-specific age-related operating experience for the reactor head closure assembly components.
As noted in the staffs evaluation of the exception for this AMP, the applicants ISI examinations 3-59
 
under ASME Code Section XI, Examination B-G-1 for the reactor head closure assembly components can detect loss of material and cracking. Based on this review, the staff concludes that the applicant has addressed industry operating experience relevant to the Reactor Head Closure Studs Program and that the scope of this AMP includes inspection techniques that can detect the aging effects shown by industry operating experience. The staff concludes that the operating experience element for the Reactor Head Closure Studs Program is acceptable.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.3, the applicant provided the FSAR supplement for the Reactor Head Closure Studs Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Reactor Head Closure Studs Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exception and their justifications and determines that the AMP, with the exception, is adequate to manage the aging effects for which the LRA credits it. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.3 Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure of Pressurized Water Reactors Program Summary of Technical Information in the Application. LRA Section B.2.5 describes the existing Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure of Pressurized Water Reactors Program as consistent, with enhancement, with GALL AMP XI.M11A, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors.
Since the issuance of GL 97-01, the applicant has participated actively in industry initiatives on Alloy 600 and the specific issue of degradation of vessel head penetration (VHP) nozzles. Since GL 97-01, additional operating experience shows occurrences of circumferential cracking in VHP nozzles resulting in the issuance of NRC Bulletin 2001-01, which required evaluation of VHP nozzles for susceptibility. The applicants response was supported by the PWR
[pressurized-water reactor] Materials Reliability Program Response to Bulletin 2001-01 (MRP-48), which categorized HNP as a low-susceptibility plant. Subsequently, Bulletins 2002-01 and 2002-02 were issued as results of several cracked and leaking Alloy 600 VHP nozzles within the industry including the degradation of the reactor pressure vessel head at Davis-Besse. In response to the NRC bulletins, the applicant provided additional assurance 3-60
 
that its programs are adequate to prevent degradation as observed in the industry. Additionally, in response to Bulletin 2002-02, the applicant proactively scheduled and completed a 100 percent BMV inspection of the reactor pressure vessel head and control rod drive mechanism penetrations.
On February 11, 2003, NRC Order EA-03-009 established interim inspection requirements for reactor pressure vessel heads at PWRs. Subsequently, the NRC issued First Revised Order EA-03-009 on February 20, 2004, to revise certain inspection aspects of the original order. The order (as revised) resulted in major changes to the applicants program for managing cracking in the VHP nozzles. The revised order required determination of a susceptibility ranking and inspections commensurate with plant susceptibility rankings. The revised order required from HNP, as a low susceptibility plant, a 100 percent BMV inspection of the reactor pressure vessel head surface (including 360 E around each penetration nozzle) to be completed at least every third RFO or every five years, whichever comes first. In keeping with the revised order, the applicant completed the BMV inspection during RFO-11. This inspection was observed as a part of a staff integrated inspection. The applicant calculates the susceptibility ranking using the technical method described in the revised order. The applicant updates this susceptibility calculation periodically to incorporate actual operating plant data for each completed plant cycle. The calculation currently projects a low susceptibility ranking well into the period of extended operation.
Following industry initiative, NEI 03-08, Guideline for the Management of Materials Issues, and as mandated by EPRI Materials Reliability Program (MRP)-126, Generic Guidance for Alloy 600 Management, the applicant committed to develop and document an Alloy 600 management plan. On June 21, 2006, the applicant issued Revision 0 of the corporate  EAlloy 600 Strategic Plan. Issuance of this document establishes compliance with the NEI 03-08 mandate to implement the requirements of MRP-126. This plan will define the processes the applicant intends to use to maintain the integrity and operability of each Alloy 600/82/182 component for the remaining life of the plant. The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is implemented through the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program by augmented inspections.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancement to determine whether the AMP, with the enhancement, remained adequate to manage the aging effects for which the LRA credits it.
During the audit, the staff interviewed the applicants technical personnel and reviewed documents on the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program, including the license renewal program evaluation report (Calculation No. HNP-P/LR-0607, Revision 1, dated June 6, 2006), assessing consistency of the program elements with those of GALL AMP XI.M11A.
Revised Order EA-03-009, Section IV.C.(3), for plants in the low category requires BMV examinations meeting Section IV.C.(5)(a) requirements every third RFO or every five years and nonvisual NDEs (ultrasonic, eddy current/dye penetrant testing, or a combination these 3-61
 
examinations) at least every fourth RFO or every seven years, whichever occurs first.
The staff noted that the LRA program description of this AMP states that HNP completed the BMV inspection during RFO-11, and the calculation projects a low susceptibility ranking into the period of extended operation; however, the operating experience description states no additional information for the BMV examination results nor whether HNP had completed or scheduled nonvisual NDEs. The staff requested that the applicant:
* State the BMV examination results and explain how they meet Revised Order EA-03-009 requirements
* Calculate the HNP effective degradation years for the completed plant cycles and for the period of extended operation
* Clarify whether nonvisual NDEs have occurred during the previous RFOs and, if so, whether results meet Revised Order EA-03-009 requirements In response to the staff's request, the applicant stated that:
* The order requires a 100-percent BMV examination of the reactor pressure vessel (RPV) head surface. Such an examination during RFO-11 revealed no evidence of leakage. HNP made a detailed inspection report to the NRC within 60 days as required by the order. The next BMV examination will proceed in RFO-14 scheduled in the Fall of 2007 in accordance with the order.
* The actual calculation of effective degradation years through Cycle 12 is 2.521.
Although HNP has completed 13 plant cycles, the calculation through Cycle 13 is not yet complete; however, the projected calculation through Cycle 13 is 2.76. The period of extended operation begins during Cycle 27. The projection through Cycle 27 into the period of extended operation is 6.16 (low category). The category should remain low through operating Cycle 34. Beginning with Cycle 35, the projected category is moderate (more than eight effective degradation years) through Cycle 40 (60 years of operation). The projected calculation through Cycle 40 is 9.34. HNP will characterize the susceptibility category to moderate or high as appropriate in accordance with the order and inspections and examinations will proceed as required.
* During RFO-13, HNP examined the reactor vessel head penetrations using nonvisual NDEs to satisfy Order Section IV.C.(5)(b) requirements and to set a baseline for future examinations. These examinations found no evidence of primary water stress corrosion cracking. HNP made a detailed inspection report to the NRC within 60 days as required by the order.
The staff reviewed implementation procedures and inspections reports and interviewed the applicants technical personnel with specialized knowledge of the program and found no omissions of NRC Order EA-03-009 requirements or GALL AMP XI.M11A recommendations.
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On this basis, the staff found that the applicants implementation of the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program is acceptable.
Enhancement. The LRA states an enhancement to the GALL Report program element parameters monitored or inspected, specifically:
The Inservice Inspection Program procedure will be enhanced to include the augmented inspections required by NRC Order EA-03-009 (as amended).
The applicant in Enclosure 1 to its letter dated November 14, 2006 committed (Commitment No. 3) to implement the enhancement prior to the period of the extended operation.
During the audit, the staff requested from the applicant additional information on the augmented inspections to be included in the enhancement to the Inservice Inspection (ISI) Program procedure.
The applicant responded that the procedure administers the Inservice Inspection (ISI) Program by designating augmented inspection programs under the ISI program. All inspections as required by NRC Order EA-03-009 will be augmented inspections under the ISI program. This enhancement clarified the program procedure to designate inspections required by NRC Order EA-03-009 as augmented inspections under the Inservice Inspection (ISI) Program.
The staff reviewed the ISI program procedure (ISI-100, Control of Inservice and Testing Activities, Revision 26, dated April 4, 2007) and noted that this enhanced procedure includes augmented inspections required by NRC Order EA-03-009. The enhanced procedure specifically states that it is required to implement license renewal commitments and requirements in support of the Nickel-Alloy Penetration Nozzle Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program. On the basis of this review, the staff finds the applicants proposed enhancement acceptable.
Operating Experience. LRA Section B.2.5 states that, although no VHP nozzle cracking has been detected, the applicant has participated actively in the industry response to the issue by a commitment to implement a plant-specific Alloy 600 Management Plan as described in MRP-126, Materials Reliability Program Generic Guidance for Alloy 600 Management, Final Report, November 2004. This plan will be based upon industry Alloy 600/82/182 operating experience and will schedule periodic reviews of industry data on inspection, repair, mitigation technologies, and lessons learned from industry experience.
The staff reviewed the operating experience described in the LRA and interviewed the applicants technical personnel to confirm that plant-specific operating experience revealed no degradation not bounded by industry experience. During the audit, the staff noted that the applicant recently had completed both a BMV examination of the top of the reactor vessel closure head and a nonvisual NDE of the nickel-alloy penetration nozzles of the reactor vessel closure head. The staff reviewed the implementing procedures for these examinations and 3-63
 
asked the applicant for a summary of examination results.
The applicants response to the staffs request stated that HNP had completed a 100-percent BMV examination of the reactor pressure vessel head surface during RFO-11 with no evidence of leakage revealed. The applicant added that the next BMV examination will proceed in the Fall of 2007 (RFO-14). The applicants response also stated that, during RFO-13, nonvisual NDEs of the vessel head penetrations found no evidence of primary water stress corrosion cracking. The staff reviewed the applicants letters dated July 16, 2003, and July 14, 2006, submitting BMV and NDE inspection reports for the reactor vessel head and found the applicants response consistent with the submitted reports. Based on the applicants compliance with NRC Order EA-03-009, the staff finds the operating experience program element acceptable.
FSAR Supplement. In LRA Section A.1.1.5, the applicant provided the FSAR supplement for the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure of Pressurized Water Reactors Program. Further, in Enclosure 1 of its letter dated November 14, 2006, the applicant committed (Commitment No. 3) to enhance the ISI program administrative control prior to the period of extended operation. The staff evaluation of this enhancement is under Enhancement in this SER section. The staff reviewed this commitment and LRA Section A.1.1.5 and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure of Pressurized Water Reactors Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancement and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.4 Flow-Accelerated Corrosion Program Summary of Technical Information in the Application. LRA Section B.2.7 describes the existing Flow-Accelerated Corrosion Program as consistent, with enhancement, with GALL AMP XI.M17, Flow-Accelerated Corrosion.
The Flow-Accelerated Corrosion Program predicts, detects, and monitors flow-accelerated corrosion (FAC) in piping and piping components so timely and appropriate action may minimize the probability of a FAC-induced leak or rupture. The Flow-Accelerated Corrosion Program is based on the guidance of EPRI NSAC-202L-R2, Recommendations for an Effective Flow-Accelerated Corrosion Program, and includes an analysis to determine critical locations, limited baseline inspections to determine the extent of thinning at these locations, follow-up inspections to confirm the predictions, and repair or replacement of components as 3-64
 
necessary.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancement to determine whether the AMP, with the enhancement, remained adequate to manage the aging effects for which the LRA credits it.
The applicant defines its existing, inspection-based Flow-Accelerated Corrosion Program when enhanced as consistent with the ten program elements of GALL AMP XI.M17, Flow-Accelerated Corrosion. During the audit, the staff reviewed the Flow-Accelerated Corrosion Program license renewal basis calculation, the basis document establishing how the program elements compare to the ten program elements of GALL AMP XI.M17.
NRC Bulletin 87-01, Thinning of Pipe Walls in Nuclear Power Plants (November 6, 1987), and NRC Generic Letter 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning (May 2, 1989),
state the NRC bases for FAC programs at US nuclear power plants. The staff reviewed the license renewal basis document and noted that the scope of Flow-Accelerated Corrosion Program includes these generic communications and the applicants responses dated September 14, 1987, to Bulletin 87-01 and July 21, 1989, to Generic Letter 89-08. The staff also noted that the scope of the Flow-Accelerated Corrosion Program includes the implementation guidelines of EPRI Report No. NSAC-202L-R2, Recommendations for an Effective Flow-Accelerated Corrosion Program (April 1999). The applicants inclusion of these documents into the scope of the Flow-Accelerated Corrosion Program is consistent with the recommendations of the scope of program element of GALL AMP XI.M17, Flow-Accelerated Corrosion, and acceptable.
The staff reviewed the license renewal basis calculation and noted that the Flow-Accelerated Corrosion Program monitors for loss of material due to corrosion in carbon steel piping components and alloy steel components with less than 1 percent chromium as an alloy element. This monitoring is consistent with the parameters inspected/monitored program element of GALL AMP XI.M17, Flow-Accelerated Corrosion, and acceptable.
The staff also reviewed the implementation procedure for the Flow-Accelerated Corrosion Program and noted that the procedure invokes the implementation guidelines of EPRI Report No. NSAC-202L-R2 and also administratively requires the applicant to model and rank the susceptibility of its carbon steel and low-alloy steel piping components as well as to schedule and implement ultrasonic testing (UT) examinations in accordance with the CHECWORKS computer code. This requirement includes incorporating the results of previous UT examinations into the CHECWORKS modeling software and using them to re-establish piping rankings to determine and schedule locations that need UT inspection at the next inspection period. The procedure is consistent with the detection of aging effects, monitoring and trending, and acceptance criteria program elements of GALL AMP XI.M17, Flow-Accelerated Corrosion, and acceptable.
The staffs evaluation of the applicants program enhancement for this program follows:
Enhancement. The LRA states an enhancement to thescope of program program element of GALL AMP XI.M17, Flow-Accelerated Corrosion, specifically:
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The HNP FAC Program will be enhanced to provide a consolidated exclusion bases document (i.e., a FAC susceptibility analysis). The exclusion basis document will include an evaluation of the Steam Generator Feedwater Nozzles to determine their susceptibility to FAC.
The staffs review of the license renewal basis calculation indicated that EPRI Report No. NSAC-202L-R2 sets screening criteria for excluding plant piping components and that the applicants Flow-Accelerated Corrosion Program uses these EPRI criteria; however, the applicant has not proceduralized these exclusion criteria into a corporate or plant-specific exclusion criteria bases document. The applicant therefore included the need to proceduralize these exclusion criteria (i.e., develop an exclusion bases document) as a necessary program enhancement. Use of these exclusion criteria is acceptable because GALL AMP XI.MM17, Flow-Accelerated Corrosion, refers to EPRI Report No. NSAC-202L-R2 as acceptable guidance for FAC programs and because the EPRI guidelines are acceptable criteria for including or excluding plant systems. The staff has confirmed that this part of the enhancement is in Commitment No. 5 submitted in the applicants letter of November 14, 2006.
The applicants enhancement also provides in the exclusion bases document for an evaluation of the steam generator feedwater nozzles to determine their susceptibility to FAC. The staff also confirmed that this part of the enhancement is in Commitment No. 5. The staff found this provision acceptable because the screening criteria are consistent with recommendations of GALL AMP XI.M17, Flow-Accelerated Corrosion, and the applicant will use these EPRI Report No. NSAC-202L-R3 criteria to determine whether the steam generator feedwater nozzles should be included in the scope of the Flow-Accelerated Corrosion Program.
The applicants enhancement of the Flow-Accelerated Corrosion Program is Commitment No. 5. Based on this review, the staff concludes that the Flow-Accelerated Corrosion Program, when enhanced by Commitment No. 5, will be consistent with the program elements of GALL AMP XI.M17, Flow-Accelerated Corrosion, and acceptable.
Operating Experience. LRA Section B.2.7 states that nuclear power plants have experienced pipe wall thinning largely attributable to FAC in single-phase and two-phase high-energy piping systems. In response to Generic Letter 89-08, the industry has mounted a broad-based effort to manage this aging mechanism, previously referred to as erosion-corrosion. HNP has experienced through-wall leakage in high-energy carbon steel piping; however, there have been no catastrophic failures and the number of instances of through-wall failures has declined steadily.
The Flow-Accelerated Corrosion Program, as evolved through industry experience, is described in NSAC-202L-R2. The Flow-Accelerated Corrosion Program has been effective in its response to both industry and plant-specific operating experience and effectively ensures the structural integrity of high-energy carbon steel systems. Since inception, the Flow-Accelerated Corrosion Program has matured and become more effective as a result of program improvements based upon self-assessments, independent staff inspections, and plant-specific and industry operating experience.
The staff has audited industry programs based on the EPRI methodology at several plants and 3-66
 
determined that these activities are good predictors of FAC onset so timely corrective actions can be undertaken.
During the audit, the staff interviewed the applicants staff responsible for implementing the Flow-Accelerated Corrosion Program. The license renewal basis calculation for the Flow-Accelerated Corrosion Program indicated that review of both industry and plant-specific operating experience is an ongoing part of the Flow-Accelerated Corrosion Program, that this review will extend through the period of extended operation, and that the incorporation of operating experience into the Flow-Accelerated Corrosion Program is also a programmatic requirement invoked by corporate procedures. The applicant clarified that its reviews of industry data include the Institute of Nuclear Power Operations (INPO), EPRI, CHUG, FAC NET data sources.
The staffs review of the license renewal basis calculation for the Flow-Accelerated Corrosion Program indicated that it also assesses carbon steel piping locations that the NRC has described in information notices (INs), GLs, or bulletins as susceptible to FAC:
* Bulletin 87-01, Thinning of Pipe Walls in Nuclear Power Plants, November 6, 1987.
* GL 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning, May 2, 1989.
* IN 89-53, Rupture of Extraction Steam Line on High Pressure Turbine, November 6, 1987.
* IN 91-18, High-Energy Piping Failures Caused by Wall Thinning, March 12, 1991.
* IN 92-35, Higher Than Predicted Erosion/Corrosion in Unisolable Reactor Coolant Pressure Boundary Piping Inside Containment at a BWR, May 6, 1992.
* IN 93-21, Summary of NRC Staff Observations Compiled During Engineering Audits or Inspections of Licensee Erosion/Corrosion Programs, March 25, 1993.
* IN 95-11, Failure of Condensate Piping Because of Erosion/Corrosion at a Flow-Straightening Device, February 24, 1995.
* IN 97-84, Rupture in Extraction Steam Piping as a Result of Flow-Accelerated Corrosion, December 11, 1997.
The staff reviewed the FAC records for UT examinations during the last refueling outage, noted that the carbon steel components selected for examination included locations based on industry operating experience, and concluded that the applicant includes operating experience in selecting carbon steel piping locations for UT examination. The staff also noted that the applicant replaces any carbon steel piping exhibiting an unacceptable amount of FAC-induced wear with stainless steel or chromium-molybdenum alloy steel piping with chromium content of at least 1-1/4 (1.25) percent. The chromium levels in these steels makes them more resistant 3-67
 
than carbon steel materials to FAC. The chromium level also permits exclusion of the replaced components from the scope of the program (i.e., the EPRI guidelines permit exclusion of stainless steel piping or alloy steel piping with 1.25 chromium from FAC programs).
Based on this review, the staff concludes that the applicants Flow-Accelerated Corrosion Program includes programmatic controls to track and incorporate industry and plant-specific operating experience for use in selecting carbon steel piping locations for UT examination and that the operating experience program element of the Flow-Accelerated Corrosion Program is acceptable because the applicant uses industry operating experience as a basis for supplementing the scope of the program and for selecting and scheduling the component inspections implemented by this AMP.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.7, the applicant provided the FSAR supplement for the Flow-Accelerated Corrosion Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff determined that the applicant states that the Flow-Accelerated Corrosion Program will be enhanced to ensure consistency with the program elements of GALL AMP XI.M17, "Flow-Accelerated Corrosion," and that this enhancement is Commitment No. 5 in the LRA and a reference in FSAR Supplement Section A.1.1.7.
Based on this review, the staff concludes that FSAR Supplement A.1.1.7 is acceptable because adequately describes the Flow-Accelerated Corrosion Program and incorporates Commitment No. 5.
Conclusion. On the basis of its audit and review of the applicants Flow-Accelerated Corrosion Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancement and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.5 Bolting Integrity Program Summary of Technical Information in the Application. LRA Section B.2.8 describes the existing Bolting Integrity Program as consistent, with exceptions and enhancement, with GALL AMP XI.M18, Bolting Integrity.
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The Bolting Integrity Program addresses aging management requirements for bolting on mechanical components within the scope of license renewal. The Bolting Integrity Program utilizes industry recommendations and EPRI guidance that consider material properties, joint/gasket design, chemical control, service requirements, and industry and plant-specific operating experience in specifying torque and closure requirements. The program relies on staff recommendations for a bolting integrity program as in NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants, and industry recommendations as in EPRI Reports NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, and TR-104213, Bolted Joint Maintenance & Applications Guide, for pressure-retaining bolting within the scope of license renewal.
Safety-related bolting and closure inspections, monitoring/trending, and repair/replacement are under the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program.
Nonsafety-related pressure-retaining bolting and closure inspection, monitoring, and trending are under the External Surfaces Monitoring Program. Degraded conditions are also subject to the Corrective Action Program.
The Bolting Integrity Program periodically inspects closure bolting for loss of preload, cracking, and loss of material due to corrosion and rust and takes measures to prevent or minimize loss of preload and cracking.
Other AMPs (e.g., GALL AMP XI.M1, "ASME Section XI Inspection (ISI) Subsections IWB, IWC, and IWD," and GALL AMP XI.S3, "ASME Section XI Subsection IWF") that also manage inspection of safety-related bolting supplement the Bolting Integrity Program.
HNP has included no high-strength structural bolts within the scope of license renewal; therefore, the Bolting Integrity Program includes no activities of the ASME Section XI, Subsection IWF Inservice Inspection Program.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions and enhancement to determine whether the AMP, with the exceptions and enhancement, remained adequate to manage the aging effects for which the LRA credits it.
Enhancement. The LRA states the following enhancement to meet the GALL Report program element preventive actions, specifically:
The HNP procedures for torquing/bolted connections MMM-010, Threaded Fastener Tightening Procedure, Reference 5.24, Attachment 5, will be revised to prohibit the use of Molybdenum Disulfide Lubricants (e.g., Molycote).
In a letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 6) to enhance the program implementing procedures by prohibiting the use of molybdenum disulfide lubricants. The staff finds this commitment acceptable because the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the preventive actions program element.
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Exception. The LRA states the following exception to the GALL Report program elements parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions, specifically:
GALL AMP XI.M1 describes the ASME Section XI, Subsections IWB, IWC and IWD, Inservice Inspection Program as conforming to the requirements of the ASME Code, Section XI, Subsections IWB, IWC and IWD in the 2001 Edition including the 2002 and 2003 Addenda. However, as noted in the description of GALL AMP XI.M1, 10 CFR 50.55a governs the application of Codes and Standards. In conformance with 10 CFR 50.55a(g)(4)(ii), the ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition and addenda of the Code specified 12 months before the start of the inspection interval. The differences between the HNP code of record and the Code edition specified in the GALL Report are considered to be an exception to the GALL Report criteria.
The applicant stated that it had added an exception to the Bolting Integrity Program as to the reference to the ASME Code 1995 Edition with 1996 Addenda in GALL AMP XI.M18. The applicants edition of record is the 1989 Edition with no addenda, an exception to the GALL Report. The staff compared the examination requirements of Tables IWB-2500-1 and IWC-2500-1 in the 1995 Edition with 1996 Addenda against those of the 1989 Edition, found them consistent, and finds the applicants Bolting Integrity Program, with the exception, acceptable because the HNP edition of record is consistent with GALL Report requirements.
Operating Experience. LRA Section B.2.8 states that operating experience shows the Bolting Integrity Program as continually upgraded based on industry experience, research, and routine program performance. The program, through its continual improvement, assures the capability of mechanical bolting to support plant safety throughout the period of extended operation.
During the audit and review, the staff reviewed various action requests on bolting issues and descriptions of their corrective actions addressed in the following paragraphs.
In one action request on a leak on a 12-inch 90-degree elbow due to failed bolting in the fire protection piping discovered after a fire pump start, the ensuing investigation included an engineering review and a metallurgical analysis. Corrective actions replaced the elbow, realigned the piping, and installed a thrust block.
In another action request on three flange bolts missing from a valve to expansion joint bolted connection, the ensuing investigation concluded that the bolts had been missing since the original installation of the joint. Corrective actions installed the proper bolting material.
On the basis of its review of this plant-specific operating experience and discussions with the applicants technical personnel, the staff finds that the applicants Bolting Integrity Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion 3-70
 
defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.8, the applicant provided the FSAR supplement for the Bolting Integrity Program. Also, in a letter dated August 20, 2007, the applicant stated Commitment No. 6 to enhance the Bolting Integrity Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 6, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Bolting Integrity Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which the LRA credits it. Also, the staff reviewed the enhancement and confirmed that its implementation through Commitment No. 6 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.6 Steam Generator Tube Integrity Program Summary of Technical Information in the Application. LRA Section B.2.9 describes the existing Steam Generator Tube Integrity Program as consistent, with exceptions and enhancements, with GALL AMP XI.M19, Steam Generator Tube Integrity.
The Steam Generator Tube Integrity Program, part of the overall Steam Generator Integrity Program, is credited for aging management of the tubes, tube plugs, tube supports, and secondary-side components whose failure could prevent the steam generator from fulfilling its intended safety function. The Steam Generator Integrity Program is based on technical specification requirements and meets the intent of NEI 97-06, Steam Generator Program Guidelines. The Steam Generator Tube Integrity Program manages aging effects by a combination of prevention, inspection, evaluation, repair, and leakage monitoring. Preventive measures are intended to mitigate by primary-side and secondary-side water chemistry monitoring and control degradation from corrosion phenomena. Foreign material exclusion requirements are intended to inhibit wear degradation. The Steam Generator Tube Integrity Program provides the actions to be taken in response to detection of foreign objects.
The Steam Generator Tube Integrity Program requires inspection activities to detect flaws in tubing, plugs, tube supports, and secondary-side internal components needed to maintain tube integrity. Degradation assessments identify both potential and existing degradation mechanisms. Inservice inspections (i.e., eddy current testing and visual inspections) detect flaws. Condition monitoring compares the inspection results against performance criteria, and an operational assessment predicts tube conditions so performance criteria will not be 3-71
 
exceeded during the next operating cycle. Primary-to-secondary leakage is monitored continually during operation. The steam generators were replaced in 2001. The new steam generators incorporate significant design improvements, including Alloy 690 thermally-treated tubing, stainless steel tube supports and anti-vibration bars, full-depth hydraulically-expanded tubes in the tubesheet, and design features which minimize the deposition of sludge on it.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions and enhancements to determine whether the AMP, with the exceptions and enhancements, remained adequate to manage the aging effects for which the LRA credits it.
During the review, the staff asked the applicant how many tubes in each steam generator have been plugged or repaired and what steam generator repair methods (plugging, sleeving, kinetic expansion) have been reviewed and approved by the NRC under this program.
In Enclosure 3 of its response dated August 20, 2007, the applicant stated that to date three tubes in Steam Generator A, one in Steam Generator B, and three in Steam Generator C are plugged. The applicant also clarified that, since a steam generator tube surveillance program amendment on March 16, 2007, tubes found by ISI with flaws as deep as 40 percent of nominal tube wall thickness shall be plugged. Because it provided the requested information and stated that plugging is the only repair method for steam generator tubes with flaws exceeding 40 percent of tube wall nominal thickness, the staff finds the applicants response acceptable.
Exception. The LRA states that the existing Steam Generator Integrity Program, following the enhancement, will be consistent with GALL AMP XI.M19 with exceptions to the scope of the program, preventive actions, detection of aging effects, and monitoring and trending program elements:
The Steam Generator Tube Integrity Program has been established to meet the intent of NEI 97-06, Steam Generator Program Guidelines, Revision 2. The GALL Report refers to Revision 1 of NEI 97-06. This is a difference with the GALL Report. HNP is committed to the implementation of the latest revision of NEI 97-06. The updated NEI 97-06 document incorporates the latest industry operating experience, which strengthens the intent of NEI 97-06 to establish a framework for structuring and strengthening existing steam generator programs.
The NRC has not approved NEI 97-06 but recognizes its usefulness as a framework for structuring an effective steam generator program. The NRC stated in GALL AMP XI.M19, that a licensees plant Technical Specifications, response to GL 97-06, and commitment to implement the steam generator degradation management program described in NEI 97-06 are adequate to manage the effects of aging on the steam generator tubes, plugs, sleeves, and tube supports. Therefore, use of the latest revision of NEI 97-06 is justified.
During the review and audit, the staff asked the applicant to explain the major differences between NEI 97-06, Revision 1 and Revision 2 and to clarify how they affect the scope of the program, preventive actions, detection of aging effects, and monitoring and trending program elements. The applicants response in Enclosure 3 of its letter dated August 20, 2007, 3-72
 
stated that HNP's commitment to NEI 97-06, Revision 2, consistent with NRC and industry adoption of improved steam generator technical specifications, is a CLB change. The NRC in its letter to The applicant dated March 16, 2007, approved adoption of the improved steam generator technical specifications. The applicant also explained that NEI 97-06, Revision 2, summarizes its changes from NEI 97-06, Revision 1. On the basis that the NRC has reviewed and approved the applicants commitment to NEI 97-06, Revision 2, the staff finds the applicants response and exception to the GALL AMP XI.M19 acceptable.
Enhancement. The LRA states that, prior to the period of extended operation, an enhancement to the existing program will affect the scope of the program, parameters monitored or inspected, and corrective actions program elements, specifically:
Enhance the program implementing procedure to require that degraded tube plugs and secondary side components (e.g., tube supports) are evaluated for corrective actions.
The applicant in Enclosure 1 to its letter dated November 14, 2006, committed (Commitment No. 7) to implement the enhancement prior to the period of the extended operation.
During the audit, the staff reviewed the applicants supporting documents, including the license renewal program evaluation report and the Steam Generator Integrity Program (EGR-NGGC-0208), Revision 1, and noted that this existing program will be consistent with the GALL AMP with this enhancement describing instructions for corrective action evaluations for degraded tube plug or secondary-side components. On the basis of this review, the staff finds the applicants proposed enhancement acceptable.
Operating Experience. LRA Section B.2.9 states that the Steam Generator Tube Integrity Program is implemented and maintained in accordance with the general requirements for engineering programs for assurance that the program meets regulatory and procedural requirements and that qualified personnel assigned as program managers have authority and responsibility to implement the program and to commit adequate resources to program activities.
The Steam Generator Integrity Program utilizes operating experience to promote the transfer of lessons learned from both internal and industry events so the knowledge gained can be used to improve nuclear plant safety and operations. Operating experience provides the methodology for receiving, processing, screening, reviewing, and evaluating information, status reporting, and taking preventive and corrective actions.
Industry operating history shows that plant-specific operating experience of the HNP replacement steam generators is similar to that of other replacement steam generators with thermally-treated Alloy 690 tubes and design enhancements which minimize the likelihood of degradation. There have been no reported instances of cracking in thermally-treated Alloy 690 tubes at any US plants; the only indications to date are from wear (fretting) due to loose parts, tube supports, anti-vibration bars, and from manufacturing or handling anomalies.
Plant-specific condition reports, internal and external assessments, and operating history show 3-73
 
the Steam Generator Integrity Program to be critically monitored, effectively maintaining tube integrity, and continually improving. The overall effectiveness of the Steam Generator Integrity Program is proven by SSC operating experience; no tube integrity-related degradation has led to loss of component intended function.
During the audit, the staff interviewed the applicant's technical personnel and reviewed the operating experience described in the Steam Generator Tube Integrity Program supporting documents, including the license renewal program evaluation report. During the review, the staff noted that, although the applicant had described industry and plant-specific steam generator integrity program operating experience in its supporting documents, the LRA Section B.2.9 operating experience program element does not state specific operating experience details. The staff requested from the applicant additional information about Steam Generator Tube Integrity Program operating experience, specifically (1) a listing and a brief summary of the industry operating experience addressing whether it is relevance to the program and, if so, whether it introduced any new requirements and (2) a listing and a brief summary of plant-specific operating experience history addressing condition reports, corrective actions, and how the corrective actions were resolved, specifically whether these conditions introduced any new requirements to the program.
The applicants response in Enclosure 3 of its letter dated August 20, 2007, listed industry operating experience for the Steam Generator Tube Integrity Program and stated that:
The above [listed in the August 20, 2007, letter] industry operating experience items were reviewed for applicability to the HNP steam generator tube integrity program, as follows:
With respect to the NRC Generic Letters, HNP found that steam generator tube inspections are consistent with the NRCs position regarding tube inspections.
Additionally, HNP has submitted an application for Technical Specification improvement regarding steam generator tube integrity consistent with NRC and industry adoption of improved steam generator Technical Specifications. The adoption of the improved steam generator Technical Specifications has been approved by the NRC. The subject NRC Information Notices and Licensee Event Reports were reviewed and found not to be directly applicable to the present-day HNP Model Delta 75 steam generators. Although the operating experience was not directly applicable to the HNP steam generators, the underlying aging mechanisms were also reviewed. The aging mechanisms associated with the NRC Information Notices and Licensee Event Reports were found to be addressed by the HNP steam generator tube integrity program. INPO Operating Experience was reviewed for applicability to the HNP steam generator tube integrity program. For those events that were directly related to the present-day HNP Model Delta 75 steam generators, it was found that the HNP steam generator tube integrity program addressed the concerns identified. For those events that were not directly related to the present-day HNP Model Delta 75 steam generators, the underlying aging mechanisms were also reviewed. The aging mechanisms associated with the INPO Operating Experience were found to be addressed by the HNP steam generator tube integrity program.
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Further, the applicants response in Enclosure 3 of the letter dated August 20, 2007, summarized plant-specific operating experience:
A review of plant-specific condition reports, internal and external assessments was conducted and showed the Steam Generator Integrity Program to be critically monitored, effective in maintaining tube integrity, and continually improving.
Corrective actions introducing new requirements to the Steam Generator Integrity Program associated with Nuclear Condition Reports (NCRs) consisted of the following:
Revision to the Steam Generator Tube Integrity Surveillance Test Procedure to improve identification/storage of various eddy current probes brought on site.
Revision to the HNP Steam Generator Program Procedure to incorporate an independent review of the foreign object search and retrieval data.
Revision to the HNP procedures to require verification of the automated analysis parameters during the Site-Specific Performance Demonstration Corrective actions introducing new requirements to the Steam Generator Integrity Program associated with external and internal assessments consisted of the following:
Action items to improve the documentation for eddy current techniques, tube plug inspection acceptance criteria, documentation of deviations to EPRI documents used in the Steam Generator Integrity Program guidelines, long-range planning of inspection activities for the replacement steam generators, and improvements in implementation of chemistry and primary-to-secondary leakage procedures.
Additional actions taken included: (1) improvements in the documentation of actions from tube leak events, (2) improvements in degradation assessment, condition monitoring, and operational assessment procedures, (3) improvements in Steam Generator in-service inspection procedures, (4) improvements in primary-to-secondary leak detection procedures, and (5) review of the In-Service Inspection vendor root cause analyses.
The NRC audit team reviewed operating experience details during the AMR audit and determined that the applicant adequately incorporated industry and plant-specific operating experience into the Steam Generator Integrity Program. On the basis of this determination, the staff found the applicants response acceptable.
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The staff noted that IN 97-88, Experiences During Recent Steam Generator Inspections, dated December 16, 1997, states that in May 1997 the Shearon Harris Nuclear Power Plant licensee found extensive damage to four perforated carbon steel ribs in a steam generator. The ribs are welded to the feedwater impingement plate which shields the steam generator tubes from direct impact of the feedwater flow. The licensee concluded that the high-flow velocities of the feedwater had eroded the ligaments between the perforation on the ribs.
The staff asked the applicant to explain whether loss of material due to erosion is present at the secondary side components of the replaced steam generators and how the Steam Generator Tube Integrity Program will prevent, inspect, detect, or monitor for this aging effect.
The applicants response in Enclosure 3 of the letter dated August 20, 2007, provided a table showing the steam generator feedwater impingement plate and support and the steam generator tube bundle wrapper as steam generator secondary side components susceptible to loss of material due to erosion. The applicant added that the One-Time Inspection Program by visual or volumetric inspection or both will verify for the feedwater impingement plate and support whether degradation has occurred or will trigger additional actions to maintain intended functions of the affected components during the period of extended operation. The staff finds the applicant's response acceptable, on the basis of no operating experience with erosion of impingement plates and supports in the replaced steam generators. In addition, the One-Time Inspection Program inspections will be adequate to verify whether any loss of material due erosion occurs.
The applicant stated that, consistent with the GALL Report, the Steam Generator and Water Chemistry Programs manage aging effects due to erosion for the steam generator tube bundle wrapper. SER Sections 3.0.3.1.1 and 3.0.3.2.6 document the staff's evaluation of the applicant's Water Chemistry Program and of its Steam Generator Tube Integrity Program. On this basis, the staff agrees with the applicant that loss of steam generator tub bundle wrapper material due to erosion will be adequately managed during the period of extended operation.
On the basis of its reviews, the staff found the applicants response on aging effects due to erosion acceptable.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.9, the applicant provided the FSAR supplement for the Steam Generator Tube Integrity Program. This section of the LRA states:
The Steam Generator Tube Integrity Program is credited for aging management of the tubes, tube plugs, tube supports, and the secondary-side components in which failure could prevent the steam generator from fulfilling its intended safety function, for the period of extended operation. The Steam Generator Tube Integrity Program is based on an existing program, the Steam Generator Integrity Program. The Steam Generator Integrity Program is based on Technical Specification requirements, and meets the intent of NEI 97-06, Steam Generator Program Guidelines.
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Prior to the period of extended operation, the program implementing procedure will be enhanced to include a description of the instructions for implementing corrective actions if tube plugs or secondary-side components (e.g., tube supports) are found to be degraded.
In Enclosure 1 of its letter dated November 14, 2006, the applicant committed (Commitment No. 7) to enhance the program implementing procedure to include instructions for corrective actions for degraded tube plugs or secondary-side components (e.g., tube supports) prior to the period of extended operation. The staff evaluation of this enhancement is under Enhancement of this program. The staff reviewed this commitment and LRA Section A.1.1.9 and determines that the information in the FSAR supplement is an adequate summary description of the program as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Steam Generator Tube Integrity Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which the LRA credits it. Also, the staff reviewed the enhancements and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.7 Closed-Cycle Cooling Water System Program Summary of Technical Information in the Application. LRA Section B.2.11 describes the Closed-Cycle Cooling Water System Program as consistent, with exceptions, with GALL AMP XI.M21, Closed-Cycle Cooling Water System.
The Closed-Cycle Cooling Water System Program addresses aging management of components in the component cooling water and essential services chilled water systems and components in other systems cooled by these systems. This program also manages the jacket water components of the emergency diesel generators, diesel-driven fire pump, and security diesel. These systems are closed cooling loops with controlled chemistry consistent with the GALL Report description of a closed cycle cooling water system. In order to minimize corrosion, this program maintains system corrosion inhibitor concentrations within specified limits of Closed Cooling Water Chemistry Guideline: Revision 1 to TR-107396, Closed Cooling Water Chemistry Guideline, EPRI, Palo Alto, CA: 2004. Surveillance testing and inspection in accordance with standards in the above EPRI report evaluates system and component performance. These measures ensure that the closed-cycle cooling water system and components serviced by that system perform their functions acceptably.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions to determine whether the 3-77
 
AMP, with the exceptions, remained adequate to manage the aging effects for which the LRA credits it.
Exception 1. The LRA states the following exception to the GALL Report program element preventive action, specifically:
The Closed-Cycle Cooling Water System Program currently uses the 2004 version of the EPRI Closed Cooling Water Chemistry Guideline. However, the GALL Report references the 1997 version.
During the audit and review, the staff reviewed the Closed-Cycle Cooling Water System Program procedure for establishing water chemistry parameters. Based on this review, the staff confirmed that wherever Revision 1 of the EPRI guideline relaxed the criteria the implementing procedure reverted to the Revision 0 version of the guideline. Where acceptable parameter values were tightened, the implementing procedure used the tighter values. Based on the review of the implementing procedure, the staff finds the applicants implementation of the guidance at least conservative as the GALL Report recommendations and therefore acceptable.
Exception 2. The LRA states the following exception to the GALL Report program element parameters monitored or inspected, specifically:
Some heat exchangers are not monitored for flow, inlet and outlet temperatures, and differential pressure. In these cases, either the functionality of these heat exchangers is verified by activities outside the Closed-Cycle Cooling Water System Program or the specific operating conditions of the heat exchanger render performance testing unreliable.
During the audit and review, the staff asked the applicant which specific heat exchangers are not monitored for flow, inlet and outlet temperatures, and differential pressure and to describe how activities outside the Closed-Cycle Cooling Water System Program verify the performance of these heat exchangers.
In its response dated August 20, 2007, the applicant stated:
Flow, temperature and pressure are not specifically monitored in the following heat exchangers. As noted in LRA Section B.2.11, in these cases, either the functionality of these heat exchangers is verified by activities outside the Closed-Cycle Cooling Water System Program or the specific operating conditions of the heat exchanger render performance testing unreliable.
Primary Sample Condenser and Cooler - The performance of the sample coolers and condensers is validated as the system is used by chemistry personnel.
These components are not needed for safe shutdown and not required to mitigate the consequences of an accident.
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Component Cooling Water Heat Exchangers - The component cooling water heat exchangers are tested or inspected as part of HNP's commitments to Generic Letter 89-13 as described in the Open-Cycle-Cooling Water System Program in LRA Section B.2.10. An engineering evaluation concluded that factors inherent in the testing process make the test results too unreliable to be used for operability determinations or as a basis for an inspection program. In addition, temperature and pressures are indicated on the main control board and operations monitors them to ensure they are performing as expected for the plant conditions.
Emergency Diesel Generator Oil and Jacket Water Coolers - The emergency diesel generator jacket water coolers are tested or inspected as part of HNP's commitments to Generic Letter 89-13 as described in the Open-Cycle Cooling Water System Program in LRA Section B.2.10. Inspection and cleaning of the emergency diesel generator lube oil cooler is included as part of a maintenance periodic test. The degradation of heat exchanger performance can be identified through these inspections.
EDG Turbocharger Intercoolers - The combustion air intercoolers are inspected or cleaned as part of the periodic diesel generator maintenance. The degradation of heat exchanger performance can be identified through this inspection.
Reactor Coolant Drain Tank (RCDT) Heat Exchanger - The RCDT heat exchanger performs no safety-related heat transfer function. The heat exchanger tubes provide a pressure boundary function. Nevertheless, reactor coolant drain tank heat exchanger high temperature is annunciated and the procedural response is to investigate temperature increases that would indicate heat exchanger fouling.
Fuel Pool Heat Exchangers - Testing is not performed for the same reasons associated with the component cooling water heat exchangers above.
Degradation of heat exchanger performance can be identified through control room and local alarms. This is considered an exception because specific performance testing is not performed. Per FSAR Section 9.1.3: 'Control Room and local alarms are provided to alert the operator of high and low pool water level, and high temperature in the fuel pool. A low flow alarm, based on measured flow to the fuel pool, is provided to warn of interruption of cooling flow.'
Air Handling Unit Cooling Coils - The safety-related air handling units are periodically inspected and differential pressures recorded. The condition of heat exchanger performance can be identified through this inspection. This is considered an exception because specific performance testing is not performed.
Per procedures, operations performs periodic monitoring of the rooms cooled by these safety-related units.
The licensing renewal activities described above along with the activities 3-79
 
described in the Closed-Cycle Cooling Water System Program ensure the performance and structural integrity of these heat exchangers will be maintained during the period of extended of operation.
For such heat exchangers there is no specific performance testing so the applicant has listed them as exceptions; however, in each case, as described, there is adequate indication, through visual inspections, operating performance, and through flow, pressure, or temperature indications in the control room, that the heat exchangers perform their intended function. Some of these indications have alarms The staff finds this exception acceptable because there is sufficient indication that the heat exchangers perform their intended function.
Exception 3. The LRA states the following exception to the GALL Report program element detection of aging effects, specifically:
Some heat exchangers that are not normally in operation are not periodically tested to ensure operability. However, the functionality of these heat exchangers is verified by activities outside the Closed-Cycle Cooling Water System Program.
During the audit and review, the staff confirmed that there are two heat exchanger component types not normally in service and not periodically tested for operability, the spent fuel pool heat exchangers and the air-handling units cooled by the component cooling water. The spent fuel pool heat exchangers operate not continuously but when pool temperature exceeds 105 EF.
When the spent fuel pool heat exchangers operate in modes 1-3, pool temperature monitoring ensures that it does not exceed 127.5 EF. Because of the importance assigned to the spent fuel pool temperature, the plant's operation staff would detect any significant degradation in heat exchanger performance and take appropriate corrective action. Monitoring of the spent fuel pool temperature readily indicates operability of the spent fuel pool heat exchangers. Inspection verifies the condition of the air-handling units cooled by component cooling water. During the audit and review, the staff also confirmed that temperature monitoring in rooms cooled by the air-handling units indicates by elevated area temperature air-handling units not operable. On the basis that there is sufficient indication through temperature monitoring and inspections of operability of these components not normally in service, the staff finds this exception acceptable.
During the audit and review, the staff reviewed a number of procedures for the performance testing of pumps in the Closed-Cycle Cooling Water System Program. The staff found the pumps tested quarterly in accordance with acceptance criteria for flow and inlet and outlet pressures consistent with GALL Report recommendations. In addition, the staff reviewed the plant procedure implementing water chemistry control processes and confirmed that the chemistry sampling frequencies are in accordance with EPRI water chemistry guidelines. The staff also confirmed by review of procedures that the Environmental and Chemistry Unit reviews, trends, and assesses plant chemistry data Operating Experience. LRA Section B.2.11 states that operating experience shows no evidence of age-related degradation for components wetted by the HNP closed-cycle cooling water systems. Components that interact with the service water system (e.g., heat exchanger tubes) have experienced degradation.
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Operating experience shows that the Closed-Cycle Cooling Water Program is upgraded continually based on industry experience, external and internal assessments, and routine program performance and has mitigated loss of material, cracking, and reduction of heat transfer effectiveness effectively.
During the audit and review, the staff reviewed plots of plant chemistry data back to 1997 for various components within the Closed-Cycle Cooling Water System Program indicating that plant personnel maintain chemistry parameters within established limits. The staff also reviewed recent NRC integrated inspection reports and noted no adverse trends or violations in the chemistry program from 1999 through 2006.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.11, the applicant provided the FSAR supplement for the Closed-Cycle Cooling Water System Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Closed-Cycle Cooling Water System Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which the LRA credits it. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.8 Boraflex Monitoring Program Summary of Technical Information in the Application. LRA Section B.2.12 describes the existing Boraflex Monitoring Program as consistent, with enhancements, with GALL AMP XI.M22, Boraflex Monitoring.
The Boraflex Monitoring Program assures that no unexpected degradation of the Boraflex neutron-absorbing material compromises the criticality analysis for spent fuel storage racks.
The program periodically inspects test coupons, correlates measured levels of silica in the spent fuel pool with analysis using a predictive code (e.g., RACKLIFE) to estimate boron loss from Boraflex panels, and tests neutron attenuation to measure the boron areal density of the test coupons. The Boraflex Monitoring Program will be enhanced to require periodic in-situ neutron attenuation testing (blackness testing) of boron areal density and the use of EPRI RACKLIFE predictive code or its equivalent to correlate the measured levels of silica in the spent fuel pool to estimate boron loss from Boraflex panels. The Boraflex Monitoring Program 3-81
 
will be in use until a new criticality analysis eliminates credit for Boraflex in the spent fuel pools still reliant on the neutron-absorbing material to maintain sub-criticality.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
Enhancement 1. The LRA states the following enhancement to the GALL Report program elements preventive actions, parameters monitored or inspected, and detection of aging effects, specifically:
The Boraflex Monitoring Program will be enhanced to include measurements of actual boron areal density using in-situ techniques.
During the audit and review, the staff noted that a plant-specific procedure monitors the integrity of the Boraflex neutron-absorbing material in the spent fuel racks through an engineering test.
The applicant will revise the procedure to measure actual boron areal density using in-situ techniques and to announce that this procedure involves license renewal commitments. The revised procedure will measure the boron areal density of the Boraflex material for degradation due to exposure to gamma radiation. This commitment will address the gradual thinning of the Boraflex material due to the dissolution of silica and consequent loss of neutron-absorbing capability.
The applicant proposed a commitment (Commitment No. 8) to enhance the program implementing procedure to measure actual boron areal density of the boraflex within the scope of license renewal. The staff finds this enhancement acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the preventive actions, parameters monitored or inspected, and detection of aging effects program elements.
Enhancement 2. The LRA states the following enhancement to the GALL Report program elements preventive actions and detection of aging effects,specifically:
Administrative controls that implement the program will be enhanced to include neutron attenuation testing (blackness testing), to determine gap formation in Boraflex panels.
During the audit and review, the staff noted that a plant-specific procedure monitors the integrity of the Boraflex neutron-absorbing material in the spent fuel racks and will test neutron attenuation to determine gap formation. The applicant will revise the procedure to announce that it involves license renewal commitments. The revised procedure will detect gaps in the Boraflex material occurring during long-term exposure to gamma radiation in a wet pool environment. This commitment will address monitoring for gap formation in the Boraflex material and consequent loss in local areas of neutron-absorbing capability.
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The applicant proposed a commitment (Commitment No. 8) to enhance the program implementing procedure to test neutron attenuation in boraflex panels within the scope of license renewal. The staff finds this enhancement acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the preventive actions and detection of aging effects program elements.
Enhancement 3. The LRA states the following enhancement to the GALL Report program elements preventive actions and detection of aging effects, specifically:
The HNP Boraflex Monitoring Program will be enhanced to include the use of EPRI RACKLIFE predictive code or its equivalent.
During the audit and review, the staff noted that HNP already uses the EPRI RACKLIFE predictive code. The code uses data from the spent fuel pool chemistry sampling results controlled by a plant-specific procedure. The Boraflex Monitoring Program uses the EPRI RACKLIFE predictive code. The applicant has made license renewal commitments for the Boraflex Monitoring Program. The EPRI RACKLIFE code will be a tool for predicting and trending Boraflex degradation from silica levels in the spent fuel pool.
The applicant proposed a commitment (Commitment No. 8) to enhance the program implementing procedure to include a code to predict and trend degradation of Boraflex within the scope of license renewal. The staff finds this enhancement acceptable because the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the preventive actions, parameters monitored or inspected, and detection of aging effects program elements.
Operating Experience. LRA Section B.2.12 states that HNP has used predictive codes (e.g.,
RACKLIFE) to confirm data determined from surveillance coupon testing and silica trend data.
In addition, the normal operating review process records operating experience regularly. HNP has implemented corrective actions as results of Boraflex Monitoring Program inspections, tests, and analyses and review of recent industry operating experience (i.e., NRC Generic Letter 96-04) recorded in corrective action documents. The staff has audited the program with satisfactory results. The staff cited two items of most importance reported in action requests described as Boraflex Degradation of BWR Fuel Storage Racks at HNP and RACKLIFE Model of PWR Fuel. Both conditions addressed Boraflex degradation in the PWR racks.
Corrective actions resolved these items and formalized the process of initiating preventive maintenance inspections at prescribed frequencies.
These operating experience results prove that the Boraflex Monitoring Program ensures the continuing integrity of Boraflex neutron-absorbing material where required to meet criticality analyses for the spent fuel storage racks.
During the audit and review, the staff reviewed the operating experience described in the LRA and the 2003 inspection results, finding them very comprehensive and detailed. The staffs review focused primarily on the most recent results. The applicant had not initiated any new action requests in response to these.
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During the audit and review, the staff reviewed the two action requests on Boraflex degradation of boiling-water reactor (BWR) fuel storage racks and the use of the RACKLIFE Model. These action requests followed detection by the Boraflex Monitoring Program of degradation of the neutron absorber sheets credited in criticality analyses for the spent fuel racks. Conditions documented included loss of boron from the Boraflex material. Resolution of the condition requires continued monitoring of the Boraflex degradation until approval of a new criticality analysis for the affected spent fuel racks.
On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff concluded that the applicants Boraflex Monitoring Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.12, the applicant provided the FSAR supplement for the Boraflex Monitoring Program. The staff reviewed this section and determines that the information in the FSAR supplement, with Commitment No. 8, is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Boraflex Monitoring Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation (Commitment No. 8) prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.9 Inspection of Overhead Heavy Load and Light Load Handling Systems Program Summary of Technical Information in the Application. LRA Section B.2.13 describes the existing Inspection of Overhead Heavy Load and Light Load Handling Systems Program as consistent, with enhancements, with GALL AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems.
The inspections monitor structural members for the absence of signs of corrosion other than minor surface corrosion and crane rails for abnormal wear. The inspections are annual for the fuel handling building cranes and every fuel cycle for the containment building cranes. Other monorail structures located in in-scope structures do not credit this program for aging management because they are addressed and managed as structural steel under the Structures Monitoring Program.
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Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
During the audit and review, the staff noted that in Commitment Letter HNP 06-0136, dated November 14, 2006, Enclosure 1, the Commitment No. 9 enhancements for the Inspection of Overhead Heavy Load and Light Load Handling Systems Program are not consistent with LRA Sections A.1.1.13 and B.2.13. The staff asked the applicant to explain these discrepancies.
In its response dated August 20, 2007, the applicant stated that LRA Commitment No. 9 and Section B.2.13 were not and should be consistent with LRA Section A.1.1.13 and the license renewal basis calculation.
The applicant further stated that this response, HNP-06-0136, Enclosure 1, Harris Nuclear Plant License Renewal Commitments, amended Commitment No. 9 for consistency agree with LRA Section A.1.1.13 and the license renewal basis calculation as follows:
Commitment No. 9, item (7) will be deleted.
LRA Section B.2.13, Detection of Aging Effects, Item (1) was changed to state:
to include all cranes that are within the scope of license renewal.
After these changes, there were only four (4) enhancement items in Harris Commitment Letter HNP-06-0136, Enclosure 1. (Commitment No. 9)
In the same August 20, 2007 letter, the applicant amended Commitment No. 9, as follows:
The program will be enhanced to: (1) include in the program all cranes within the scope of license renewal; (2) require the responsible engineer to be notified of unsatisfactory crane inspection results; (3) specify an annual inspection frequency for the fuel cask handling crane, fuel handling bridge crane, and fuel handling building auxiliary crane, and every refuel cycle for the polar crane, jib cranes, and reactor cavity manipulator crane, and (4) include a requirement to inspect for bent or damaged members, loose bolts/components, broken welds, abnormal wear of rails, and corrosion (other than minor surface corrosion) of steel members and connections.
The staff finds the applicants response acceptable. The number of program enhancements listed in Commitment No. 9 of the License Renewal Commitments, Revision 1, LRA Section B.2.13, and LRA Section A.1.1.13 now agree. The correct number of unique enhancements to the Inspection of Overhead Heavy Load and Light Load Handling Systems Program after the LRA amendment (which revised the license renewal commitments) is four.
The following enhancement evaluations are based on the amendment to reduce the number of enhancements from five to four in LRA Section B.2.13. Only these four enhancements are 3-85
 
require evaluation after the amendment.
Enhancement 1. The LRA states the following enhancement to meet the GALL Report program element scope of the program, specifically:
Revise administrative controls to include all cranes that are within the scope of license renewal.
During the audit and review, the staff noted that implementation of the Inspection of Overhead Heavy Load and Light Load Handling Systems Program is through corporate and plant-specific procedures. Inspection of overhead heavy load and light load handling systems is through the corporate maintenance rule structures monitoring procedure. The applicant will revise this procedure to include all cranes within the scope of license renewal, not just maintenance rule cranes.
The applicant proposed a commitment (Commitment No. 9, item No. 1) to enhance the program implementing procedure to include all cranes within the scope of license renewal. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the scope of the program program element.
Enhancement 2. The LRA states the following enhancement to the GALL Report program element parameters monitored or inspected, specifically:
Revise administrative controls to require notification of the responsible engineer of unsatisfactory inspection results.
During the audit and review, the staff noted that implementation of the Inspection of Overhead Heavy Load and Light Load Handling Systems Program is through corporate and plant-specific procedures. Inspection of overhead heavy load and light load handling systems is through plant-specific procedures which document inspections for the reactor cavity manipulator crane (Enhancement 3), fuel-handling bridge crane, fuel-handling building auxiliary crane, jib cranes, polar crane, and the fuel cask-handling crane. The applicant will revise these procedures to require maintenance to notify responsible engineers of any crane inspection results unsatisfactory for license renewal The applicant proposed a commitment (Commitment No. 9, item No. 2) to enhance program implementing procedures to require notification to responsible engineers of unsatisfactory crane inspection results. The staff finds this commitment acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the parameters monitored or inspected program element.
Enhancements 3 and 4. The LRA states the following unique enhancements to the GALL Report program element detection of aging effects, specifically:
Revise administrative controls to specify an annual inspection frequency for the 3-86
 
fuel cask handling crane, fuel handling bridge crane, and fuel handling building auxiliary crane, and every refuel cycle for the polar crane, jib cranes, and reactor cavity manipulator crane.
During the audit and review, the staff noted that the applicant will revise a corporate procedure to specify an annual inspection frequency for the fuel-handling building cranes and an inspection frequency of every fuel cycle for the containment cranes:
Revise administrative controls to include requirements to inspect for bent or damaged members, loose bolts or components, broken welds, abnormal wear of rails, and corrosion (other than minor surface corrosion) of steel members and connections.
During the audit and review, the staff noted that the applicant will revise plant-specific procedures for the reactor cavity manipulator crane, fuel-handling bridge crane, fuel-handling building auxiliary crane, jib cranes, polar crane, and the fuel cask handling crane to inspect for bent or damaged members, require inspection for loose bolts or components and broken welds, clarify rails to be inspected for abnormal wear, and specify an inspection for corrosion (other than minor surface corrosion) of steel members and connections.
The applicant proposed a commitment (Commitment No. 9, item Nos. 3 and 4 after amendment) to enhance program implementing procedures: (1) to specify an annual inspection frequency for the fuel cask-handling crane, fuel-handling bridge crane, and fuel-handling building auxiliary crane and every refuel cycle for the polar crane, jib cranes, and reactor cavity manipulator crane and (2) to include a requirement to inspect for bent or damaged members, loose bolts or components, broken welds, abnormal wear of rails, and corrosion (other than minor surface corrosion) of steel members and connections. The staff finds these commitments acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the detection of aging effects program element.
On this basis, the staff finds all four enhancements acceptable because when are implemented the Inspection of Overhead Heavy Load and Light Load Handling Systems Program will be consistent with GALL AMP XI.M23 and will assure adequate management of the effects of aging.
Operating Experience. LRA Section B.2.13 states that plant-specific operating experience shows issues with missing and loose crane components, crane operation anomalies, industry issues, crane manufacturer recommendations, periodic inspections, and regulatory compliance through the corrective action process. Even though there has been no evidence of corrosion or wear reported for the cranes, these aging effects found for other carbon steel components for similar environments still require aging management. Crane monitoring programs are upgraded continually based upon industry and plant-specific operating experience. The results of this intrusive and proactive approach to the operation and management of cranes validate the effectiveness of procedures implementing the Inspection of Overhead Heavy Load and Light Load Handling Systems Program. These results of operating experience prove that the Inspection of Overhead Heavy Load and Light Load Handling Systems Program ensures the continuing integrity of the subject license renewal cranes.
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During the audit and review, the staff reviewed the operating experience described in the LRA and an HNP maintenance rule self-assessment for the period from June 30, 2003, to November 17, 2004, and found the program effective in meeting 10 CFR 50.65 requirements.
The self-assessment reported two weaknesses and five items for management consideration.
One weakness in structural items indicated a need to update the maintenance rule database with current performance criteria. Corrective action resolved the weakness.
During the audit and review, the staff reviewed 1999, 2001, and 2005 HNP corporate Nuclear Assessment Section assessments of the Maintenance Rule Program. The assessments did not include the Inspection of Overhead Heavy Load and Light Load Handling Systems Program specifically but did include the Maintenance Rule Program, which inspects overhead heavy load and light load handling systems. The 1999 assessment found an issue and a weakness in the Maintenance Rule Program. These deficiency findings resulted in corrective actions which improved the overall Maintenance Rule Program. The 2001 and 2005 assessments found no issues or weaknesses in the Maintenance Rule Program.
During the audit and review, the staff reviewed:
* a summary of system walkdowns, periodic system reviews and vendor inspection reviews documented by the system engineer responsible for the cranes within the scope of license renewal. The staff determined that no entries addressed corrosion of steel or crane wear in the summaries of the system walkdowns and that walkdown conclusions were that the cranes inspected appeared to be in good structural condition. The staff also determined that the periodic system review summary indicated that the reviews are indeed periodic and document a particular crane histories. The summaries indicated no adverse conditions due to corrosion or crane rail wear. In addition, the staff determined from the summary of crane vendor inspection reviews of findings of clearance, brake adjustment, lubrication, broken resistor, missing splice plates, and housekeeping issues that they provide a valuable independent review; however, the summary reviewed indicated no adverse conditions due to corrosion nor crane rail wear.
* NRC Inspection Report 50-400/97-07 (1997) which evaluated the effectiveness of HNP implementation of maintenance rule requirements. The inspection concluded that the program was comprehensive and effective. There was no specific mention of the inspection of overhead heavy load and light load handling systems or of system violations or deficiencies.
* various action requests and condition reports written against the cranes within the scope of license renewal. Missing handrails on polar crane access platforms and set screws for the reactor cavity manipulator crane shaft couplings needing replacement were some of the documented conditions of the cranes. The conditions were corrected.
The staff reviewed system engineer notes, the NRC inspection report, and action request and condition report subject matter and found no operating history issues of corrosion of crane structural members or crane rail wear.
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On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff concluded that the applicants Inspection of Overhead Heavy Load and Light Load Handling Systems Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.13, the applicant provided the FSAR supplement for the Inspection of Overhead Heavy Load and Light Load Handling Systems Program. In a letter dated August 20, 2007, the applicant amended Commitment No. 9 to enhance the Inspection of Overhead Heavy Load and Light Load Handling Systems Program prior to the period of extended operation. The staff reviewed this section and determines that, with the LRA amendment to Commitment No. 9, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Inspection of Overhead Heavy Load and Light Load Handling Systems Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation through Commitment No. 9 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.10 Fire Protection Program Summary of Technical Information in the Application. LRA Section B.2.14 describes the existing Fire Protection Program as consistent, with enhancements, with GALL AMP XI.M26, Fire Protection.
The Fire Protection Program manages aging of the diesel-driven fire pump fuel oil supply line and credited fire barrier assemblies including fire doors, penetration seals, fire wrap, barrier walls, barrier ceilings and floors, and seismic joint filler. The program is implemented through various plant procedures and will manage the aging effects of the subject components effectively to maintain component intended functions through the period of extended operation.
The applicant relies on water-based fixed fire suppression systems to meet 10 CFR 50.48 fire protection requirements. The GALL Report refers to fixed suppression systems that use carbon dioxide and Halon. Carbon dioxide systems are not in use at HNP for fire protection. The Halon 1301 extinguishing system for the record storage facility located in the administration building outside the protected area is not needed for compliance with 10 CFR 50.48. In 3-89
 
addition, a foam suppression system protects the auxiliary boiler fuel oil tanks, which are at least 500 feet and isolated from any Class 1 structure and structures directly related to power production. The foam suppression system is not needed for compliance with 10 CFR 50.48.
The applicant also uses distributed portable fire extinguishing equipment containing Halon and carbon dioxide in various areas to protect safety-related equipment. These portable extinguishers require no AMP because they are treated as short-lived equipment periodically inspected and replaced as required.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
The staff also noted no exceptions to GALL AMP XI.M26, "Fire Protection." The staff reviewed the Fire Protection Program for which the applicant claims consistency with GALL AMP XI.M26 and found it consistent. Furthermore, the staff concludes that the applicant's Fire Protection Program reasonably assures management of aging effects so components crediting this program can perform intended functions consistent with the CLB during the period of extended operation. The staff finds the applicant's Fire Protection Program consistent with recommended GALL AMP XI.M26, "Fire Protection," and acceptable with enhancements as described:
Enhancement 1. The LRA states an enhancement to the GALL Report program element "parameters monitored/inspected," specifically:
The HNP Fire Protection Program procedure for periodic inspections of penetration seals will be enhanced to include inspections for signs of degradation as described in NUREG-1801, Section XI.M26, for this program element. This will include requirements to inspect for cracking, seal separation from walls and components, separation of layers of material, rupture and puncture of seals, which are directly caused by increased hardness, and shrinkage of seal material due to weathering.
This enhancement is acceptable because it will make the program consistent with GALL AMP XI.M26, Element 3, which states that visual inspection of approximately 10 percent of each type of penetration seal proceed during walkdowns at least once every refueling outage.
This enhancement is also acceptable for making the program consistent with GALL AMP XI.M26, Element 6, which states that inspection results are acceptable if there are no visual indications (outside those allowed by approved penetration seal configuration) of cracking, separation of seals from wall and components, separation of layers of material, or seal ruptures or punctures. The staff reviewed the applicant's program procedures for whether these elements are consistent with the GALL Report.
On this basis, the staff finds the enhancement acceptable because the enhanced Fire Protection Program will be consistent with GALL AMP XI.M26 and will add assurance of adequate management of aging effects.
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Enhancement 2. The LRA states an enhancement to the GALL Report program elements "parameters monitored/inspected," specifically:
The HNP Fire Protection Program will be enhanced to include a periodic test procedure for inspections of barrier walls, ceilings, and floors on at least an 18-month interval. Visual inspections of the fire barrier walls, ceilings, and floors will examine any sign of degradation such as cracking, spalling, and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates.
The enhanced procedure will include requirements for notification, restoration, and mitigating actions if any fire barrier wall, ceiling or floor fails to meet the acceptance criteria.
This enhancement is acceptable because it will make the program consistent with GALL AMP XI.M26, Element 3, which states that visual inspection will examine fire barrier walls, ceilings, and floors for any sign of degradation like cracking, spalling, and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates. This enhancement is also acceptable for making the program consistent with GALL AMP XI.M26, Element 6, which states that inspection results are acceptable if there are no visual indications of concrete cracking, spalling, and loss of material of fire barrier walls, ceilings, and floors. The staff reviewed the applicants program procedures for consistency with the GALL Report.
On this basis, the staff finds the enhancement acceptable because the enhanced Fire Protection Program will be consistent with GALL AMP XI.M26 and will add assurance of adequate management of aging effects.
Enhancement 3. The LRA states an enhancement to the GALL Report program elements "parameters monitored/inspected," specifically:
The Program operability test procedure for the diesel-driven fire pump will be enhanced to include a visual inspection of the insulated fuel oil supply piping for signs of leakage.
This enhancement is acceptable because it will make the program consistent with GALL AMP XI.M26, Element 3, which states that observation of the diesel fire pump during performance tests detects any fuel supply line degradation. This enhancement is also acceptable for making the program consistent with GALL AMP XI.M26, Element 6, which states that no corrosion is acceptable in the diesel-driven fire pump fuel supply line. The staff reviewed the applicants program procedures for consistency with the GALL Report.
On this basis, the staff finds the enhancement acceptable because the enhanced Fire Protection Program will be consistent with GALL AMP XI.M26 and will add assurance of adequate management of aging effects.
Operating Experience. LRA Section B.2.14 states that the Fire Protection Program is maintained in accordance with HNP engineering program requirements and managed in accordance with plant administrative controls. The operating history and assessment results for 3-91
 
the program show it effectively preserves safe shutdown capability from fire. The Fire Protection Program improves continually on the bases of both industry and plant-specific operating experience. Industry operating experience is incorporated into the Fire Protection Program through the Operating Experience Program and through staff generic communications. The program benefits from bench-marking other industry plants. Plant-specific operating experience also improves the Fire Protection Program through the Corrective Action Program and program assessments.
The LRA also states that QA audits and surveillances revealed system equipment in good material condition meeting licensing requirements. The audits and surveillances revealed no issues or findings with impact on program effectiveness to manage aging effects for fire protection components.
In September 2005 the NRC completed a triennial fire protection inspection to assess whether the plant had implemented an adequate fire protection program and whether post-fire safe shutdown capabilities have been established and maintained properly. Results confirmed that plant personnel had maintained the fire protection systems in accordance with an approved fire protection program, detected program deficiencies, and implemented appropriate corrective actions. The inspection team also evaluated the material condition of fire area boundaries, fire doors, and fire dampers and concluded that plant personnel had maintained passive features in a state of readiness. The staff reviewed operating experience and operating experience reports and interviewed the applicants technical personnel and confirmed that plant-specific operating experience revealed no degradation not bounded by industry experience. The staff also reviewed condition reports for the corrective actions taken for signs of degradation of fire protection components. The staff confirmed that repairs to the degraded fire barriers or by adequate engineering evaluations of their acceptability closed out the condition reports. The staff noted that the applicants periodic inspections place deficiencies into the corrective action program for timely, appropriate corrective actions.
On the basis of its review of the operating experience and discussions with the applicant's technical personnel, the staff concludes that the applicant's Fire Protection Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.14, the applicant provided the FSAR supplement for the Fire Protection Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Fire Protection Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the 3-92
 
applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.11 Fire Water System Program Summary of Technical Information in the Application. LRA Section B.2.15 describes the existing Fire Water System Program as consistent, with enhancements, with GALL AMP XI.M27, Fire Water System.
The Fire Water System Program periodically monitors system pressure, evaluates wall thickness, tests flow and pressure in accordance with National Fire Protection Association commitments, and visually inspects overall system condition. These activities effectively determine whether corrosion and bio-fouling have occurred. Inspections of sprinkler heads assure that corrosion products that could block flow from the sprinkler heads do not accumulate. These measures for timely corrective action for system degradation ensure the capability of the water-based Fire Suppression System to perform its intended function.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
The staff also noted no exceptions to GALL AMP XI.M27, "Fire Water System." The staff reviewed the Fire Water System Program for which the applicant claims consistency with GALL AMP XI.M27 and found it consistent. Furthermore, the staff concludes that the applicant's Fire Water System Program reasonably assures management of aging effects so components crediting this program can perform intended functions consistent with the CLB during the period of extended operation. The staff finds the applicant's Fire Water System Program consistent with the recommended GALL AMP XI.M27, "Fire Water System," and acceptable with enhancements as described:
Enhancement 1. The LRA states an enhancement to the GALL Report program element "parameters monitored/inspected," specifically:
Revise the program to incorporate a requirement to perform non-intrusive baseline pipe thickness measurements at various locations, prior to the expiration of current license and trended through the period of extended operation. The plant-specific inspection intervals will be determined by engineering evaluation performed after each inspection of the fire protection piping to detect degradation prior to the loss of intended function.
The staff finds this enhancement acceptable because the enhanced Fire Water System Program will be consistent with GALL AMP XI.M27, Element 4, and will add assurance of 3-93
 
adequate management of aging effects.
Operating Experience. LRA Section B.2.15 states that the Fire Water System Program is maintained in accordance with HNP engineering program requirements for assurance of effective program implementation to meet regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have authority and responsibility to implement the program and to commit adequate resources to its activities. The operating history and assessment results for the Fire Water System Program show that it effectively preserves safe shutdown capability from fire. These measures assure continual improvement of the program as prompted by industry experience and research and routine program performance and program capability to support plant safety throughout the period of extended operation.
The staff reviewed the operating experience described in the LRA and interviewed the applicant's technical personnel to confirm that plant-specific operating experience revealed no degradation not bounded by industry experience.
On September 2005, the staff completed a triennial fire protection inspection for whether the applicant had implemented an adequate fire protection program and established properly maintained post-fire safe shutdown capabilities. Results confirmed that the applicant had maintained the fire protection systems in accordance with an approved fire protection program, detected program deficiencies, and implemented appropriate corrective actions. The inspection team also evaluated the material condition of selected wet pipe sprinkler systems, standpipe systems, and hose reels and concluded that the applicant had maintained passive features in a state of readiness. A QA audit revealed no issues or findings with impact on program effectiveness to manage loss of material for fire water system components.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.15, the applicant provided the FSAR supplement for the Fire Water System Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Fire Water System Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
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3.0.3.2.12 Fuel Oil Chemistry Program Summary of Technical Information in the Application. LRA Section B.2.16 describes the existing Fuel Oil Chemistry Program as consistent, with enhancements, with GALL AMP XI.M30, Fuel Oil Chemistry.
Fuel oil quality is maintained by monitoring and controlling fuel oil contamination in accordance with the guidelines of the American Society for Testing and Materials (ASTM) Standards D1796 (as referenced in ASTM D975-81), D2276-78, and D4057-81. The applicant applies the 1983 version of D1796. The ASTM standards are in accordance with the applicants technical specification surveillance requirements for fuel oil testing. In accordance with industry best practices, HNP periodically tests for the presence of biological growth. Exposure to fuel oil contaminants (e.g., water and microbiological organisms) is minimized by verification of new oil quality and addition of stabilizers before its introduction into the storage tanks and by periodic sampling for whether the tanks are free of water, particulates, and biological growth. Program effectiveness is verified by periodic tank inspections for significant degradation to maintain component intended functions during the period of extended operation.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions and enhancements to determine whether the AMP, with the exceptions and enhancements, remained adequate to manage the aging effects for which the LRA credits it.
Exception 1. The LRA states an exception to the GALL Report program element scope of the program, specifically:
In addition to the aging mechanisms listed in the GALL Report, the HNP Fuel Oil Chemistry Program is credited with managing loss of material due to crevice corrosion. The GALL Report program lists loss of material due to general, pitting, and microbiologically-influenced corrosion.
The staff finds this exception acceptable because the GALL Report already considers the loss of material due to pitting in an environment similar to that which causes crevice corrosion. In addition, the monitoring and inspection methods of the Fuel Oil Chemistry Program are appropriate for detecting crevice corrosion.
Exception 2. The LRA states an exception to the GALL Report program element scope of the program, specifically:
In addition to storage tanks, the program is used to manage aging effects on all within scope system components wetted by fuel oil. This exception results in additional materials being within scope beyond those in the GALL Report and is considered to be an exception.
The staff finds this exception acceptable because quality control of fuel oil in contact with these surfaces is in the supply tanks by control of its chemistry or by design features. The materials in 3-95
 
these additional components, therefore, are not subject to an aggressive environment.
Exception 3. The LRA states exceptions to the GALL Report program element preventive actions, specifically:
None of the systems within scope of this program use corrosion inhibitors. Site operating experience does not show adverse trends in corrosion in the fuel oil components. Therefore, corrosion inhibitors are not required.
During the audit and review, the staff noted that HNP actually used corrosion inhibitors in the fuel oil and asked the applicant why it needed this exception.
In its response dated August 20, 2007, the applicant amended the LRA:
Under the program description section, the sentence starting with Exposure to fuel oil contaminants,... will be changed to say: Exposure to fuel oil contaminants, such as water and microbiological organisms, is minimized by verifying the quality of new oil and the addition of a stabilizer, which contains a biocide and corrosion inhibitors, before the fuel oil is added to the storage tanks that supply the Emergency Diesel Generator and Security Power Diesel Generator. Continued quality levels are assured by periodically checking for and removing water from tank drains, sampling to confirm that the bulk properties of water and sediment, particulate contamination, and biological growth are within administrative target values or Technical Specification limits.
Under the exceptions section, for the preventive actions, the first sentence has been changed to a Note and the remaining items renumbered. The Note states that: A stabilizer containing a biocide and corrosion inhibitor is added to new fuel before it is added to the storage tanks in the diesel fuel oil storage and transfer system and the security power system.
The staff finds this response acceptable because with this amendment the applicants Fuel Oil Chemistry Program in the LRA uses stabilizers with a biocide and corrosion inhibitor consistent with GALL report recommendations and therefore acceptable. The diesel-driven fire pump fuel oil tank does not benefit from the stabilizer with the biocide and corrosion inhibitor. The staff finds this situation acceptable based on a review of plant-specific operating experience and on the fact that the staff confirmed that routine refreshment of this fuel oil replaces fuel oil used during testing. The staff confirmed during the onsite audit that HNP typically replaces the fuel oil in the tank every three years.
Exception 4. The LRA states exceptions to the GALL Report program element preventive actions, specifically:
The penetrations for the drain line in the emergency diesel generator day tanks enter the tanks horizontally resulting in water and sediment, if present, remaining 3-96
 
on the bottom of the tanks. The day tanks are in the Diesel Generator Building, which has its own HVAC system and, therefore, would not be subject to large temperature swings causing condensation. Frequent checks for water are performed as a result of Technical Specification Surveillance Requirements. The tanks are periodically cleaned to minimize corrosion and biological growth.
During the audit and review, the staff noted that the suction lines for these day tanks are on the tank bottoms and that the monthly operation of the emergency diesel generators confirms whether water and sediment are drawn downstream from the day tanks in any significant quantities. On the bases of the periodic cleaning of the tanks, the low probability of condensation formation in the tanks due to temperature changes, and lack of evidence of water and sediment downstream from the day tanks, the staff finds this exception acceptable.
Exception 5. The LRA states exceptions to the GALL Report program element preventive actions, specifically:
The security power system diesel engine (day) tank is sampled at the inlet filter to the engine, which is installed at an elevation above the tanks outlet nozzle.
The outlet nozzle is located horizontally at the bottom of the tank; thus, sediment and water may accumulate there. Periodic water removal is not performed.
During periodic inspection of the tank, removal of water and sediment will be performed, as practical, given its limited access.
During the audit and review, the staff reviewed plant procedures to confirm that water removal from the main fuel oil tank, which supplies fuel oil to the security power system diesel day tank, minimizes a potential source of water to the day tank. In addition, the staff noted that the day tank is elevated over the main fuel oil tank with the fill line on the day tank bottom to minimize the potential presence of water and sediment. Even though the sample point may not be conducive to the detection of the presence of water and sediment in the day tank fuel oil, the staff finds this exception acceptable based on the configuration of the day tank inlet piping and the periodic inspection and removal of water and sediment from the day tanks by documented plant procedures reviewed during the onsite audit.
Exception 6. The LRA states exceptions to the GALL Report program element preventive actions, specifically:
The use of stabilizers in the diesel-driven fire pump fuel oil tank is not warranted, as fuel oil is frequently refreshed. The consumption of fuel oil is the result of the monthly requirement in Fire Protection Program to run the pump for 30 minutes on relief flow. The frequent addition of diesel fuel oil eliminates the need for stabilizers.
During the audit and review, the staff confirmed that HNP replaces the fuel oil in the diesel-driven fire pump fuel oil tanks completely about every three years based on the amount of diesel operation time to support the monthly fire protection requirement. Based on the fact of regular addition of fresh fuel oil to the day tank, the staff finds this exception acceptable.
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Exception 7. The LRA states an exception to the GALL Report program element parameters monitored or inspected, specifically:
HNP uses the guidance in ASTM D2276-78, Method A, without modification for filter pore size. The filter used is a smaller pore size.
The use of a filter pore size smaller than recommended by the standard will trap more particulates with the result of corrective actions sooner than with the larger filter pore size.
Based on the conservative use of filter pore size, the staff finds this exception acceptable.
Exception 8. The LRA states exceptions to the GALL Report program element detection of aging effects, specifically:
Multi-level sampling is not performed in the main fuel oil storage tanks, as recommended for the larger fuel oil tanks used in the petroleum industry.
Discretion is used at nuclear plants where significantly smaller tanks are used for storage and are not subject to the same degree of heterogeneity.
During the audit and review, the staff reviewed the sampling procedure for the main fuel oil tanks calling for samples from a point in the lower section of the tanks (exhibited on plant drawing 5-G-0063-LR at location XY). Samples from a low point in the tank are conservative as to multi-level sampling for water and sediment, which tend to be present in higher concentrations in the lower sections. The staff finds this method conservative and therefore acceptable for the main diesel fuel oil tanks.
For the security diesel main fuel tank, the staff noted during the audit and review that the sampling used a weighted beaker to take samples from the bottom of the tank where any sediment will accumulate for the detection of corrosion products, microbiological organisms, or water if present. The staff finds use of a weighted sampling beaker conservative as to multi-level sampling and therefore acceptable.
For the diesel-driven fire pump fuel oil storage tank, the staff reviewed the chemistry sampling procedure and noted a weighted beaker also in use to sample fuel oil in this tank. In this case, the sampler fills gradually with the beaker on the bottom of the tank and then the sampler stopper opens gradually as the beaker is pulled to the top of the tank. The staff finds this method similar to multi-level sampling and acceptable as a multi-level method consistent with the GALL Report recommendation.
Based on the preceding facts, the staff finds this exception acceptable because the applicant uses a sampling method equivalent to or more conservative than that recommended by the GALL Report. As noted, the specific sampling method depends on the fuel oil storage tank sampled.
Exception 9. The LRA states exceptions to the GALL Report program element detection of aging effects, specifically:
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An exception is taken regarding ultrasonic testing of the security power system diesel engine fuel oil tanks. Ultrasonic thickness measurements would only be done for the buried main tank and the (day) tank if visual inspection reveals significant internal damage due to loss of material.
During the audit and review, the staff confirmed that this exception is for both the main fuel oil storage tank and the day tank. The main fuel oil tank is double-walled with the internal surface inspected periodically under this program. If these visual inspections find no evidence of degradation additional ultrasonic thickness measurements are not necessary. The staff finds this exception acceptable based on the alternative indication of degradation by visual inspections, the dual-walled tank design with corrosion-resistant material on the outer liner exposed to soil, and the applicants commitment to ultrasonic testing if it detects significant degradation. In addition to periodic visual inspections, the day tank receives an external examination under the Structures Monitoring Program. If there is no significant interior or exterior degradation, there is no compelling reason for ultrasonic thickness measurements. On the bases of alternative methods to detect the aging effect and the applicants commitment to ultrasonic testing if it detects significant degradation, the staff finds this exception acceptable.
Exception 10. The LRA states exceptions to the GALL Report program element detection of aging effects, specifically:
An exception is taken regarding ultrasonic testing of the diesel-driven fire pump fuel oil tank. Ultrasonic thickness measurements would only be done for the tank if visual inspection reveals significant internal damage due to loss of material or limited access makes visual inspection unacceptable.
During the audit and review, the staff noted that the applicant has developed an enhancement to remove the sediment from the tank periodically for a visual inspection of the internal surface.
In addition, the staff noted that the External Surfaces Monitoring Program will inspect visually the external surface of this tank mounted above ground. Based on the alternative means to detect surface degradation and the applicants commitment to testing if it detects significant degradation of the internal or external surfaces, the staff finds this exception acceptable.
Exception 11. The LRA states exceptions to the GALL Report program element monitoring and trending, specifically:
Monitoring and trending for biological growth (e.g., microorganisms and algae) in the fuel oil contained within the diesel fuel oil storage tank building tanks will be performed semiannually not quarterly.
As described in the LRA, HNP has developed an enhancement to require for the diesel fuel oil storage tank at least semiannual monitoring and trending of bacterial growth instead of the quarterly monitoring recommended by the GALL Report. This enhancement causes the applicant to take an exception because the frequency is not consistent with that of the GALL Report recommendation.
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During the audit and review, the staff noted that plant-specific operating experience shows no biological growth On this basis and because the applicant uses a fuel oil stabilizer with a biocide before adding fuel oil to the storage tanks, the staff finds this exception acceptable.
Exception 12. The LRA states exceptions to the GALL Report program element monitoring and trending, specifically:
The security power system buried tank and (day) tank are monitored semiannually, not quarterly.
During the audit and review, the staff asked the applicant to confirm the sampling frequency for the emergency diesel generator and security building diesel generator fuel oil day tanks.
In its response dated August 20, 2007, the applicant clarified its position on sampling frequency by stating that the GALL Report does not address the sampling frequency of the day tanks, which are downstream of the main fuel oil storage tanks; therefore, the applicant considers the frequency and testing of the fuel oil in the day tanks for the emergency diesel generator and security diesel confirmatory to the testing on the main fuel oil tanks. The periodic testing is not an exception for the emergency diesel generator and neither an enhancement nor an exception for the security diesel. In the letter dated August 20, 2007, the applicant amended the LRA to include this information. On the basis that the fuel oil testing is a periodic confirmation of the main tank testing, the staff finds this response acceptable.
Because the GALL Report recommends quarterly testing, the semiannual testing for biological growth in the security diesel buried tank is still an exception that the staff finds acceptable on the bases that plant-specific operating experience shows no evidence of biological growth and that the fuel oil stabilizer added to the fuel oil before it is added to the storage tanks has a biocide.
Exception 13. The LRA states exceptions to the GALL Report program element monitoring and trending, specifically:
Testing for biological growth (e.g., microorganisms and algae) in the diesel driven fire pump fuel oil tank will be performed semiannually not quarterly.
The staff finds this exception acceptable on the basis that plant-specific operating experience shows no evidence of biological growth since HNP switched to Grade 1-D fuel oil. Furthermore, under the enhancement for the corrective actions program element, the applicant has committed to initiate a nuclear condition report when biological growth exceeds an administrative limit. The applicant will use this exception for trending purposes and will take appropriate actions to address any detrimental biological growth issues.
Exception 14. The LRA states an exception to the GALL Report program element acceptance criteria, specifically:
HNP uses the guidance in ASTM D2276-78, Method A, without modification for 3-100
 
filter pore size. The filter used is a smaller pore size.
During the audit and review, the staff confirmed that the applicant uses a filter with a pore size smaller than specified in ASTM D2276-78, Method A, without changing the acceptance criteria.
On the basis that the applicant uses a more conservative filter with the same acceptance criteria, the staff finds this exception acceptable.
Enhancement 1. The LRA states an enhancement to the GALL Report program element scope of the program, specifically:
Enhance the monitoring procedure for the diesel-driven fire pump fuel oil tank by checking for and removing accumulated water and adding particulate analysis.
These activities will be performed quarterly. Additionally, biological growth testing will be added and performed semiannually.
The staff finds the enhancement to check for and remove accumulated water for quarterly particulate analyses consistent with the GALL Report recommendations and therefore acceptable. Evaluation of the semiannual biological growth testing is under Exception 13.
Enhancement 2. The LRA states enhancements to the GALL Report program element preventive actions, specifically:
Develop a work activity to periodically clean and inspect the security power system buried fuel tank and (day) tank. Prior to inspection, fuel, water, and sediment will be removed as practical given the limited access in the tank. UT or other NDE will be performed if inspection proves inadequate or indeterminate.
The staff finds this enhancement consistent with GALL Report recommendations and acceptable.
Enhancement 3. The LRA states enhancements to the GALL Report program element "preventive actions," specifically:
Revise the chemistry sampling procedure for the diesel-driven fire pump fuel oil tank to identify the corrective actions to be taken if a positive result is obtained for biological growth. The appropriate course of action should be taken after the amount and type of biological growth is quantified. The use of biocides will be included as one alternative.
The staff finds this enhancement consistent with GALL Report recommendations and acceptable.
Enhancement 4. The LRA states enhancements to the GALL Report program element "preventive actions," specifically:
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Develop a work activity to inspect the diesel-driven fire pump fuel oil tank. Prior to the inspection, remove fuel, water, and sediment as practical due to the limited access. UT or other NDE will be performed if inspection proves inadequate or indeterminate.
The staff finds this enhancement consistent with GALL Report recommendations and acceptable.
Enhancement 5. The LRA states enhancements to the GALL Report program element "preventive actions," specifically:
Develop a work activity to periodically check and remove water from the bottom of the diesel-driven fire pump fuel oil tank.
The staff finds this enhancement consistent with GALL Report recommendations and acceptable.
Enhancement 6. The LRA states enhancements to the GALL Report program element detection of aging effects, specifically:
Prior to the period of extended operation and as part of the One-Time Inspection Program, ultrasonic thickness measurements will be taken and compared with previous measurements to confirm the effectiveness of the program in preventing loss of material of the internal surfaces of the diesel fuel oil storage tank building tank liners.
The staff finds this enhancement consistent with the GALL Report recommendations and acceptable.
Enhancement 7. The LRA states enhancements to the GALL Report program element "detection of aging effects," specifically:
Refer to the enhancements for cleaning and inspecting the security power system buried fuel tank and (day) tank discussed under the preventive actions above.
The staff finds this enhancement consistent with the GALL Report recommendations and acceptable.
Enhancement 8. The LRA states enhancements to the GALL Report program element "detection of aging effects," specifically:
Refer to the enhancements for cleaning and draining water from the diesel-driven fire pump fuel oil tank discussed under the preventive actions above.
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The staff finds this enhancement consistent with the GALL Report recommendations and acceptable.
Enhancement 9. The LRA states enhancements to the GALL Report program element monitoring and trending, specifically:
Revise the Fuel Oil Chemistry Program procedure to require, at least semiannually, monitoring and trending of bacterial growth in the fuel oil contained in the diesel fuel oil storage tank building tanks and semiannual monitoring and trending of particulate contamination and water and sediment in the emergency diesel generator fuel oil day tanks.
During the audit and review, the staff asked the applicant to confirm the sampling frequency for the emergency diesel generator and security building diesel generator fuel oil day tanks.
In its response dated August 20, 2007, the applicant clarified its position on the sampling frequency of the fuel oil day tanks by stating that the GALL Report does not address the sampling frequency of the day tanks, which are downstream of the main fuel oil storage tanks; therefore, the applicant considers the frequency and testing of the fuel oil in the day tanks for the emergency diesel generator and security diesel confirmatory to the testing on the main fuel oil tanks. In the letter dated August 20, 2007, the applicant amended the LRA accordingly to state that the testing of the emergency diesel generator day tanks is confirmatory to the tests on the main storage tanks.
The staff finds the enhancement to require monitoring and trending of bacterial growth, particulate contamination, and water and sediment consistent with the GALL Report and acceptable. The semiannual frequency inconsistent with the GALL Report recommendation is evaluated under Exception 11.
Enhancement 10. The LRA states enhancements to the GALL Report program element "monitoring and trending," specifically:
For the emergency diesel fuel oil day tanks, establish an appropriate sample point, e.g., in the drain line or pump suction line upstream of piping components such as a filter or pump, and incorporate it into the sampling procedure.
As in Enhancement No. 9, testing of the emergency diesel fuel oil day tanks is confirmatory to the testing on the main storage tanks. On this basis and because the applicant has committed to establishment of an appropriate sample point, the staff finds this enhancement acceptable.
Enhancement 11. The LRA states enhancements to the GALL Report program element "monitoring and trending," specifically:
Revise the program procedure to require, at least semiannually, monitoring and trending of bacterial growth in the fuel oil contained in the security diesel system buried fuel oil tank. Add a requirement to perform quarterly monitoring and 3-103
 
trending for water and sediment and particulates if diesel fuel oil Grade No. 2-D is used.
The staff finds the enhancement to require monitoring and trending of particulate contamination, water, and sediment consistent with the GALL Report and acceptable. The semiannual frequency for trending the bacterial growth is, however, inconsistent with the GALL Report and evaluated under Exception 11. In addition, the enhancement to require quarterly monitoring and trending for water, sediment, and particulates in Grade No. 2-D fuel oil is consistent with the GALL Report and acceptable.
Enhancement 12. The LRA states enhancements to the GALL Report program element "monitoring and trending," specifically:
Revise the program procedure to require, at least semiannually, monitoring of bacterial growth in the fuel oil contained in the diesel-driven fire pump fuel oil tank, and at least quarterly, monitoring and trending of particulate contamination with appropriate administrative limits. Additionally, for the storage tank, perform quarterly checks for water using the bottom drain line.
The staff finds the monitoring and trending of water and particulate contamination consistent with the GALL Report and acceptable. The semiannual frequency of the monitoring of bacterial growth is, however, inconsistent with the GALL Report and evaluated under Exception 13.
Enhancement 13. The LRA states enhancements to the GALL Report program element corrective actions, specifically:
A nuclear condition report will be initiated for trending purposes when an administrative limit is exceeded for water and sediment, particulates, biological growth or when water is drained from a tank. Based on the judgment of the responsible personnel, a nuclear condition report of higher priority may be initiated that requires the cause to be determined and actions to be taken to prevent recurrence. Additionally, where the program does not specify administrative limits for water and sediment and particulates, appropriate values will be established.
The staff finds this enhancement consistent with GALL Report recommendations and acceptable.
Operating Experience. LRA Section B.2.16 states that the Fuel Oil Chemistry Program is implemented and maintained in accordance with general requirements for the Environmental and Chemistry Sampling and Analysis Program for assurance that the Fuel Oil Chemistry Program effectively meets regulatory and procedural requirements, including periodic assessments and reviews of operating experience.
Plant condition reports, chemistry results since 2000 for available parameters, and the 10-year emergency diesel generator fuel oil storage tank liner inspection results demonstrate that the 3-104
 
Fuel Oil Chemistry Program is monitored critically and improving continually. These operating experience results prove that Fuel Oil Chemistry Program practices thus far have ensured the integrity of the subject components.
During the onsite audit, the staff reviewed the fuel oil chemistry data for the years 2000 through 2005 and confirmed that the parameters measured were at or below the limit of unacceptable levels. The data indicated no incident of water contamination in the fuel oil systems. A condition report explained limited data on the diesel-driven fire pump fuel oil tank, indicating inadvertent removal of a chemistry procedure step in testing for viscosity, sediment, and water content every 92 days. Fuel oil testing confirmed acceptable quality and HNP reinstated the missing step into the chemistry procedure.
Condition reports confirmed no failures in the fuel oil system attributed to contamination and the applicant's assertion of no recurrence of biological growth in the security diesel fuel oil tanks since switch to fuel oil Grade 1-D in the mid-1990s. One condition report documented a failure in the fuel oil system buried piping of the 10-year pressure test, indicating that, although not visually inspected, the apparent cause of the failure was exterior corrosion where the coating was defective or damaged in installation. Because of the inaccessible location of this piping, HNP abandoned it in place.
Finally, during the onsite audit, the staff reviewed the emergency diesel generator fuel oil tank inspections during RFO-7 and RFO-13. Inspections of the main fuel oil storage tank liners during RFO-7 revealed minor wall thickness differences from the ultrasonic measurements attributed to installation problems and not to corrosion or material degradation. There was very little ground-side corrosion detected in the bottom plates. These results were after 12 years of service and, except for some minor coating repair in Tank A, there were no signs of degradation on the inside or outside liner surfaces. During RFO-13, internal inspection and cleaning of the emergency diesel day Tank A noted the absence of pitting or general corrosion on the tank bottom. In addition, inspections of the main fuel oil storage tanks revealed an intact coating with no repairs necessary.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.16, the applicant provided the FSAR supplement for the Fuel Oil Chemistry Program. In a letter dated August 20, 2007, the applicant amended the FSAR description in the LRA to incorporate program description changes and the revision to Commitment No. 12 resulting from the staffs questions during the audit and review. The staff reviewed this section and determines that the information in the FSAR supplement, as amended, is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Fuel Oil Chemistry Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements (Commitment No. 12 as revised in the letter dated August 20, 2007) and confirmed that their implementation 3-105
 
prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.13 Reactor Vessel Surveillance Program Summary of Technical Information in the Application. LRA Section B.2.17 describes the existing Reactor Vessel Surveillance Program as consistent, with enhancements, with GALL AMP XI.M31, Reactor Vessel Surveillance.
The Reactor Vessel Surveillance Program manages the reduction of fracture toughness of the reactor vessel beltline materials due to neutron embrittlement to fulfill the intent and scope of 10 CFR 50, Appendix H. The program evaluates neutron embrittlement by projecting upper-shelf energy (USE) for all reactor materials with projected neutron exposure greater than 1017 n/cm2 (E>1.0 MeV) after 60 years of operation and with the development of pressure-temperature limit curves. Embrittlement information is obtained from RG 1.99, Revision 2, chemistry tables and from surveillance capsules, which have provided credible data during the current operating period and are expected to provide additional data for the period of extended operation.
The surveillance program design, the capsule withdrawal schedule, and the evaluation of test results are in accordance with ASTM E 185-82. As capsules are withdrawn from the reactor vessel, tested specimens are stored for future reconstitution if needed. The program manages the remaining capsules for withdrawal of one capsule when the capsule fluence is equivalent to the 60-year maximum vessel fluence. The two remaining capsules will be managed for optimal neutron exposure and meaningful metallurgical data if additional license renewals are sought.
The program manages the steps taken (e.g., the review and updating of 60-year fluence projections to support the preparation of new pressure-temperature limit curves and pressurized thermal shock reference temperature calculations) for altered reactor vessel exposure conditions.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it. The Reactor Vessel Surveillance Program, designed and implemented in accordance with 10 CFR Part 50, Appendix H, tests the reactor vessel surveillance capsule test specimens to monitor for neutron irradiation-induced embrittlement in base metals (plate or forgings) and welds in the beltline region of the low-alloy steel reactor vessel. The Reactor Vessel Surveillance Program has six surveillance capsules, each with mechanical test specimens, Charpy V-Notch specimens, dosimetry, and thermal monitors. The program monitors fracture toughness of beltline materials indirectly through measurement of the impact energy of Charpy V-Notch specimens. The program uses two sets of specimens, one made from representative limiting beltline material, Intermediate Shell Plate Heat Number B4197-2, 3-106
 
and the other from a non-limiting beltline circumferential weld (Intermediate Shell to Lower Shell Weld Heat Number 5P6771). To date, HNP has withdrawn and tested three surveillance capsules from the reactor vessel with the remaining three to be exposed to additional neutron flux as a source for future data to for management of neutron embrittlement for the period of extended operation.
In response to the request for additional information (RAI) B.2.17, the applicant confirmed by letter dated August 16, 2007, that one of the capsules (Capsule W) scheduled for withdrawal during RFO-16 would be exposed to a maximum neutron fluence equivalent to 55 effective full-power years of reactor vessel operation. Based on the analysis of the capsule withdrawn during RFO-16, the applicant intends to optimize the neutron exposure and withdrawal schedule for the remaining two capsules (standby capsules) to obtain meaningful metallurgical data. The applicant reiterated that it will adjust the withdrawal schedule for one of the standby capsules based on the analysis of the capsule W. To comply with paragraph 7.6.2 of ASTM E-185, the applicant stated, the projected neutron fluence for the next capsule to be withdrawn after RFO-16 will not exceed twice the 60-year maximum reactor vessel fluence. The applicant noted that if the capsules projected fluence value is excessive, HNP will either relocate it to where it will be exposed to a lower neutron flux or withdraw it for possible future testing or reinsertion.
One standby capsule will be available for monitoring of neutron exposure if HNP seeks additional license renewals. The applicants response to RAI B.2.17 by letter dated August 16, 2007, included the following statement consistent with the applicants Commitment 13, Item 1. The tested and untested specimens from all the capsules pulled from the reactor vessel must be kept in storage to permit future reconstitution use and HNP shall maintain the identity, traceability, and recovery of the capsule specimens throughout testing and storage; therefore, the applicant needs no additional commitment in the LRA.
The staff finds this response acceptable because future capsule testing will reasonably assure effective monitoring of neutron irradiation-induced embrittlement in the reactor vessel beltline materials as a result of any change in projected neutron fluence during the period of extended operation. The staff determined that the applicants response will be included in the safety evaluation as part of a standard licensing condition.
As to the applicants plan for the withdrawal of the reactor vessel surveillance capsules, in response to RAI B.2.17 the applicants letter dated August 16, 2007, stated that it will obtain staff approval when making any changes to the withdrawal schedule, The applicant stated that this response is consistent with the statements in Attachment 3 to the HNP procedure, Technical Specification Equipment List Program and Core Operating Limits Report. The staff finds this response acceptable provided the applicant includes this response in the LRA commitment table. This item is Confirmatory Item (CI) B.2.17.
After reviewing the applicants response to the staffs RAI B.2.17, the staff concludes that its concern described in RAI B.2.17 is resolved. The staff accepts the applicants Reactor Vessel Surveillance Program for the following reasons:
* the testing of the surveillance capsules in accordance with the proposed schedule reasonably assures adequate monitoring of neutron-induced embrittlement in low-alloy steel reactor vessel base metals and their welds during the period of extended operation 3-107
 
and
* the applicants Reactor Vessel Surveillance Program complies with 10 CFR Part 50, Appendix H. The staff confirmed that the applicants description of the operating experience program element satisfies criteria defined in the GALL Report and in SRP-LR Section A.1.2.3.10.
The staff finds this program element acceptable.
Operating Experience. LRA Section B.2.17 states that the Reactor Vessel Surveillance Program described in FSAR Section 5.3 has provided materials data and dosimetry for the monitoring of irradiation embrittlement since plant startup. The staff has approved use of program during the period of current operation. A review of NRC information notices, bulletins, and generic letters and the INPO operating experience database found no applicable operating experience with reactor vessel surveillance events since January 2005. Surveillance capsules have been withdrawn during the period of current operation, and the credible data from these surveillance capsules have verified and predicted reactor vessel beltline material performance as to neutron embrittlement. Calculations as required have projected the degree of USE reduction expected to result from future neutron exposure, including 60-year projections.
Pressure-temperature limits imposed on operational parameters assure vessel operation within required safety margins. Three capsules remain inside the reactor vessel exposed to additional neutron flux as a source for future data for management of neutron embrittlement aging effects for the period of extended operation.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.17, the applicant provided the FSAR supplement for the Reactor Vessel Surveillance Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Reactor Vessel Surveillance Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.14 Selective Leaching of Materials Program 3-108
 
Summary of Technical Information in the Application. LRA Section B.2.19 describes the new Selective Leaching of Materials Program as consistent, with exceptions, with GALL AMP XI.M33, Selective Leaching of Materials Program.
The Selective Leaching of Materials Program ensures the integrity of components and commodities (e.g., piping, pump casings, valve bodies and heat exchanger components) made of copper alloys with zinc content greater than 15 percent and gray cast iron exposed to raw water, treated water, lubricating oil or hydraulic fluid, fuel oil, wetted air/gas, or soil environments. A new inspection procedure will define one-time examination methodology and acceptance criteria. The program will be implemented by the work management process with a qualitative determination of selected components that may be susceptible to selective leaching.
Confirmation of selective leaching may be by metallurgical evaluation or other testing methods.
The examinations will determine whether loss of material due to selective leaching has occurred and whether the process will affect component ability to perform intended function(s) for the period of extended operation. A sample population will be selected for the inspections to be completed prior to the period of extended operation. Evidence of selective leaching will result in expanded sampling as appropriate and an engineering evaluation.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions to determine whether the AMP, with the exceptions, remained adequate to manage the aging effects for which the LRA credits it.
Exception. The LRA states the following exception to the GALL Report program elements scope of the program, parameters monitored or inspected, and detection of aging effects, specifically:
The exception involves the use of examinations, other than Brinell hardness testing identified in the GALL Report, to identify the presence of selective leaching. A qualitative determination of selective leaching will be used in lieu of Brinell hardness testing for components within the scope of this program. The exception is justified, because (1) Brinell hardness testing may not be feasible for most components due to form and configuration (i.e., heat exchanger tubes) and (2) other mechanical means, i.e., scraping or chipping, provide an equally valid method of identification.
In a letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 15) to implement the program with the exception to the stated program elements. During the audit and review, the staff discussed the exception with the applicant to clarify the use of qualitative methods of determination in lieu of Brinell hardness testing. The applicant stated that mechanical means (e.g., scraping or chipping) would be a valid method for selective leaching.
The staff finds this exception acceptable because these qualitative mechanistic techniques can detect selective leaching and are in use in addition to visual inspections as recommended by the GALL Report; therefore the program will address GALL Report recommendations and be consistent with the scope of the program, parameters monitored or inspected, and detection of aging effects program elements.
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Operating Experience. LRA Section B.2.19 states that operating experience to verify the effectiveness of the new Selective Leaching of Materials Program is not available. Plant-specific operating experience shows no occurrences of selective leaching of materials.
During the audit and review, the staff asked the applicant how it records operating experience.
The applicant indicated that the Corrective Action Program tracks and trends plant-specific operating experience for components managed by the Selective Leaching of Materials Program and documents any degraded or potentially unable to fulfill intended functions for evaluation by engineering personnel for extent of condition and appropriate follow-up actions. The evaluation would note adverse trends and include industry operating experience.
On the basis of its discussions with the applicants technical personnel, the staff finds that the applicant's Selective Leaching of Materials Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.19, the applicant provided the FSAR supplement for the Selective Leaching of Materials Program and, by letter dated August 20, 2007, Commitment No. 15 to implement the Selective Leaching of Materials Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 15, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Selective Leaching of Materials Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which the LRA credits it. The staff concludes that the applicant has demonstrated that, with Commitment No. 15, the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.15 One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program Summary of Technical Information in the Application. LRA Section B.2.21 describes the new One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program as consistent, with exceptions, with GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping.
The industry has experienced cracking of small-bore piping from thermal and mechanical loading and intergranular stress corrosion. Specific industry events include cracking caused by 3-110
 
fatigue due to thermal stratification resulting in the issuance of Bulletin 88-08, Thermal Stresses in Piping Connected to Reactor Coolant System (as supplemented). The ASME Code does not currently require volumetric examination of Class 1 small-bore piping; however, as stated in GALL Report Section XI.M35, the staff believes that the inspection of small-bore Class 1 piping (less than nominal pipe size (NPS) 4) should include volumetric examinations to detect cracking. The One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program will manage this aging effect by volumetric examinations except for small-bore socket-welds. In lieu of volumetric inspections of socket welds, the program will include one-time volumetric examinations of samples of Class 1 butt welds for pipe less than NPS 4. The One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program will manage cracking in small-bore piping (less than NPS 4) to maintain the system intended function and prevent loss of reactor coolant system pressure boundary through the period of extended operation. This program will be implemented and inspections completed and evaluated prior to the period of extended operation.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions to determine whether the AMP, with the exceptions, remained adequate to manage the aging effects for which the LRA credits it.
The staff interviewed the applicants technical personnel and reviewed the applicants license renewal basis documents for the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program, including the license renewal basis calculation assessing consistency of the program elements with the program element criteria recommended in GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. Specifically, the staff reviewed the program elements (documented in SER Section 3.0.2.1) in the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program license renewal basis calculation and its basis documents, as listed in the Audit Report, for whether the program elements are consistent with the programmatic criteria defined and recommended in the program elements of GALL AMP XI.M35.
From its review of the license renewal basis calculation, the staff verified that the specific One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program is a specific one-time inspection program for small-bore piping in reactor coolant pressure boundary and that the program credits one-time volumetric examinations of the ASME Code Class 1 small-bore piping to confirm whether cracking from either stress corrosion cracking or cyclical loading is an aging effect requiring augmented management (i.e., to confirm whether an augmented periodic inspection program is needed for small-bore piping during the period of extended operation).
The staff also verified that the program elements for the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program were consistent with the criteria recommended in the program elements of GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, with the following exception evaluated in the following paragraphs:
Exception. The LRA states that the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program includes the following exception to the detection of aging effects and monitoring and trending program elements of GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping:
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The HNP One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program will manage this aging effect through the use of volumetric examinations with the exception that volumetric examinations for small-bore socket-welds will not be done. The current state of technology provides no effective, reliable method of performing volumetric examinations of small-bore socket welds. In lieu of performing volumetric inspections of socket welds, the program will include one-time volumetric examinations of a sample of Class 1 butt welds for pipe less than NPS 4. The sample population for volumetric inspections will be at least 10 percent or will otherwise be based on a risk-informed inspection plan approved by the NRC. The volumetric inspections will be completed prior to the end of, and within the last five years of, the current operating period. In addition, the program will include controls to ensure the 100 percent of all ASME Class 1 socket welds NPS 2 and smaller receive a VT-2 visual inspection each refueling outage in accordance with the approved ASME Section XI ISI program. Any cracking identified in small-bore Class 1 piping determined to be attributable to stress corrosion or thermal and mechanical loading will result in periodic inspections.
The detection of aging effect program element of GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Piping, recommends a one-time volumetric inspection on a sample of the facilitys ASME Code Class 1 small bore piping welds for whether cracking is an AERM by an augmented periodic-inspection program for small-bore piping. The monitoring and trending program element of GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Piping, recommends a sample size for these one-time volumetric inspections based on component susceptibility, inspectability, dose, operating experience, and limiting location considerations.
During the audit, the staff asked the applicant to clarify its regulatory basis for one-time inspections of the ASME Code Class 1 small-bore socket welds and to justify its selections of sample size and components.
In its response dated August 20, 2007, the applicant stated:
ASME Section Xl currently requires a pressure test at the end of each refueling outage on all Class 1 socket welds. VT-2 visual examinations are performed at that time. Currently, Section Xl requires a surface examination of selected Class 1 socket welds. HNP will follow Section Xl and NRC requirements for socket welds during the period of extended operation.
Consistent with GALL, inspections will be performed at a sufficient number of locations to assure an adequate sample. The sample size for the plant-specific program will be based on susceptibility, inspectability, dose considerations, operating experience, and limiting locations of the total population of ASME Code Class 1 small bore piping locations. The sample prioritization will consider the potential for mechanical loading as a result of thermal stratification, piping potentially susceptible to IGSCC (normally stagnant piping), and locations identified for inspection under the RI-ISI program (which considers thermal loading from plant cycles and thermal stratification).
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The applicants license renewal basis calculation for the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program, as modified by the information in the applicants letter of August 20, 2007, indicates that the applicant uses the following bases for this program:
* The applicant will complete one-time volumetric examinations of a sample of ASME Code Class 1 small-bore pipe full-penetration butt welds prior to the period of extended operation. The applicants basis for volumetric examinations of the ASME Code Class 1 small-bore full penetration welds is consistent with the recommended criteria in the detection of aging effects program element of GALL AMP XI.M35 and acceptable.
* The applicant will complete the VT-2 visual examinations required by the ASME Code Section XI, Table IWB-2500-1, Examination Category B-P (every refueling outage), and the surface examinations required for ASME Code Class 1 small-bore socket welds in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-J, Inspection Item B9.40 (once every 10-year ISI interval), as the basis for inspection of the ASME Code Class 1 small-bore socket welds within the scope of this AMP. The visual examinations will detect system leakage from these components during each scheduled RFO. The surface examinations will detect surface-breaking flaws on the socket welds.
Based on this assessment, the staff concludes that this basis is acceptable because the applicants periodic surface examinations of ASME Code Class 1 small-bore socket welds will be in accordance with ASME Code Section XI and because these examinations will be sufficient to detect surface-breaking flaws in the socket welds prior to any component failure.
* The applicant will base the sample size for the one-time examinations of the small-bore full-penetration butt welds on susceptibility, inspectability, dose considerations, operating experience, and accessibility considerations. The applicants bases for selecting the sample size and the specific component locations for volumetric examination are consistent with the criteria recommended in the monitoring and trending program element of GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small Bore Piping. Based on this assessment the staff concludes that bases for selecting the sample size and components for inspection are consistent with the corresponding recommendations in GALL AMP XI.M35 and acceptable.
The staff also reviewed portions of the applicants One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program for which the applicant claimed consistency with GALL AMP XI.M35 and determined that they were consistent with the remaining program element criteria of GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping.
The staff also verified the applicants incorporation of its need to implement the One-Time Inspection of ASME Code Class 1 Small-bore Piping Program prior to the period of extended operation as LRA Commitment No. 17 docketed in the applicants letter of August 20, 2007.
On the basis of its review, the staff concludes that the applicants One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program is consistent with the recommended program elements in GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, with the exception that the applicant has an acceptable basis for using the required 3-113
 
examinations of the ASME Code Section XI for its ASME Code Class 1 small-bore socket welds during the period of extended operation. Based on this assessment, the staff concludes that the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program, with the applicants commitment to implement this program prior to the period of extended operation, provides assurance that either aging of small-bore ASME Code Class 1 piping has not occurred or is so insignificant that a periodic, inspection-based AMP is not warranted for these components.
Operating Experience. LRA Section B.2.21 states that this new AMP for the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program has no operating experience to verify its effectiveness. Any future operating experience which may impact the program will be reviewed through the normal screening process for applicability. This process will continue through the period of extended operation.
The staff reviewed the operating experience described in the LRA and interviewed the applicants technical personnel to confirm that plant-specific operating experience revealed no degradation not bounded by industry experience.
During the audit, the staff asked the applicant for plant-specific operating experience and the schedule for the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program.
In its response dated August 20, 2007, the applicant stated that there is no plant-specific operating experience for the new One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program and that this program will be implemented prior to the period of extended operation.
LRA Section B.2.21 also states that there is no operating experience to validate the effectiveness of this new One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program. The normal operating experience review process will screen for applicability and record any future operating experience which may impact the program. This process will continue through the period of extend operation. The LRA states in Commitment No. 17 that this program will be implemented prior to the period of extended operation.
On the basis of this review, the staff concludes that (1) the applicants One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program includes no operating experience with degradation of ASME Code Class 1 small-bore piping because this new program has not been implemented at the facility, (2) the applicants implementation of this program in Commitment No. 17 will assess and correct any recordable indications of age-related degradation in the ASME Code Class 1 small-bore piping adequately before returning the affected components to service, and (3) the applicant will evaluate the need for an augmented periodic-inspection program for small-bore piping if it detects any indications of age-related degradation in the small-bore piping while implementing this AMP.
FSAR Supplement. In LRA Section A.1.1.21, the applicant provided the FSAR supplement for the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
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The staff has verified that the applicant has reflected its need to implement the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program prior to the period of extended operation in LRA Commitment No. 17 docketed in the applicant's letter of dated August 20, 2007, and that this commitment refers to the FSAR supplement for the AMP in LRA Section A.1.1.21.
Based on this review, the staff concludes that the FSAR supplement for this AMP describes the program adequately and because an appropriate commitment in the LRA reflects the need to implement the program.
Conclusion. On the basis of its audit and review of the applicants One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which the LRA credits it. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.16 External Surfaces Monitoring Program Summary of Technical Information in the Application. LRA Section B.2.22 describes the existing External Surfaces Monitoring Program as consistent, with enhancements, with GALL AMP XI.M36, External Surfaces Monitoring.
The External Surfaces Monitoring Program based on system inspections and walkdowns consists of periodic visual inspections of components (e.g., piping, piping components, ducting) and other equipment within the scope of license renewal and subject to an AMR in order to manage aging effects. The External Surfaces Monitoring Program includes inspections and evaluations by engineering personnel and directs thorough and consistent inspection of SSCs by criteria that focus on detection of aging effects. The program manages aging effects through visual inspection of external surfaces. Loss of material due to boric acid corrosion is managed by the Boric Acid Corrosion Program. Surfaces inaccessible during plant operations are inspected during refueling outages. Surfaces inaccessible during both plant operations and refueling outages are inspected at frequencies for reasonable assurance of management of the effects of aging so components perform intended functions during the period of extended operation.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
The staff interviewed the applicants technical personnel and reviewed the applicants license 3-115
 
renewal basis calculation for the External Surfaces Monitoring Program assessing program consistency with GALL AMP XI.M36, External Surfaces Monitoring. Specifically, the staff reviewed the program elements (SER Section 3.0.2.1) of the External Surfaces Monitoring Program and its basis documents, as listed in the Audit Report, for consistency with program element criteria defined and recommended in GALL AMP XI.M36. The staff also reviewed the enhancements and the justifications for whether the AMP with the enhancements remains adequate to manage the aging effects for which the LRA credits it. From its review of the license renewal basis calculation and its basis documents, the staff determined that the applicant credits this program and visual examinations to manage loss of material from the external surfaces of steel components for which the AMP is credited subject to the following enhancements to make the program consistent with the program element criteria recommended in GALL AMP XI.M36, External Surfaces Monitoring. Based on this determination, the staff found the program elements for the External Surfaces Monitoring Program consistent with the program element criteria defined and recommended in GALL AMP XI.M36, External Surfaces Monitoring, subject to enhancements evaluated in the following paragraphs:
The LRA states that the External Surfaces Monitoring Program will be enhanced prior to the period of extended operation, as specified in Enhancements 1, 2, and 3:
Enhancement 1. The LRA states the scope of program program element for the External Surfaces Monitoring Program will be enhanced as follows:
A specific list of systems managed by the program will be added to the program document. Specific guidance will be provided for insulated/jacketed pipe and piping components to evaluate the integrity of the covering for signs of leakage and the environmental conditions (moist/wet) to determine whether insulation should be removed to inspect for corrosion.
The scope of program program element in GALL AMP XI.M36, External Surfaces Monitoring, recommends that the program visually inspect and monitor the external surfaces of steel components in systems within the scope of license renewal and subject to an AMR for loss of material and leakage. The staff noted that the scope of program program element for the Externals Surfaces Monitoring Program did not specify steel components within its scope; therefore, the staff concluded that it was necessary and appropriate for the applicant to enhance the scope of program program element to specify such components.
The staff verified the applicants incorporation of this enhancement as Items (1) and (2) of LRA Commitment No. 18 docketed in the applicants letter of August 20, 2007; thus, the staff concludes that this program enhancement will make the scope of program program element consistent with the corresponding program element of GALL AMP XI.M36, External Surfaces Monitoring, because the enhancement will update the program to specify components within its scope. Based on this conclusion the staff finds this program enhancement acceptable.
Enhancement 2.The LRA states the detection of aging effects program element for the External Surfaces Monitoring Program will be enhanced as follows:
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Components and structures of the system that are inaccessible or not readily visible during both plant operations and refueling outages are to be inspected at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
Specific guidance will be provided for visual inspections of elastomers for cracking, chafing, or changes in material properties due to wear.
The staff noted that the detection of aging effects program element for the Externals Surfaces Monitoring Program did not describe the applicants activities to manage loss of material in inaccessible components or define specific guidelines for visual inspection of elastomers for cracking, chaffing, or changes in material properties due to wear; therefore, the staff concluded that it was necessary and appropriate for the applicant to enhance the detection of aging effects program element of the External Surfaces Monitoring Program to describe these activities.
The staff verified the applicants incorporation of these enhancements as items (3) and (4) of LRA Commitment No. 18 docketed in the applicants letter of August 20, 2007. The enhancement will update the program to describe activities for components inaccessible or not readily accessible during plant operations and guidance for visual examinations of elastomeric components with the scope of the AMP. Thus, the staff concludes that these enhancements will make the detection of aging effects program element of the External Surfaces Monitoring Program consistent with the detection of aging effects program element criteria recommended in GALL AMP XI.M36, External Surfaces Monitoring.
Enhancement 3. The LRA states the acceptance criteria program element of the External Surfaces Monitoring Program will be enhanced as follows:
The program will incorporate a checklist for evaluating inspection findings, with qualified dispositions. The program will define when corrective action is required.
Unacceptable findings will have a condition report initiated and will be handled under the Corrective Action Program.
The acceptance criteria program element in GALL AMP XI.M36, External Surfaces Monitoring, recommends acceptance criteria defined for each component/aging effect combination monitored by the AMP to detect the need for corrective actions before loss of intended functions and design standards, procedural requirements, current licensing bases, industry codes or standards, and engineering evaluations as acceptable source documents for defining what such acceptance criteria should be. The staff noted that the acceptance criteria program element of the Externals Surfaces Monitoring Program did not define acceptance criteria specifically; therefore, the staff concluded that it was necessary and appropriate for the applicant to enhance the acceptance criteria program element to define acceptance criteria and to state that the program would take corrective actions if the acceptance criteria are exceeded.
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The staff verified the applicants incorporation of these enhancements as Item (5), as stated in LRA Commitment No. 18. Thus, the staff concludes that these enhancements will make the acceptance criteria program element for the External Surfaces Monitoring Program consistent with the detection of aging effects program element criteria recommended in GALL AMP XI.M36, External Surfaces Monitoring, because the enhancement will update the program specifically to define acceptance criteria for each component/aging effect combination for which the program monitors and to state that it would take corrective action if these acceptance criteria are exceeded.
On this basis of this review, the staff finds these enhancements acceptable because, when implemented, the External Surfaces Monitoring Program will be consistent with GALL AMP XI.M36 and will assure adequate management of the effects of aging. The staff also reviewed portions of the applicants External Surfaces Monitoring Program for which the applicant claimed consistency with GALL AMP XI.M36 and verified their consistency with program element criteria of GALL AMP XI.M36, External Surfaces Monitoring.
On the basis of its review, the staff concludes that the applicants External Surfaces Monitoring Program, as enhanced in Commitment No. 18, will make the program consistent with GALL AMP XI.M36, Externals Surfaces Monitoring, and that the program assures adequate management of aging effects during the period of extended operation.
Operating Experience. LRA Section B.2.22 states that system inspection requirements in effect have been effective in maintaining the material condition of plant systems with a significant number of corrective actions processed as results of system engineer walkdowns. The External Surfaces Monitoring Program will be re-assessed and upgraded based on industry and plant-specific operating experience.
The staff reviewed the operating experience described in the LRA and interviewed the applicants technical personnel to confirm that plant-specific operating experience is not bounded by industry operating experience. In addition, the staff finds that the corrective action program, which records plant-specific and industry operating experience, will review and incorporate future operating experience for objective evidence of adequate management of the effects of aging.
The staff asked the applicant for any plant-specific operating experience information for the External Surfaces Monitoring Program with emphasis on component condition when observed during system walkdowns or maintenance.
The staff reviewed two action requests for components within the scope of the Inspection of External Surfaces Monitoring Program: (1) one (dated March 12, 1997) for degradation detected in the Chilled Water System and (2) another (dated February 4, 2004) for corrosion detected in the traveling screen baskets of the emergency service water system. The staff determined that the applicants root cause analyses of the degradation described in these action reports and actions to repair or replace the impacted components prior to returning them to service had been appropriate. Based on this determination, the staff concluded that the applicant has taken appropriate action to correct any previous degradation detected in components within the scope of this AMP.
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The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.22, the applicant provided the FSAR supplement for the External Surfaces Monitoring Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
The staff confirmed that the applicant reflected its need to implement the Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program prior to the period of extended operation in LRA Commitment No. 18. This commitment refers to the FSAR supplement section for the AMP in LRA Section A.1.1.22. Based on this review, the staff concludes that the FSAR supplement for this AMP is acceptable because it describes the program adequately and because an appropriate commitment in the LRA reflects the need to implement the program.
Conclusion. On the basis of its audit and review of the applicants External Surfaces Monitoring Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.17 Flux Thimble Tube Inspection Program Summary of Technical Information in the Application. LRA Section B.2.23 describes the existing Flux Thimble Tube Inspection Program as consistent, with enhancements, with GALL AMP XI.M37, Flux Thimble Tube Inspection Program.
The Flux Thimble Tube Inspection Program monitors for thinning of the flux thimble tube wall, which provides a path for the incore neutron flux monitoring system detectors and forms part of the RCS pressure boundary. Flux thimble tubes are subject to loss of material at certain locations in the reactor vessel where flow-induced fretting causes wear at discontinuities in the path from the reactor vessel instrument nozzle to the fuel assembly instrument guide tube.
Industry experience with thimble tube thinning led to issuance of Bulletin 88-09, Thimble Tube Thinning in Westinghouse Reactors. In response to the NRC Bulletin, HNP has established a Flux Thimble Tube Inspection Program to monitor for thinning of the flux thimble tube walls. The program uses eddy current testing to monitor for wear. Plant-specific test results are evaluated to determine the wear rate by the methodology outlined in Westinghouse Commercial Atomic Power (WCAP)-12866, Bottom Mounted Instrumentation Flux Thimble Wear. With the wear rate established, wear predictions are calculated by the WCAP-12866 methodology. The applicant then uses wear predictions to determine an adequate inspection frequency. The 3-119
 
acceptance criteria for finding unacceptable flux thimbles include an allowance to account for instrument inaccuracies.
The Flux Thimble Tube Inspection Program manages loss of material due to wear to maintain system intended function to prevent loss of reactor coolant system pressure boundary through the period of extended operation.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
Enhancement 1.The LRA states the following enhancements to the GALL Report program element monitoring and trending, specifically:
Subsequent to each inspection, the latest test results will be evaluated against the historical test results in order to determine a plant-specific value for n (wear curve exponent). If the generic value of 0.67 is used for n, a basis must be provided for using the generic value in lieu of plant-specific data.
During the audit and review, the staff noted that use of a generic wear curve exponent is inconsistent with the GALL Report because a basis is needed for use of the generic value in lieu of plant-specific data. The staff asked the applicant to explain its use of the generic value.
In the same August 20, 2007 letter, the applicant proposed to amend the monitoring and trending program element in Enhancement 1 in LRA Section B.2.23 to delete the use of the generic value of 0.67 as n.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 19) to enhance the program to require an evaluation of historic plant-specific test data to ensure use of conservative wear rates. The staff finds this commitment acceptable, along with the proposed LRA supplement that restricts use of the generic wear rate without a basis, because the enhanced program implementing procedures will follow the recommendations and be consistent with the monitoring and trending program element of the GALL Report.
Enhancement 2. The LRA states the following enhancements to the GALL Report program element monitoring and trending, specifically:
The program engineer may deem it unnecessary to perform a 100 percent inspection of all uncapped flux thimbles during each scheduled inspection. Such a decision may be due to thimbles that have been recently replaced or thimbles that are in locations with historically low wear rates. Since plant-specific test data is necessary to determine wear rates used to predict future wear, the program procedure is to be revised to require an evaluation and basis for each flux thimble not inspected.
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The applicant proposed a commitment (Commitment No. 19) to enhance the program implementing procedure to authorize the program engineer to determine which uncapped thimbles recently replaced or located in positions with historically low wear rates would need no inspection if review of plant-specific data and an evaluation document the basis for no inspection. This commitment is consistent with the methodology of WCAP-12866. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the monitoring and trending program element of the GALL Report.
Enhancement 3. The LRA states the following enhancements to the GALL Report program element monitoring and trending, specifically:
Plant-specific test data should be used to validate the wear curve exponent. The program procedure is to be revised to require an assessment of actual test results to determine if the assumed wear rate is conservative. This includes a comparison of the actual test results with the predicted wear.
The applicant proposed a commitment (Commitment No. 19) to enhance the program implementing procedure to require an assessment of actual test results for whether the assumed wear rate is conservative. This commitment is consistent with the methodology of WCAP-12866. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the monitoring and trending program element.
Enhancement 4. The LRA states the following enhancements to the GALL Report program element acceptance criteria, specifically:
The procedure governing the program does not directly address the requirements for test results showing an actual wear depth of greater than 70 percent. However, it requires replacement or isolation of any thimble not meeting the acceptance criteria. Therefore, the procedure indirectly requires any thimble with over 70 percent wear to be replaced or isolated. In order to clarify this requirement, the acceptance criteria of the procedure should be changed to require replacement or capping for any thimble with actual wear greater than 70 percent (instead of 80 percent).
The applicant proposed a commitment (Commitment No. 19) to enhance the program implementing procedure to require replacement or capping of any thimble with actual wear greater than 70 percent (instead of 80 percent). This commitment is consistent with the methodology of WCAP-12866. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the acceptance criteria program element.
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Enhancement 5. The LRA states the following enhancements to the GALL Report program element "acceptance criteria," specifically:
The program procedure currently states that thimbles which have a predicted wear of less than 70 percent are acceptable for another fuel cycle operation.
This suggests that evaluation may only consider inspection frequencies of one fuel cycle (18 months). This requirement should be re-worded to state that thimbles meeting this criterion are acceptable until the next scheduled inspection.
The applicant proposed a commitment (Commitment No. 19) to enhance the program implementing procedure to specify that thimbles with predicted wear of less than 70 percent are acceptable until the next scheduled inspection instead of another complete fuel cycle operation.
This commitment is consistent with the methodology of WCAP-12866. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the acceptance criteria program element.
Enhancement 6. The LRA states the following enhancements to the GALL Report program element corrective actions, specifically:
Add a requirement to provide a disposition and basis for thimbles that could not be inspected due to restriction, defect or other reason. Thimbles which cannot be shown by analysis to be satisfactory for continued service must be removed from service and replaced or capped to ensure the integrity of the reactor coolant system pressure boundary.
The applicant proposed a commitment (Commitment No. 19) to enhance the program implementing procedure with a disposition and basis for thimbles that cannot be inspected due to restriction, defect, or other reason. This commitment is consistent with the methodology of WCAP-12866. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the corrective actions program element.
Enhancement 7. The LRA states the following enhancements to the GALL Report program element "corrective actions," specifically:
Add a requirement for test results and evaluations of test results to be sent to Document Services to be filed as QA records.
The applicant proposed a commitment (Commitment No. 19) to enhance the program implementing procedure to retain test results and their evaluations as QA records. This commitment is consistent with the methodology of WCAP-12866. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the corrective actions program element.
Operating Experience. LRA Section B.2.23 states that industry experience with thimble tube 3-122
 
thinning was initially communicated from the staff by Information Notice 87-44, Thimble Tube Thinning in Westinghouse Reactors (as supplemented), and Bulletin 88-09.
As stated in Bulletin 88-09 and in GALL Report Section XI.M37, the only effective method for determining thimble tube integrity is through inspections which are adjusted to account for plant-specific wear patterns and history; therefore, the Flux Thimble Tube Inspection Program focuses on plant-specific wear data rather than industry data.
The Flux Thimble Inspection program does not rely on preventive measures to manage the effects of wear. Wear is expected to occur and managed by monitoring and acting to prevent loss of the reactor coolant system pressure boundary. As results of flux thimble inspections, several thimbles have been replaced. A staff search of corrective action items and discussion with the program engineer found no history of through-wall leaks of flux thimbles at HNP.
During the audit and review, the staff reviewed the results from the most recent flux thimble inspections and their evaluations. The inspection results indicated no actual flux thimble tube wear outside of predicted values.
On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff finds that the applicants Flux Thimble Inspection Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.23, the applicant provided the FSAR supplement for the Flux Thimble Tube Inspection Program. By letter dated August 20, 2007, the applicant proposed Commitment No. 19 to enhance the Flux Thimble Tube Inspection Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 19, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Flux Thimble Tube Inspection Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation through Commitment No. 19 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
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3.0.3.2.18 Lubricating Oil Analysis Program Summary of Technical Information in the Application. LRA Section B.2.25 describes the existing Lubricating Oil Analysis Program as consistent, with enhancement, with GALL AMP XI.M39, Lubricating Oil Analysis.
The purpose of the Lubricating Oil Analysis Program is to maintain the oil environment in mechanical systems to the required quality. The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to loss of material, cracking, or reduction of heat transfer.
Lubricating oil testing includes sampling and analysis for detrimental contaminants.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancement to determine whether the AMP, with the enhancement, remained adequate to manage the aging effects for which the LRA credits it.
Enhancement 1. The LRA states the following enhancements to the GALL Report program element parameters monitored or inspected, specifically:
Ensure by revising program control and implementing documents as needed that used oil from appropriate component types listed within the scope of license renewal are analyzed to determine particle count and moisture, and if oil is not changed in accordance with the component manufacturers recommendation, then additional analyses for viscosity, neutralization number, and flash point will be performed. During oil changes, used oil is drained and visually checked for water. This is done to detect evidence of abnormal wear rates, contamination by moisture, or corrosion.
During the audit and review, the staff reviewed the preventive maintenance procedures that implement the Lubricating Oil Analysis Program and confirmed that they require only a visual check for water at the time of sampling and no checks of diesel lubricating oils for particle count, moisture, and neutrality. This enhancement will require the GALL Report recommended testing for particle count and moisture for lubricating oils in components within the scope of license renewal and additional analyses for viscosity, neutralization and flash point for oil not changed in accordance with the manufacturers recommendation. Finally, during oil changes, the used oil will be checked visually for water.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 21) to implement this enhancement prior to the period of extended operation. Based on the review of this commitment, the staff finds this enhancement acceptable because with Commitment No. 21, the Lubricating Oil Analysis Program will be consistent with the GALL Report recommendations for the parameters monitored or inspected program element.
Enhancement 2. The LRA states the following enhancements to the GALL Report program element "parameters monitored or inspected," specifically:
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Program procedures will be enhanced to include a requirement to perform ferrography or elemental analysis to identify wear particles or products of corrosion when particle count exceeds an established level or when considered appropriate.
During the audit and review, the staff confirmed that analytical ferrography proceeded only when deemed appropriate by the maintenance specialist or after an unusual spike in particle count. This enhancement will require this analysis whenever the particle count exceeds an established limit or whenever deemed appropriate by the specialist.
By letter dated August 20, 2007, the applicant proposed Commitment No. 21 to implement this enhancement prior to the period of extended operation. The staff finds this enhancement acceptable because, with Commitment No. 21, the Lubricating Oil Analysis Program will be consistent with the GALL Report recommendations for the parameters monitored or inspected program element.
During the audit and review, the staff reviewed the current preventive maintenance procedures and confirmed periodic sampling of the lubricating oil and adoption of acceptance criteria from industry or manufacturer recommendations. The staff also confirmed comparison of the data to limits established by manufacturer and baseline values for each component. Specialists review and trend results communicate recommendations for appropriate actions to responsible system engineers.
Operating Experience. LRA Section B.2.25 states that operating history over a 10-year period and operating experience data between 1999 and 2005 showed no failures attributed to lubricating oil contamination. The Lubricating Oil Analysis Program has managed aging effects for components wetted by lubricating oil effectively and has been improved through evaluation of plant-specific and industry operating experience.
During the audit and review, the staff reviewed selected action request corrective action program documents and confirmed that the existing program had detected lubricating oil problems in various components and taken appropriate actions. In all cases, there were no component failures attributed to aging effects. In addition, during the audit and review, the staff reviewed a sample of equipment assessment entries in the plant database from 9/23/2002 to 5/15/2006. The sample assessed lubricating oil contamination events, pressure boundary failures due to corrosion, reductions in heat transfer due to lubricating oil side fouling, or component failures attributed to contamination or changes in lubricating oil properties. This information, the result of either periodic oil sample analyses or oil samples taken as diagnostic tools for anomalous equipment vibration levels, indicated that the program detected oil contamination issues and took appropriate actions to prevent equipment failures. The staff noted that the data showed no failures attributed to lubricating oil issues.
Finally, the staff reviewed a self-assessment report developed by HNP personnel after a benchmarking visit to Palo Verde Nuclear Generating Station and an industry oil analysis training course. The lubricating oil program engineer concluded that there were some gaps in the Lubricating Oil Analysis Program as to current industry practice. The self-assessment established action items to address these gaps, five weaknesses and one item for management 3-125
 
attention, although the program was effective and had good practices. HNP initiated a series of corrective actions to correct the weaknesses and to address the item for management attention. The staff concluded from this self-assessment and the corrective actions that the Lubricating Oil Analysis Program was effective but strengthened by the industry input.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.25, the applicant provided the FSAR supplement for the Lubricating Oil Analysis Program. The staff reviewed this section and determines that the information in the FSAR supplement, with Commitment No. 21, is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Lubricating Oil Analysis Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancement and confirmed that its implementation (Commitment No. 21) prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.19 ASME Section XI, Subsection IWE Program Summary of Technical Information in the Application. LRA Section B.2.26 describes the existing ASME Section XI, Subsection IWE Program as consistent, with exception and enhancements, with GALL AMP XI.S1, ASME Section XI, Subsection IWE.
The ASME Section XI, Subsection IWE Program periodically inspects Class MC components of the containment structure. The program is in accordance with the ASME Code, Section XI, Subsection IWE, 1992 Edition, with the 1992 Addenda, as modified by 10CFR50.55a. The ASME Section XI, Subsection IWE Program is credited for the aging management of:
* the metallic liner (including attachments) for the concrete containment
* the penetration sleeves including the personnel airlock, emergency airlock, and equipment hatch
* pressure-retaining bolted connections within the boundary of the concrete containment vessel
* seals, gaskets, and moisture barriers.
The primary inspection method for the ASME Section XI, Subsection IWE Program is periodic visual examination along with limited volumetric examinations utilizing ultrasonic thickness measurements as needed.
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Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exception and enhancements to determine whether the AMP, with the exception and enhancements, remained adequate to manage the aging effects for which the LRA credits it.
Exception. The LRA states an exception to the GALL Report program element scope of the program, specifically:
GALL AMP XI.S1 describes the ASME Section XI Subsection IWE Program as conforming to the requirements of ASME Section XI Subsection IWE, 2001 Edition including the 2002 and 2003 Addenda. The current HNP ASME Section XI, Subsection IWE program plan for the first ten-year inspection interval defined from September 9, 1998 to September 8, 2008, approved per 10 CFR 50.55a, is based on ASME Section XI Subsection IWE, 1992 Edition with 1992 Addenda. The difference between the HNP Code of record and the Code edition specified in the GALL Report is considered to be an exception to the GALL Report criteria.
During the audit and review, the staff noted that in the license renewal basis calculation the following statement of the exception to the AMP scope of the program program element:
In conformance with 10 CFR 50.55a(g)(4)(ii), the ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition and addenda of the Code specified 12 months before the start of the inspection interval.
LRA page B-76 describing the exception to the scope of the program element for the ASME Section XI, Subsection IWE Program omits this statement. The staff asked the applicant to explain this omission from the LRA.
By letter dated August 20, 2007, the applicant stated that by oversight it inadvertently had not repeated in the LRA the 10 CFR 50.55a requirement to update the ISI program during each successive 120-month inspection interval to comply with the latest code edition and addenda 12 months before the start of the next inspection interval, This update required by NRC regulation applies to the ASME Section XI, Subsection IWE Program. On the basis of this response, an LRA amendment will incorporate this requirement.
In the same August 20, 2007, letter, the applicant proposed to amend the LRA Section B.2.26 scope of the program program element to add the 10 CFR 50.55a requirement statement.
The staff found the applicants response acceptable because it explained that the license renewal basis calculation statement was left out of the LRA by oversight.
GALL AMP XI.S1, ASME Section XI, Subsection IWE, specifies the ASME Section XI Subsection IWE, 2001 Edition including 2002 and 2003 Addenda as the code edition with which license renewal applicants must comply to be consistent with the GALL Report. The ASME 3-127
 
Section XI, Subsection IWE Program complies with the ASME Section XI Subsection IWE, 1992 Edition with 1992 Addenda. Although there are differences between code editions, the program complies with a Section XI edition approved per 10 CFR 50.55a for use at the time of implementation. Implementation to this earlier code edition meets the intent of the GALL Report.
The staff found the exception acceptable because the edition of record is an ASME Code version earlier than that specified by the GALL Report. The use of the 1992 Edition with 1992 Addenda was acceptable per 10 CFR 50.55a at the time of its implementation. As stated in the applicants response to the staffs question, the ISI program during each successive 120-month inspection interval will be updated to comply with the latest code edition and addenda specified per 10 CFR 50.55a 12 months before the start of the inspection interval. When HNP enters the period of extended operation, the ASME Code edition specified in 10 CFR 50.55a will be different from the ASME Section XI Subsection IWE, 2001 Edition with 2002 and 2003 Addenda specified in the GALL Report.
Enhancement 1. The LRA states the following enhancements in meeting the GALL Report program elements parameters monitored or inspected and acceptance criteria, specifically:
Revise administrative controls to include discoloration, surface discontinuities and other signs of surface irregularities as recordable conditions for coated and uncoated surfaces.
During the audit and review, the staff noted that a specific procedure for ASME Section XI Subsection IWE general visual inspections implements the existing ASME Section XI, Subsection IWE Program; however, the procedure does not address discoloration, surface discontinuities, and other signs of surface irregularities as recordable conditions. A form in the procedure used by NDE examiners does include these aging effects as adverse conditions to be detected; however, the applicant will revise the procedure to include them as recordable conditions.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 22, item No. 1) to enhance program implementing procedures to include additional recordable conditions. The staff finds this commitment acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the parameters monitored or inspected and acceptance criteria program elements.
Enhancement 2. The LRA states the following enhancements in meeting the GALL Report program elements "parameters monitored or inspected" and "acceptance criteria," specifically:
Revise administrative controls to include moisture barriers and parameters identified by Table IWE-2500-1 for Category E-D for aging effects of wear, damage, erosion, tear, surface cracks, or other defects that may violate the leak-tight integrity.
The staff also noted that the same plant-specific procedure for ASME Section XI 3-128
 
Subsection IWE general visual inspections does not address seals, gaskets, and moisture barriers and parameters specified by the GALL Report for Category E-D for aging effects wear, damage, erosion, tear, surface cracks, or other defects that may violate leak-tight integrity; however, another plant-specific procedure addressing IWE and IWL inspections implements the existing ASME Section XI, Subsection IWE Program. This procedure states in its appendices that visual examination per Category E-D is required. The applicant will revise the plant-specific procedure for ASME Section XI Subsection IWE general visual inspections to include moisture barriers and parameters shown by Table IWE-2500-1 for Category E-D for aging effects of wear, damage, erosion, tear, surface cracks, or other defects that may violate leak-tight integrity.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 22, item No. 2) to enhance program implementing procedures to include moisture barriers and their aging effects. The staff finds this commitment acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the parameters monitored or inspected and acceptance criteria program elements.
Enhancement 3. The LRA states the following enhancements in meeting the GALL Report program elements "parameters monitored or inspected" and "acceptance criteria," specifically:
Revise administrative controls to include pressure retaining bolting parameters identified by Table IWE-2500-1 for Category E-G for visual inspection and bolt torque or tension test.
The staff noted also that the plant-specific procedure for ASME Section XI Subsection IWE general visual inspections does not address pressure-retaining bolting and parameters specified by the GALL Report for Category E-G for visual inspection and bolt torque or tension tests. Another plant-specific procedure addressing IWE and IWL inspections states in its appendices that visual examination per Category E-G is required. The applicant will revise the plant-specific procedure for ASME Section XI Subsection IWE general visual inspections to include pressure-retaining bolting parameters shown in Table IWE-2500-1 for Category E-G for visual inspection and bolt torque or tension tests or ASME Code Case N-604.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 22, item No. 3) to enhance program implementing procedures to include pressure-retaining bolting and their aging effects. The staff finds this commitment acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the parameters monitored or inspected and acceptance criteria program elements.
Enhancement 4. The LRA states the following enhancements in meeting the GALL Report program elements "parameters monitored or inspected" and "acceptance criteria," specifically:
Revise administrative controls to discuss augmented examinations per IWE-1240 and inspections identified by Table IWE-2500-1 for Category E-C.
The staff noted also that the plant-specific procedure for ASME Section XI Subsection IWE 3-129
 
general visual inspections does not address Examination Category E-C, Containment Surfaces Requiring Augmented Examination; however, another plant-specific procedure addressing IWE and IWL inspections and visual and volumetric examination methods for minimum wall thickness includes augmented inspection evaluations. the applicant will revise the plant-specific procedure for ASME Section XI Subsection IWE general visual inspections to include augmented examinations per IWE-1240 and inspections shown in Table IWE-2500-1 for Category E-C.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 22, item No. 4) to enhance the program implementing procedures to include augmented examinations. The staff finds this commitment acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the parameters monitored or inspected and acceptance criteria program elements.
During the audit and review, the staff asked the applicant why the program enhancements need to address surface irregularities, moisture barriers, pressure-retaining bolting, and augmented examinations if the program has been in compliance with ASME Code Section XI, Subsection IWE since the NRC final rulemaking in 1996 to require IWE inspections and how the current IWE program addresses or inspects these four items.
By letter dated August 20, 2007, the applicant stated that the administrative engineering surveillance test procedure for ASME Code Section XI, Subsection IWE general visual examination does not address surface irregularities (for metallic surfaces without coatings),
moisture barriers, pressure-retaining bolting, and augmented examinations specifically but that the first containment inspection interval program document and specific QA inspection documents include these items. The enhancement only improves the administrative procedure by including in one administrative procedure instructions for all IWE inspection requirements.
The program has complied with ASME Code Section XI, Subsection IWE since the NRC final rulemaking in 1996 to require IWE inspections. The first Subsection IWE containment inspection interval is from September 9, 1998, to September 8, 2008 as described in the HNP containment inspection program.
The program addresses the four items as follows:
Surface irregularities - The administrative engineering surveillance test procedure for the ASME Section XI, Subsection IWE Category E-A, containment surfaces inspections does not currently list surface irregularities as a specific recordable condition. However, gouges, dents, bulges, and other damage, deformation, or degradation are listed as recordable conditions in the HNP administrative engineering surveillance test procedure and envelopes surface irregularities. The enhancement adds the specific term of surface irregularities to the HNP administrative engineering surveillance test procedure. It should also be noted that a QA visual examination form is utilized for inspection of various MC surfaces and it does include surface irregularities as a specific recordable condition.
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Moisture barriers - The inspections of the Category E-D, moisture barrier is performed using a QA visual examination form with the appropriate inspection attributes (wear, damage, erosion, tear, cracks, or other defects). The completed QA visual examination form for the moisture barrier inspections is attached to the administrative engineering surveillance test procedure for the ASME Section XI, Subsection IWE Program as a QA record.
Pressure retaining bolting - The inspections of the Category E-G, Pressure Retaining Bolting is performed using the first containment inspection interval containment inspection program document and a QA visual examination form.
Augmented examinations - An evaluation of the potential Category E-C, Containment Surfaces requiring augmented examination are included as an Appendix to the first containment inspection interval containment inspection program document. However no areas have been identified as surface areas requiring augmented examination.
The staff finds the applicants response acceptable. The applicant has demonstrated that all the required and proper inspections have been in accordance with Subsection IWE and that the enhancement only improves an administrative procedure by including in it instructions for all Subsection IWE inspection requirements.
On this basis, the staff finds all enhancements acceptable because, when implemented, the ASME Section XI, Subsection IWE Program will be consistent with GALL AMP XI.S1 and will assure adequate management of the effects of aging.
During the audit and review, the staff noted that LRA Appendix B has no Protective Coating Monitoring and Maintenance Program section and asked the applicant to explain how HNP meets the intent of GL 98-04, Generic Safety Issue (GSI) 191, and GL 2004-02.
By letter dated August 20, 2007, the applicant stated that actions taken for GL 98-04, GSI 191, and GL 2004-02 are parts of the CLB and that some remain ongoing.
The NRC issued GL 98-04:
* to alert addressees that findings of foreign material inside operating nuclear power plant containments continue
* to alert addressees to problems with the material condition of Service Level 1 protective coatings inside the containment
* to request information to evaluate addressee programs to ensure that Service Level 1 protective coatings inside containment do not detach from their substrate during a design-basis loss-of-coolant accident and interfere with emergency core cooling system and safety-related containment spray system operations.
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The applicants November 9, 1998, response to GL 98-04 provided the requested information and the NRC closed out this issue by correspondence dated November 16, 1999.
As stated in GL 2004-024, BWR research findings indicated that fibrous material plus particulate material could result in a head loss substantially greater than that which an equivalent amount of either type of debris could alone. These research findings prompted the NRC to open GSI-191, Assessment of Debris Accumulation on PWR Sump Performance. The objective of GSI-191 is that post-accident debris blockage not impede or prevent the operation of the emergency core cooling system and containment spray system in recirculation mode at PWRs during loss-of-coolant or other high-energy line break accidents for which sump recirculation is required.
In resolution of these issues, GL 2004-02 requested from addressees the following actions:
* By an NRC-approved methodology, a mechanistic evaluation of potential adverse effects of post-accident debris blockage
* Plant modifications indicated by the mechanistic evaluation as necessary for system functionality GL 2004-02 requested from addressees the following information within 90 days of the safety evaluation report with guidance for the requested evaluation:
* Planned actions and a schedule for completion of the requested evaluation of adverse effects of post-accident debris blockage
* A statement of intent to include a containment walkdown surveillance in support of the evaluation of susceptibility to the adverse effects of post-accident debris blockage The applicant provided this information by correspondence dated March 4, 2005.
GL 2004-02 further requested from addressees the following information by September 1, 2005:
* Confirmation that the emergency core cooling system and containment spray system recirculation functions under debris loading conditions are or will be in compliance with regulatory requirements listed in GL 2004-02
* A general description of and implementation schedule for all corrective actions, including any plant modifications
* A description of the methodology for the evaluation for the adverse effects of post-accident debris blockage
* A general description of and planned schedule for any changes to plant licensing bases 3-132
 
resulting from any evaluation or plant modification
* A description of existing or planned programmatic controls to assess potential sources of debris introduced into containment for adverse effects of post-accident debris blockage.
The applicant provided this information by correspondence dated September 1, 2005; furthermore, the September 1, 2005, letter makes the following commitment:
Complete the corrective actions of this response letter (HNP-05-101) to Generic Letter (GL) 2004-02 by the GL requested due date of December 31, 2007.
As noted, activities under GL 98-04, GSI 191, and GL 2004-02 are parts of the CLB. The applicant committed to completion by December 31, 2007, of corrective actions described in correspondence dated September 1, 2005.
The staff finds the applicants response acceptable. The NRC accepted HNPs response to GL 98-04 in a letter dated November 16, 1999. The NRC found that HNP maintained an effective qualified coatings program in the containment. GALL AMP XI.S8, Protective Coating Monitoring and Maintenance Program, states:
A comparable program for monitoring and maintaining protective coatings inside containment, developed in accordance with RG 1.54, Rev. 0 or the American National Standards Institute (ANSI) standards (since withdrawn) referenced in RG 1.54, Rev. 0, and coatings maintenance programs described in license responses to GL 98-04, is also acceptable as an AMP for license renewal.
The staff reviewed the HNP response to GL 98-04 that its qualified coatings program in the containment is subject to RG 1.54 and ANSI standards and determined that the coatings maintenance program described in the response 98-04 is acceptable as an AMP for license renewal with no additional AMP required for consistency with the GALL AMP XI.S8, Protective Coating Monitoring and Maintenance Program.
Operating Experience. LRA Section B.2.26 states that the ASME Section XI, Subsection IWE Program is implemented and maintained in accordance with general requirements for engineering programs for assurance that the program effectively meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have authority and responsibility to implement the program and to commit adequate resources to program activities.
Plant-specific operating experience shows numerous assessments, both plant-specific and corporate, of program development, effectiveness, and implementation. The ASME Section XI, Subsection IWE Program is upgraded continually based upon industry and plant-specific experience. Additionally, plant-specific operating experiences are exchanged among CP&L sites through regular peer group meetings, a common corporate sponsor, and outage participation of site program managers.
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During the audit and review, the staff noted that LRA Section B.2.26 lists no actual containment Subsection IWE ISI findings under operating experience. The staff asked the applicant to document from discovery to resolution any historical containment IWE ISI findings.
By letter dated August 20, 2007, the applicant stated it had documented a detailed operating experience review in the license renewal basis calculation for the ASME Section XI, Subsection IWE Program available for review at HNP as are specific examination reports. The following summarizes the findings.
The containment inspection program document for the first containment inspection interval presents an historical record of containment inspections prior to implementation of the ASME Section XI, Subsection IWE Program:
HNP detected vertical liner corrosion between the base slab and liner in RFO-7 (1997). HNP engineering determined that the liner thickness met design requirements and that moisture barrier deterioration was the root cause. HNP removed the entire moisture barrier during RFO-8 (1998), cleaned the liner, confirmed the thickness to meet design requirements, coated it, and installed a high-density silicone seal moisture barrier. HNP examined the vertical and horizontal liner at the base slab during RFO-8 and RFO-9 and found only minor corrosion with no further actions required. Examination of the liner plate below the top of the base slab in RFO-7 after removal of the moisture barrier found only minor corrosion. Examination of a sample section of liner under the sump topping slab also found no corrosion. There was corrosion of the exterior surface of the A containment spray valve chamber due to persistent groundwater intrusion found in 1993 but only minor corrosion recorded and UT followed.
Docketed Letter HNP-00-122, Inservice Inspection Summary Report, to the USNRC from James Scarola, dated October 18, 2000, documents Subsection IWE inspections in RFO-9 (completed 05/12/00). The responsible engineer and the program manager observed some recordable indications (coating blisters, mechanical damage to coatings, and discolored coatings on the liner) but determined them to be irrelevant. There was no significant metal loss in the areas but some rust and pitting inside the A containment spray valve chamber. The metal thickness, however, was above nominal thickness as determined by UT. The liner under the transfer canal was bulged but found acceptable by HNP engineering with no further action needed. Examination of the containment liner and penetrations, moisture barrier, penetrations gaskets, and penetration bolting was complete.
Docketed Letter HNP-05-018, Inservice Inspection Summary Report to USNRC from DH Corlett, dated February 15, 2005, documents Subsection IWE inspections in RFO-12 (completed 11/15/04). There were no recordable conditions on the containment liner from the moisture barrier to the center of the dome, a number of nonrecordable conditions (scattered mechanical damage, blisters with no resulting material loss, and small areas with flaking coatings) on the containment liner, and a recordable indication (blistering) on the protective coating inside the lower regions of each of the valve chambers. UT found no significant material reduction and the surfaces were recoated. Examination of the containment liner and penetrations, moisture barrier, valve chamber internals and bolting, equipment hatch, the refueling access sleeve was complete.
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Docketed Letter HNP-06-081, 90 day Inservice Inspection (ISI) Summary Report To USNRC from DH Corlett, dated August 10, 2006, documents Subsection IWE inspections in RFO-13 (completed 05/16/06). The report states that no examinations of ASME Class MC components were required or scheduled but, as prudent measures, examinations of the moisture barrier and approximately 12 up from the moisture barrier on the liner observed no recordable indications.
The report also states a visual inspection inside the A containment spray valve chamber including the bolts and nuts on the manway observed no recordable conditions. In addition to the report, a visual examination inside the three remaining valve chambers observed no recordable conditions. HNP repaired One small damaged coating area in the A containment spray valve chamber.
The staff finds the applicants response acceptable. Plant-specific operating experience shows that the ASME Section XI, Subsection IWE Program has been effective in managing aging of components for which the LRA credits it.
During the audit and review, the staff reviewed the operating experience documented in the license renewal basis calculation for the ASME Section XI, Subsection IWE Program and a 2005 HNP corporate Nuclear Assessment Section assessment of the ISI programs. The assessment stated that the ISI programs effectively fulfill their requirements but reported three weaknesses and one management concern. Two weaknesses were in the IWE program. The first was that the ISI pressure test and repair replacement program documentation and backlog did not support some program requirements. HNP revised a procedure and completed documentation to address this weakness. The second program weakness was that some engineering program reviews and program health reports were not consistent with program requirements and site standards. HNP completed corrective actions and communicated engineering programs expectations to program managers and backups.
During the audit and review, the staff review of the additional operating experience documented in the license renewal basis calculation for the ASME Section XI, Subsection IWE Program revealed no unusual or significant findings.
On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff concluded that the applicants ASME Section XI, Subsection IWE Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.26, the applicant provided the FSAR supplement for the ASME Section XI, Subsection IWE Program. By letter dated August 20, 2007, the applicant proposed Commitment No. 22 to enhance the ASME Section XI, Subsection IWE Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 22, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
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Conclusion. On the basis of its audit and review of the applicants ASME Section XI, Subsection IWE Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exception and their justifications and determines that the AMP, with the exception, is adequate to manage the aging effects for which the LRA credits it. Also, the staff reviewed the enhancements and confirmed that their implementation through Commitment No. 22, prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.20 ASME Section XI, Subsection IWL Program Summary of Technical Information in the Application. LRA Section B.2.27 describes the existing ASME Section XI, Subsection IWL Program as consistent, with exception, with GALL AMP XI.S2, ASME Section XI, Subsection IWL.
The ASME Section XI, Subsection IWL Program periodically visually inspects reinforced concrete containment structures in accordance with ASME Code, Section XI, Subsection IWL, 1992 Edition, 1992 Addenda, and is credited for the aging management of accessible and inaccessible pressure-retaining primary containment concrete. HNP concrete containments do not utilize a post-tensioning system; therefore, the IWL requirements for a post-tensioning system do not apply.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exception to determine whether the AMP, with the exception, remained adequate to manage the aging effects for which the LRA credits it.
The staff interviewed the applicants technical personnel and reviewed the applicants the ASME Section XI, Subsection IWL Program license renewal basis calculation, in which the applicant assessed program consistency with GALL AMP XI.S2, ASME Section XI, Subsection IWL, as well as program ISI procedures and 10-year ISI plans. Specifically, the staff reviewed the program elements (documented in SER Section 3.0.2.1) for the ASME Section XI, Subsection IWL Program and their basis documents, as listed in the Audit Report, for consistency with GALL AMP XI.S2. Based on its review of these documents, the staff determined that the program elements of the ASME Section XI, Subsection IWL Program are consistent with the recommended criteria in the program elements of GALL AMP XI.S2, ASME Section XI, Subsection IWL, with the following exception.
Exception. The LRA states the following exception to the GALL Report program element scope of the program:
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GALL AMP XI.S2 describes the ASME Section XI Subsection IWL Program as conforming to the requirements of ASME Section XI Subsection IWL, 1992 edition with the 2001 Edition including the 2002 and 2003 Addenda. The current HNP ASME Section XI, Subsection IWL Program plan for the First Ten-Year inspection interval defined from September 9, 1998 to September 8, 2008, approved per 10 CFR 50.55a, is based on ASME Section XI, Subsection IWL, 1992 Edition, with 1992 Addenda. The difference between the HNP Code of record and Code edition specified in the GALL Report is considered to be an exception to the GALL Report criteria.
The GALL AMP XI.S2, ASME Section XI, Subsection IWL, program description recommends ASME Code Section XI, Subsection IWL editions acceptable for aging management of concrete containment structures:
This evaluation covers both the 1992 Edition with the 2001 Edition including the 2002 and 2003 Addenda, as approved in 10 CFR 50.55a. ASME Code Section XI, Subsection IWL and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing mandated program applicable to managing aging of containment reinforced concrete and unbonded post-tensioning systems for license renewal.
During the audit, the staff asked the applicant for its basis for the exception to the program description. The applicant stated that in accordance with 10 CFR 50.55a(g)(4)(ii), it updates the ISI program during each successive 120-month inspection interval to comply with the requirements of the latest code edition and addenda specified 12 months before the start of the inspection interval. The applicant pointed out that Section 7.3.1 of the program basis document, annotate this statement inadvertently omitted from the LRA description of the exception to the scope of the program program element of the ASME Section XI, Subsection IWL Program.
The applicant stated that it would amend LRA Section B.2.20 to incorporate the statement.
The staff verified the applicants LRA amendment to incorporate this statement by letter dated August 20, 2007.
At present, an ASME Section XI ISI (Subsection IWL) program is approved for use on an ASME Code 10-year ISI interval basis. The applicant has indicated, in its exception, that it is in its first 10-Year ISI interval for concrete containment structures and that the edition of record for this interval is the ASME Code Section XI, Subsection IWL, 1992 edition with 1992 Addenda. The statement in the program description of GALL AMP XI.S2, ASME Section XI, Subsection IWL, means that acceptable editions ASME Code Section XI, Subsection IWL to date include the 1992 through 2001 code editions with 2002 and 2003 Addenda; thus, the staff concludes that the edition for the exception is consistent with the allowable editions of the ASME Code Section XI, Subsection IWL in the GALL AMP XI.S2 program description and thus not an actual exception. On this basis, the staff finds the exception acceptable.
The staff also reviewed portions of the ASME Section XI, Subsection IWL Program for which the applicant claimed consistency with GALL AMP XI.S2 and found them consistent. Based on this finding, the staff concludes that the scope of program and other program elements of the 3-137
 
applicants ASME Section XI, Subsection IWL Program are consistent with the program description and program elements of GALL AMP XI.S2, and acceptable.
Based on its review, the staff finds the applicants ASME Section XI, Subsection IWL Program, with the exception, acceptable assurance of adequate management of the effects of aging.
Operating Experience. LRA Section B.2.27 states that the ASME Section XI, Subsection IWL Program is implemented and maintained in accordance with general requirements for engineering programs for assurance that the program effectively meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have authority and responsibility to implement the program and to commit adequate resources to its activities.
Plant-specific operating experience shows numerous assessments, both plant-specific and corporate, of program development, effectiveness, and implementation. The ASME Section XI, Subsection IWL Program is upgraded continually based upon industry and plant-specific operating experience. Additionally, plant-specific operating experiences are exchanged among CP&L sites through regular peer group meetings, a common corporate sponsor, and outage participation of site program managers.
The staff reviewed the operating experience element in the license renewal basis calculation and plant-specific assessments and interviewed the applicants technical personnel to confirm that plant-specific operating experience revealed no degradation not bounded by industry operating experience. In addition, the applicant stated that it upgrades the ASME Section XI, Subsection IWL Program continually based upon industry and plant-specific operating experience.
After the review of plant-specific assessments and discussions with the applicants technical personnel, the staff concludes with reasonable assurance that the applicants ASME Section XI, Subsection IWL Program will manage adequately the aging effects and aging effect mechanisms for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.27, the applicant provided the FSAR supplement for the ASME Section XI, Subsection IWL Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants ASME Section XI, Subsection IWL Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exception and their justifications and determines that the AMP, with the exception, is adequate to manage the aging effects for which the LRA credits it. The staff concludes that 3-138
 
the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.21 ASME Section XI, Subsection IWF Program Summary of Technical Information in the Application. LRA Section B.2.28 describes the existing ASME Section XI, Subsection IWF Program as consistent, with exceptions, with GALL AMP XI.S3, ASME Section XI, Subsection IWF.
The ASME Section XI, Subsection IWF Program visually examines component and piping supports within the scope of license renewal for loss of material and loss of mechanical function. The program is implemented through plant procedures for visual examination of ISI Classes 1, 2, and 3 supports. Visual examination is in accordance with the requirements of ASME Section XI, Subsection IWF, 1989 Edition with no Addenda and ASME Code Case N-491-2 for component supports other than snubbers. For the snubber attachments and their fasteners, inspections are in accordance with technical specifications. The applicable code for the snubber attachments and fasteners is the ASME Operation and Maintenance (OM)
Code, 1995 Edition with 1996 Addenda, and ASME OM Code Case OMN-13.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the exceptions to determine whether the AMP, with the exceptions, remained adequate to manage the aging effects for which the LRA credits it.
The staff interviewed the applicants technical personnel and reviewed the applicants basis documents related to the ASME Section XI, Subsection IWF Program in which the applicant assessed its program consistency with GALL AMP XI.S3, ASME Section XI, Subsection IWF.
The staff reviewed the ASME Section XI, Subsection IWF Program basis documents, including the license renewal basis calculation, which assesses consistency of the program elements with those recommended in GALL AMP XI.S3. Specifically, the staff compared the program element descriptions (documented in SER Section 3.0.2.1) in the license renewal basis calculation to the program element criteria recommended in GALL AMP XI.S3, ASME Section XI, Subsection IWF, and basis documents, as listed in the Audit Report, for consistency with the program elements recommended in GALL AMP XI.S3.
Based on its review of the ASME Section XI, Subsection IWF Program license renewal basis calculation and supporting basis documents, the staff determined the AMP program elements incorporate the recommended criteria from program elements defined in GALL AMP XI.S3, ASME Section XI, Subsection IWF, with the following exception evaluated in this section.
Based on this evaluation, the staff finds the program elements for the ASME Section XI, Subsection IWF Program consistent with the recommended program elements in GALL AMP XI.S3 and acceptable assurance of adequate management of aging effects for the 3-139
 
component and pipe supports during the period of extended operation with the following exception evaluated in the following paragraphs:
Exception. The LRA states an exception to the scope of program and parameters monitored/inspected program elements of GALL AMP XI.S3, ASME Section XI, Subsection IWF, specifically:
NUREG-1801, Section XI.S3, describes the ASME Section XI Subsection IWF Program as conforming to the requirements of ASME Section XI Subsection IWF, 2001 edition including the 2002 and 2003 Addenda. The current HNP ASME Section XI, Subsection IWF program plan for the second ten-year interval defined from February 2, 1998 through May 1, 2007, approved per 10 CFR50.55a, for components and supports is based on ASME Section XI Subsection IWF, 1989 Edition (no Addenda). Snubber attachments and fasteners are based on the 1995 Edition with 1996 Addenda of the ASME OM Code and ASME OM Code Case OMN-13. In conformance with 10 CFR 50.55a(g)(4)(ii), the ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition and addenda of the Code specified twelve months before the start of the inspection interval. The difference between the HNP Code of record and the Code edition specified in NUREG-1801 is considered to be an exception to NUREG-1801 criteria.
During the audit, the staff asked the applicant for the schedule for updating the ASME Section XI, Subsection IWF Program to a later ASME Code edition for the period of extended operation.
In response to the staffs question the applicant replied that in accordance with 10 CFR 50.55a(g)(4)(ii), ISI program updates during each successive 120-month inspection interval comply with the requirements of the latest code edition and addenda specified 12 months before the start of the inspection interval.
The 10 CFR 50.55a requirements govern application and implementation of codes and standards, including the ASME Code Section XI. Paragraph (g)(4)(ii) of 10CFR50.55a requires updating of the ASME Code Section XI edition of record for an applicants ISI program to the most recent edition of the code endorsed in rule at least twelve months prior to the next successive 10-year (i.e.,120-month) ISI interval.
The staff noted that at the time of the LRA submission the applicant was in its second 10-Year ISI interval and that the ASME Code Section XI edition of record for that interval was the 1989 Edition with no addenda. The staff also reviewed the license renewal basis calculation and noted that HNP entered its third 10-Year ISI interval on May 2, 2007, and that the ASME Code Section XI code of record for that interval is the 2001 Edition with 2003 Addenda.
This edition is consistent with that specified in GALL AMP XI.M1.
The applicant must update its ASME Code Section XI edition of record to the 2001 Edition with 3-140
 
2003 Addenda, and as this edition is the same as that recommended in GALL AMP XI.S3, ASME Section XI, Subsection IWF, the staff concludes that the exception to GALL AMP XI.M1 is no longer part of the review of this AMP, instead, that the program elements of the applicants ASME Section XI, Subsection IWF Program are consistent with those of GALL AMP XI.M3.
Reactor Head Closure Studs, and acceptable.
During the audit, the staff asked the applicant to justify exclusion of the ASME Class MC supports from this program.
The applicant stated that there are no ASME Class MC supports at HNP, as indicated in the First Containment Inspection Interval Containment Inspection Program section, stating, The welded attachments to the metallic liner (e.g., floor beams, seismic restraints, leak channels, equipment/pipe supports, etc.) do not perform a pressure retaining function associated with the containment support load path. For this reason, the applicant clarified that the welded attachments are nonstructural components not subject to inspection.
The staff found applicants response acceptable and verified that FSAR Section 3.2, Classification of Structures, Components, and Systems, indicates no MC supports.
The staff asked the applicant to justify use of ASME Code and ASME OM Code Case OMN-13 for snubber attachments and their fasteners.
The applicant stated that the snubbers are not within the scope of license renewal; therefore, it would remove references to ASME OM Code and ASME Code Case OMN-13 from LRA Sections B.2.28 and A.1.1.2.8 in an amendment to the application. The applicant clarified that inspection of component and piping supports will continue in accordance with ASME Code Section XI, Subsection IWF.
The staff found applicants response acceptable and verified that the snubbers were not within the scope of license renewal per LRA Section 2.1.2. Inspection of all component and pipe supports by the applicant per ASME Section XI Subsection IWF is acceptable. The staff verified that the applicant made the LRA amendment in a letter dated August 31, 2007.
Based on its review, the staff finds the applicants ASME Section XI, Subsection IWF Program consistent with the program elements of GALL AMP XI.S3, ASME Section XI, Subsection IWF, and acceptable for implementation. Based on this finding, the staff concludes that the ASME Section XI, Subsection IWF Program assures adequate management of the effects of aging.
Operating Experience. LRA Section B.2.28 states that the ASME Section XI, Subsection IWF Program is implemented and maintained in accordance with general requirements for engineering programs for assurance that the program effectively to meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have authority and responsibility to implement the program and to commit adequate resources to program activities.
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Plant-specific operating experience shows numerous assessments, both plant-specific and corporate, of program development, effectiveness, and implementation. The ASME Section XI, Subsection IWF Program is upgraded continually based upon industry and plant-specific operating experience. Additionally, plant-specific operating experiences are exchanged among CP&L sites through regular peer group meetings, a common corporate sponsor, and outage participation of site program managers.
The LRA states that ASME Section XI, Subsection IWF Program implementation and maintenance are in accordance with general requirements for engineering programs for assurance that the program is effectively meets regulatory, process, and procedure requirements, including periodic reviews; qualified personnel assigned as program managers have authority and responsibility to implement the program with and adequate resources committed to its activities.
Plant-specific operating experience shows numerous assessments, both a plant-specific and corporate, dealing with program development, effectiveness, and implementation. The applicant upgrades the IWF program continually based upon industry and plant-specific operating experience. Additionally, the applicant sites share plant-specific operating experiences through regular peer group meetings, a common corporate sponsor, and outage participation of site program managers.
After review of plant-specific assessments and discussions with the applicant's technical personnel, the staff concludes with reasonable assurance that the ASME Section XI, Subsection IWF Program will manage adequately the aging effects and aging effect mechanisms for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.28, the applicant provided the FSAR supplement for the ASME Section XI, Subsection IWF Program. The staff reviewed this section and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants ASME Section XI, Subsection IWF Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, the staff reviewed the exceptions and their justifications and determines that the AMP, with the exceptions, is adequate to manage the aging effects for which the LRA credits it. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
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3.0.3.2.22 10 CFR Part 50, Appendix J Program Summary of Technical Information in the Application. LRA Section B.2.29 describes the existing 10 CFR Part 50, Appendix J Program as consistent, with enhancement, with GALL AMP XI.S4, 10 CFR 50, Appendix J.
The 10 CFR Part 50, Appendix J Program monitors leakage rates through containment liner/welds, penetrations, fittings, and access openings to detect degradation of the pressure boundary.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancement to determine whether the AMP, with the enhancement, remained adequate to manage the aging effects for which the LRA credits it. An evaluation and appropriate corrective actions address leakage rates exceeding acceptance criteria. For integrated leak rate testing, the program is in accordance with 10 CFR Part 50, Appendix J, Option B (performance-based leak testing), with the guidelines of RG 1.163 (September 1995), and with NEI 94-01, Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J. For local leak rate testing, the program is in accordance with the prescriptive requirements of 10 CFR Part 50, Appendix J, Option A for Type B and Type C tests.
Enhancement. The LRA states the following enhancement to the GALL Report program element corrective actions, specifically:
Administrative controls that implement the program will be revised to describe the evaluation and corrective actions to be taken when leakage rates do not meet their specified acceptance criteria.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 23) to enhance program implementing procedures to require evaluation and corrective actions when leakage rates do not meet specified acceptance criteria. The staff finds this commitment acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the corrective actions program element.
Operating Experience. LRA Section B.2.29 states that the 10 CFR Part 50, Appendix J Program is maintained in accordance with general requirements for engineering programs for assurance that the program effectively meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have authority and responsibility to implement the program and to commit adequate resources to its activities.
During the audit and review, the staff reviewed various nuclear condition reports of measured leakage rates outside acceptance criteria and the corrective actions taken. These reports maintained by the10 CFR Part 50, Appendix J Program engineer were available at HNP. The staff noted no instances of 10 CFR Part 50, Appendix J, test failures due to causes other than valve or flange seat leakage. HNP evaluated and corrected all such failures.
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On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff finds that the applicant's 10 CFR Part 50, Appendix J Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.29, the applicant provided the FSAR supplement for the 10 CFR Part 50, Appendix J Program. By letter dated August 20, 2007, the applicant proposed Commitment No. 23 to enhance the 10 CFR Part 50, Appendix J Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 23, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants 10 CFR Part 50, Appendix J Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancement and confirmed that their implementation through Commitment No. 23 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.23 Masonry Wall Program Summary of Technical Information in the Application. LRA Section B.2.30 describes the existing Masonry Wall Program as consistent, with enhancement, with GALL AMP XI.S5, Masonry Wall Program.
The Masonry Wall Program manages aging effects to keep the evaluation basis for each masonry wall within the scope of license renewal valid through the period of extended operation. The program includes masonry walls with intended functions in accordance with 10 CFR 54.4. Included are the masonry walls within the containment building, reactor auxiliary building, diesel generator building, fuel handling building, heating, ventilating, and air-conditioning (HVAC) equipment room, security building, tank area/building, turbine building, and the waste processing building. The program monitors conditions with inspection frequencies established for no loss of intended function between inspections.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancement to determine whether the AMP, with the enhancement, remained adequate to manage the aging effects for which the LRA credits it.
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Enhancement. The LRA states the following enhancement to the GALL Report program element scope of the program, specifically:
Revise program administrative controls to identify the structures that have masonry walls within the scope of license renewal.
During the audit and review, the staff noted that implementation of the existing Masonry Wall Program is through a maintenance rule structures monitoring procedure. The program includes all masonry walls performing intended functions in accordance with 10 CFR 54.4. Included are masonry walls within the Containment Building, Reactor Auxiliary Building (including the Common Building), Diesel Generator Building, Fuel Handling Building, HVAC Equipment Room, Security Building, Tank Area/Building (including Units 1 and 2), Turbine Building, and Waste Processing Building.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 24) to enhance this procedure to indicate structures with masonry walls within the scope of license renewal. The staff finds this commitment acceptable as the enhanced procedure will address GALL Report recommendations and be consistent with the scope of the program program element.
On this basis, the staff finds this enhancement acceptable because, when implemented, the Masonry Wall Program will be consistent with GALL AMP XI.S5 and will assure adequate management of the effects of aging.
During the audit and review, the staff noted that GALL AMP XI.S5, Masonry Wall Program, under the detection of aging effects program element, states:
The frequency of inspection is selected to ensure there is no loss of intended function between inspections. The inspection frequency may vary from wall to wall, depending on the significance of cracking in the evaluation basis.
Unreinforced masonry walls, which have not been contained by bracing warrant the most frequent inspection, because the development of cracks may invalidate the existing evaluation basis.
The staff asked the applicant whether the inspection frequency varies from wall to wall at HNP.
In its response dated August 20, 2007, the applicant stated that the inspection interval established in a corporate-level inspection procedure for HNP and other fleet nuclear plants for masonry wall cracking varies from structure to structure but does not exceed ten years. Various frequencies based on safety significance (probabilistic safety analysis rating) of SSCs, the condition of the wall in previous structural inspection results, and accommodations to work load management for engineering personnel ensure no loss of intended function between inspections as described in GALL AMP XI.S5. For example, examinations of the masonry walls in the reactor containment building are at five-year intervals, the fuel handling building at seven-year intervals, the Turbine Building at eight-year intervals, and several nonsafety-related structures at nine-year intervals. Typically there is no established no inspection frequency from 3-145
 
wall to wall within a structure; however the responsible engineer may establish an inspection frequency based on previous inspections. Since 1996, when the inspections began, they have found no unacceptable conditions from cracking; therefore, there has been no need to change the inspection interval for masonry walls. Unacceptable conditions in the future will require a nuclear condition report and corrective actions that could change the inspection interval for a masonry wall by the responsible engineers disposition. The corporate procedure is the same for inspections of building concrete/grout. A recent example changed the inspection interval for a diesel generator foundation to yearly based on the condition of the grout. Also noteworthy is that there are no unreinforced masonry walls in safety-related areas.
HNP does not consider the methodology for selection of the inspection interval for masonry walls an exception to GALL AMP XI.S5 Program Attribute 4 because Bulletin 80-11 was issued to HNP for information while HNP was under construction. HNP designed and constructed Category I masonry walls as described in FSAR Section 3.8.4.8. To preclude problems addressed by Bulletin 80-11, HNP designed all-masonry walls in the proximity of safety-related equipment to meet seismic design criteria. QA/QC inspections of the walls were in accordance with implementation procedures. In addition, approval of equipment attachments to masonry block walls was case by case. HNP analyzes safety-related masonry walls in a structural calculation. Several NRC construction assessment teams that examined construction of the masonry walls in 1984 and 1986 reported Bulletin 80-11 requirements met. The following NRC letters document HNP design and construction of masonry walls to Bulletin 80-11 requirements:
NRC Inspection Reports 50-400/84-41, 50-400/84-48, 50-400/86-03, 50-400/86-06, and 50-400/87/32. In conclusion, the HNP masonry wall construction was to Bulletin 80-11 requirements without the design and construction problems typical of earlier plants. The masonry walls have proven to be designed, constructed, and verified to QA requirements with no unacceptable conditions over 20 years after installation. HNP considers the responsible engineers methodology in selecting the inspection intervals for masonry walls as meeting GALL AMP XI.S5 Program Attribute 4 attributes. In conclusion, there is no need to inspect nonreinforced masonry walls more frequently than reinforced masonry walls unless unacceptable conditions are present.
The staff finds the applicants response acceptable. Plant-specific operating experience revealed no history of masonry wall aging effects. With this history the corrective action program adequately determines whether inspections of masonry walls beyond the programs current building inspection cycles should be more frequent.
Operating Experience. LRA Section B.2.30 states that the Masonry Wall Program is implemented through a corporate procedure with systematic measures to ensure the program objective of managing aging effects to keep the evaluation basis for each masonry wall within the scope of license renewal valid through the period of extended operation. The Masonry Wall Program is included within the scope of the Maintenance Rule Program implemented and maintained in accordance with general requirements for engineering programs for assurance that the Masonry Wall Program effectively meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have the authority and responsibility to implement the program and to commit adequate resources to its activities.
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Inspections documented in structure walkdown inspection reports and staff inspection reports and assessments documented in self-assessments and National Academy of Sciences assessments show the Masonry Wall Program as implemented through the Maintenance Rule Program as critically monitored and continually improving. These operating experience results prove that the Masonry Wall Program ensures the continuing integrity of the subject walls.
During the audit and review, the staff reviewed the operating experience described in the LRA and an HNP maintenance rule self-assessment covering the period from June 30, 2003, to November 17, 2004. The staff determined the program to be effective in meeting 10 CFR 50.65 requirements with no specific deficiencies found by inspection of masonry walls. The staff reviewed corporate assessments of the Maintenance Rule Program, which included masonry walls, in 1999, 2001, and 2005 and found no issues. The staff reviewed walkdowns for structures within the scope of the maintenance rule completed in the summer of 2006 and documented in accordance with HNP procedures finding only minor cracking in the turbine building and minor mortar defects in the diesel generator building and requiring no corrective actions. The staff reviewed Inspection Report 50-400/97-07 (1997), which evaluated HNP effectiveness in implementing maintenance rule requirements. Noting no violations or deficiencies for masonry walls, the NRC inspection concluded that the program was comprehensive and effectively implemented.
On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff concluded that the Masonry Wall Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A1.1.30, the applicant provided the FSAR supplement for the Masonry Wall Program. In its letter dated August 20, 2007, the applicant proposed Commitment No. 24 to enhance the Masonry Wall Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 24, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Masonry Wall Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancement and confirmed that their implementation through Commitment No. 24 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared.
The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.24 Structures Monitoring Program 3-147
 
Summary of Technical Information in the Application. LRA Section B.2.31 describes the existing Structures Monitoring Program as consistent, with enhancements, with GALL AMP XI.S6, Structures Monitoring Program.
The Structures Monitoring Program manages the aging effects of civil/structural commodities within the scope of license renewal. The Structures Monitoring Program is implemented, through procedures, in accordance with the regulatory requirements and guidance of the Maintenance Rule, 10 CFR 50.65; RG 1.160, Revision 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and NEI 93-01, Revision 2, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The program incorporates criteria recommended by INPO Good Practice Document 85-033, Use of System Engineers, NEI 96-03, Guidelines for Monitoring the Condition of Structures at Nuclear Plants, and inspection guidance based on industry operating experience and recommendations from American Concrete Institute (ACI) Standard 349.3R-96, Evaluation of Existing Nuclear Safety-Related Concrete Structures, and American Society of Civil Engineers (ASCE) 11-90, Guideline for Structural Condition Assessment of Existing Buildings. The program periodically inspects and monitors the condition of structures and structure component supports to detect and determine the extent of aging degradation leading to loss of intended functions.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
Enhancements 1 through 6. The LRA states the following enhancements to the GALL Report program element scope of the program, specifically:
(1) Administrative controls that implement the program will be revised to specifically identify the license renewal structures and systems that credit the program for aging management.
(2) Administrative controls that implement the program will be revised to require notification of the responsible engineer when below-grade concrete is exposed so an inspection may be performed prior to backfilling.
(3) Administrative controls that implement the program will be revised to require periodic groundwater chemistry monitoring designed for potential seasonal variations.
(4) Administrative controls that implement the program will be revised to define the term structures of a system in the system walkdown procedure and specify the condition monitoring parameters that apply to structures of a system.
(5) Administrative controls that implement the program will be revised to include the corporate structures monitoring procedure as a reference in the plant implementing procedures and specify that forms from the corporate procedure 3-148
 
be used for inspections.
(6) Administrative controls that implement the program will be revised to require inspection of inaccessible surfaces of concrete pipe when exposed.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 25) to enhance the program implementing procedures (1) to indicate the license renewal structures and systems that credit the program for aging management, (2) to require notification of the responsible engineer of below-grade concrete exposure for an inspection prior to backfilling, (3) to require periodic groundwater chemistry monitoring designed for potential seasonal variations, (4) to define the term structures of a system in the system walkdown procedure and to specify the condition monitoring parameters for structures of a system, (5) to include the corporate structures monitoring procedure as a reference in the plant implementing procedures and to specify use of corporate procedure forms for inspections, and (6) to require inspection of inaccessible surfaces of reinforced concrete pipe exposed by removal of backfill.
The staff finds these commitments acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the scope of the program program element.
Enhancements 7 through 9. The LRA states the following enhancements to the GALL Report program element parameters monitored or inspected, specifically:
(7) Administrative controls that implement the program will be revised to identify additional civil/structural commodities and associated inspection attributes required for license renewal.
The applicant will revise the plant-specific structural condition monitoring procedure to include the following commodities within a condition monitoring group with the absence of corrosion other than minor surface corrosion performance standard:
* Phase bus enclosure assemblies
* Floor drains
* Light poles In addition the applicant will revise the procedure to include an inspection attribute for wood members with a performance standard no decay or insect infestation affecting structural properties, additional inspection guidance for friction plates (Lubrite) of absence of excessive wear, and a performance standard of "absence of corrosion other than minor surface corrosion" for the "metal siding and trim" inspection attribute for metal siding, roof deck, and trim.
(8) Administrative controls that implement the program will be revised to require notification of the responsible engineer when below-grade concrete is exposed so an inspection may be performed prior to backfilling.
The applicant will utilize the plant-specific procedure for plant area excavation and backfill, after 3-149
 
revision, to notify the structural systems engineer when and where below-grade concrete and concrete pipe are exposed for an inspection before backfilling.
(9) Administrative controls that implement the program will be revised to require inspection of inaccessible surfaces of concrete pipe when exposed.
The staff noted that a plant-specific Maintenance Rule structures monitoring procedure implements the existing Structures Monitoring Program. The applicant will revise the procedure to include inspection of inaccessible reinforced concrete pipe surfaces when exposed by removal of backfill for any reason.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 25) to enhance program implementing procedures (1) to indicate additional civil/structural commodities and inspection attributes required for license renewal, (2) to require notification of the responsible engineer when below-grade concrete is exposed for an inspection prior to backfilling, and (3) to require inspection of inaccessible surfaces of reinforced concrete pipe exposed by removal of backfill. The staff finds these commitments acceptable as the enhanced program implementing procedures will address GALL Report recommendations and be consistent with the parameters monitored or inspected program element.
On this basis, the staff finds all 9 enhancements acceptable because, when implemented, the Structures Monitoring Program will be consistent with GALL AMP XI.S6 and will assure adequate management of the effects of aging.
During the audit and review, the staff noted that the applicant will create a groundwater monitoring procedure for periodic groundwater chemistry monitoring designed for potential seasonal variations. The staff asked the applicant (1) for the dates and results at specific locations of the two most recent tests for aggressive groundwater and the scheduled frequency of groundwater monitoring, and (2) whether the Structures Monitoring Program will continue groundwater monitoring and inspection of all inaccessible areas that may be exposed by excavation whether the environment is aggressive or not.
In its response dated August 20, 2007, the applicant stated that LRA Section 3.5.2.2.1 describes groundwater sampling for license renewal in August 2005 from two wells (Well 57 -
pH 7.6, chlorides 290 mg/l, sulfate 2.4 mg/l; Well 59 - pH 7.9, chlorides 42 mg/l, sulfate 2.1 mg/l). Prior groundwater sampling in 1973 was from three site wells no longer active recorded in FSAR Table 2.4.13-8 (Well 2 - pH 7.3, chlorides 23 mg/l, no sulfate reading; Well 4A - pH 7.9, chlorides 22 mg/l, no sulfate reading; Well 7A - pH 7.9, chlorides 21 mg/l, no sulfate reading). The Structures Monitoring Program will add a groundwater implementing procedure to require periodic groundwater chemistry monitoring designed for potential seasonal variations (as stated in LRA Appendix B, Section B.2.31). The monitoring will begin in five-year intervals from 2005 until the period of extended operation (for trending prior to the extended operation period) and then yearly thereafter even though the groundwater is currently nonaggressive. In addition, a Structures Monitoring Program implementing procedure enhancement will require inspection of inaccessible below-grade concrete exposed by excavation prior to backfilling, an enhancement to be continued during the period of extended operation even though the groundwater is nonaggressive.
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The staff finds the applicants response acceptable. The groundwater is currently not aggressive. The groundwater monitoring will begin with five-year intervals from 2005 until the period of extended operation for trending. During the period of extended operation the groundwater monitoring will be yearly with provision for seasonal variations. Inspections of below-grade concrete exposed by excavation also will continue during the period of extended operation even if the groundwater is nonaggressive. The applicant has demonstrated adequately monitoring of potential aging effects for below-grade concrete during the period of extended operation.
Operating Experience. LRA Section B.2.31 states that the Structures Monitoring Program incorporates INPO-recommended best practices and inspection guidance based on industry operating experience and recommendations from the ACI and the ASCE.
Review of inspection reports, self-assessments, and condition reports has concluded that the administrative controls are effective in detecting age-related degradation, implementing appropriate corrective actions, and continually upgrading structure monitoring.
During the audit and review, the staff reviewed the operating experience described in the LRA and a Maintenance Rule self-assessment for the period from June 30, 2003, to November 17, 2004, and determined that the program was effective in meeting 10 CFR 50.65 requirements. The self-assessment reported two weaknesses and five items for management consideration. One weakness in structural items in the Maintenance Rule database needed an update with the current performance group criteria. Corrective action resolved the weakness.
One management consideration was a link between the system walkdown procedure and the plant-specific Maintenance Rule structures monitoring procedure to address structural deficiencies. Revision of the system walkdown procedure resolved this item.
During the audit and review, the staff reviewed 1999, 2001, and 2005 corporate Nuclear Assessment Section assessments of the Maintenance Rule Program. The assessments did not evaluate the Structures Monitoring Program specifically but did evaluate the Maintenance Rule Program, which includes structures and structures of systems. The 1999 assessment found an issue and a weakness in the Maintenance Rule Program and corrective actions improved the overall program. The 2001 and 2005 assessments found no issues or weaknesses in the Maintenance Rule Program.
During the audit and review, the staff reviewed walkdowns for structures within the scope of the Maintenance Rule completed in the summer of 2006 and documented in accordance with plant procedure. Four action requests addressed documented conditions: (1) a degraded (severely corroded) but operable safety-related conduit support in the intake structure, (2) a loose flange bolt nut (corrected) on a valve in the containment, (3) protective coating discrepancies (corrected) in the containment on Service Level I applications, and (4) cracks in the foundation pad for the B EDG silencer.
The staff reviewed NRC Inspection Report 50-400/97-07 (1997), which evaluated HNP effectiveness in implementing Maintenance Rule requirements and concluded that the program was comprehensive and effectively implemented. The NRC inspection report noted minor material conditions for structures not documented in the 1996 baseline inspections by the plant 3-151
 
but initiated no violations or deficiencies for such structures.
During the audit and review, the staff reviewed various action requests and condition reports.
Most of the documented conditions were rusted or corroded structural components (e.g., pipe supports, studs, grating, and conduits). HNP corrected these conditions as well as a few from procedural and walkdown documentation errors.
On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff concluded that the applicants Structures Monitoring Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.31, the applicant provided the FSAR supplement for the Structures Monitoring Program. In its letter dated August 20, 2007, the applicant proposed Commitment No. 25 to enhance the Structures Monitoring Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 25, the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Structures Monitoring Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation through Commitment No. 25, prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.25 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program Summary of Technical Information in the Application. LRA Section B.2.32 describes the existing RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program as consistent, with enhancements, with GALL AMP XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.
The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program consists of inspection and surveillance to manage the aging effects of the dams and spillways, dikes, canals, reservoirs, and the intake, screening, and discharge structures of plant cooling water systems. The program was developed to meet the requirements of RG 1.127, 3-152
 
Revision 1.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which the LRA credits it.
Enhancement 1. The LRA states the following enhancement to the GALL Report program element parameters monitored or inspected, specifically:
Administrative controls will be revised to document a visual inspection of the miscellaneous steel at the main dam and spillway.
During the audit and review, the staff noted that a plant-specific dam/dike/retaining wall monitoring procedure monitors dams, dikes, and related structures in the reservoir complex.
The applicant will revise the procedure checklist documenting observations for the main dam and spillway for the major five-year inspection to include a visual inspection of the grating, checkered plate, and hand rail.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 26, Item No. 3) to enhance the program implementing procedure to require documentation of a visual inspection of miscellaneous steel at the main dam and spillway. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the parameters monitored or inspected program element.
Enhancement 2. The LRA states the following enhancement to the GALL Report program element acceptance criteria, specifically:
Administrative controls that implement the program will be revised to require evaluation of concrete deficiencies in accordance with the acceptance criteria provided in the corporate inspection procedure.
During the audit and review, the staff noted that the RG 1.127 program implementation is through a corporate procedure for condition monitoring of structures providing the guidance and periodicity required to manage the effects of aging. Concrete acceptance criteria based on Chapter 5 of ACI 349.3R-96 are in this procedure. The plant-specific dam/dike/retaining wall monitoring procedure monitors dams, dikes, and related structures in the reservoir complex.
The applicant will revise the plant-specific dam/dike/retaining wall monitoring procedure to require evaluation of concrete deficiencies in accordance with corporate acceptance criteria.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 26, Item No. 1) to enhance program implementing procedure to require evaluation of any concrete deficiencies in accordance with corporate inspection acceptance criteria. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the acceptance criteria program element.
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Enhancement 3. The LRA states the following enhancement to the GALL Report program element corrective actions, specifically:
Administrative controls that implement the program will be revised to require initiation of a Nuclear Condition Report (NCR) for degraded plant conditions and require, as a minimum, the initiation of an NCR for any condition that constitutes an unacceptable condition based on the acceptance criteria specified.
During the audit and review, the staff noted that a plant-specific dam/dike/retaining wall monitoring procedure monitors dams, dikes, and related structures in the reservoir complex.
The applicant will revise the procedure to require NCRs for degraded plant conditions and require, as a minimum, an NCR for any condition unacceptable under specified criteria.
By letter dated August 20, 2007, the applicant proposed a commitment (Commitment No. 26, Item No. 2) to enhance the program implementing procedure to require NCRs for degraded plant conditions and require, as a minimum, an NCR for any condition unacceptable under specified criteria. The staff finds this commitment acceptable as the enhanced program implementing procedure will address GALL Report recommendations and be consistent with the corrective actions program element.
During the audit and review, the staff noted that prior to the period of extended operation one RG 1.127 program enhancement will revise the administrative controls that implement the program to require NCRs for degraded plant conditions and require, as a minimum, an NCR for any condition unacceptable under specified criteria. The staff asked the applicant to explain, as NCRs are not currently in use, how the program documents unacceptable conditions and processes them for engineering evaluation or corrective action.
In its response dated August 20, 2007, the applicant stated that a corporate corrective action program requires all employees to initiate NCRs for unacceptable conditions like deficiencies or deviations that has affected or reasonably could affect nuclear safety or quality. The RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants Program enhancement improves administrative procedure by clarifying the corporate requirement. This enhancement also makes the administrative procedure consistent with the corporate level procedure for the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants Program.
The staff finds the applicants response acceptable. The plant-specific operating experience shows action requests in the past have documented degraded plant conditions found in RG 1.127 inspections. The enhancement to plant-specific administrative procedures is for NCR clarification purposes and consistency with corporate level procedures.
Operating Experience. LRA Section B.2.32 states that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program is implemented through a corporate procedure as well as plant-specific inspection and surveillance procedures that address age-related deterioration, degradation due to extreme environmental conditions, and the effects of natural phenomena that may affect water control structures. The procedures 3-154
 
provide for periodic monitoring and maintenance of water control structures for timely prevention or mitigation of the consequences of age-related deterioration and degradation for assurance that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program effectively meets regulatory and procedural requirements, including periodic reviews. Qualified personnel assigned as program managers have the authority and responsibility to implement the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program and to commit adequate resources to its activities.
Corrective actions as results of inspections quarterly and every five years, monitoring of instrumentation readings, and evaluations of the data by plant personnel show the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program as critically monitored and continually improving. The staff has audited the program with satisfactory results. The two items of most importance cited by the staff were (1) removal of vegetation from water control structure areas and (2) correction of surface drainage in some locations to prevent erosion of elements of the dam. These items were completed and the process made more formal with the initiation of preventive maintenance inspections at prescribed frequencies.
These operating experience results prove that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program ensures the continuing integrity of water control structures.
During the audit and review, the staff reviewed the operating experience described in the LRA and the 1995, 2000 and 2005 five-year inspection reports for water control structures and found the inspection reports very comprehensive and detailed. The staffs primary focus of review was the most recent (2005) inspection report. The applicant had initiated an action request to develop a plan to address the recommendations from the 2005 water control structures inspection report. Some of the applicants actions to address the inspection report findings include:
For the Main Dam:
Initiate a new 6 month preventive maintenance to address normal maintenance activities that are to be performed for the main dam structure, spillway, and retaining walls. These activities will include the intake and discharge channels and beaver control activities.
Initiate a work request to address a rock block slide on the main dam east spillway wall.
For the Auxiliary Dam:
Initiate a new 6 month preventive maintenance to address normal maintenance activities that are to be performed for the auxiliary dam structure, spillway, and retaining walls. These activities will include the emergency water intake channel.
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Channels and Water Handling Structures Recommendations:
Initiate a new 6 month preventive maintenance to perform routine inspections of the channels.
From the staffs review, it was apparent that the applicant addressed the aging effects in the 2005 water control structures inspection report and the report recommendations to prevent aging of the structures.
The staff reviewed NRC Integrated Inspection Report 05000400/2005003 dated July 29, 2005, documenting a biennial inspection of the heat sink retaining dam, the ESW system health reports and work plans, the site dam reports by outside and corporate personnel, and the walkdown of the ESW intake structure and made no significant findings.
The staff reviewed NRC Integrated Inspection Report 50-400/01-04 dated October 25, 2001, documenting an inspection of the heat sink performance. The inspector walked down the ESW intake structure and the main and auxiliary dams with the system engineer and reviewed the reports on the ultimate heat sink dam inspections and made no significant findings.
The staff reviewed an NRC inspection report dated September 20, 2000, documenting the results of a dam safety audit dated July 28, 1999, of the Category I auxiliary reservoir dam. The report concluded that no actions were required for continued safety of the dam. The staff of the Federal Energy Regulatory Commission (FERC) performed the safety audit for the NRC and made no new recommendations for continuing maintenance. All recommendations from the previous 1995 FERC inspection had been addressed.
During the audit and review, the staff reviewed various action requests. Some of the documented conditions were corrosion on electrical supports in the ESW intake structure, a sudden change in piezometer water level readings, effects on the ESW discharge channel from fallen embankment material, and two inoperable main dam seepage monitors. All conditions were corrected or evaluated as acceptable.
On the basis of its review of plant-specific operating experience and discussions with the applicants technical personnel, the staff concluded that the applicants RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program will adequately manage the aging effects for which the LRA credits it.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.32, the applicant provided the FSAR supplement for the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program. In its letter dated August 20, 2007, the applicant proposed Commitment No. 26 to enhance the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program prior to the period of extended operation. The staff reviewed this section and determines that, with Commitment No. 26, the information in the FSAR supplement is an 3-156
 
adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation by Commitment No. 26 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.26 Reactor Coolant Pressure Boundary Fatigue Monitoring Program Summary of Technical Information in the Application. LRA Section B.3.1 describes the existing Reactor Coolant Pressure Boundary Fatigue Monitoring Program as consistent, with enhancements, with GALL AMP X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary.
The Reactor Coolant Pressure Boundary Fatigue Monitoring Program includes preventive measures to mitigate fatigue cracking caused by anticipated cyclic strains in RCPB metal components by monitoring and tracking significant thermal and pressure transients for limiting RCPB components so the fatigue design limit is not exceeded. The RCPB Fatigue Monitoring Program addresses the effects of the reactor coolant environment on component fatigue life by including within the program scope environmental fatigue evaluations of the sample locations specified in NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components. These locations were evaluated by application of environmental correction factors to ASME Section III, Class 1 fatigue analyses as specified in NUREG/CR-6583, Effects of LWR Coolant Environments on Fatigue Design Curves of Carbon and Low-Alloy Steels, NUREG/CR-5704, Effects of LWR Coolant Environments on Fatigue Design Curves of Austenitic Stainless Steels, and NUREG/CR-6717, Environmental Effects on Fatigue Crack Initiation in Piping and Pressure Vessel Steels. The program triggers preventive actions, corrective actions, or both before the design limit is exceeded. The applicant has ensured management of the effects of the reactor water environment on fatigue-sensitive locations for the period of extended operation.
Staff Evaluation. During its audit and review, the staff confirmed the applicants claim of consistency with the GALL Report. The staff reviewed the enhancements to determine whether the AMP, with the enhancements, remained adequate to manage the aging effects for which it is credited.
Enhancements. The LRA states the following enhancements to meet the GALL Report program elements "scope of the program, parameters monitored or inspected, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and "corrective actions, specifically:
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Scope:          Expand the scope of the Program to include: (a) monitoring of selected RCPB components outside of the reactor vessel (including auxiliary system components such as the pressurizer lower header, pressurizer surge line, and CVCS piping and heat exchanger), and (b) incorporation of NUREG/CR-6260 locations analyzed for environmental effects.
Parameters Monitored/Inspected:        Expand the parameters monitored to include monitoring of selected RCPB components outside of the reactor vessel as noted in Scope of Program above.
The staff reviewed these enhancement and finds them is consistent with the GALL Report.
During the audit, the staff reviewed the HNP Fatigue Evaluation for License Renewal, which recommends incorporation of auxiliary components like the pressurizer lower header, pressurizer surge line, and chemical volume and control system (CVCS) piping and heat exchanger. The staff finds that the applicant included all components recommenced by the Westinghouse report. In addition, the staff finds the incorporation of NUREG/CR-6260 recommended by the GALL Report. On these bases, the staff finds the applicants proposed enhancements acceptable.
Preventive Actions:    Enhance the preventive actions to include, prior to a monitored location exceeding a Cumulative Usage Factor (CUF) limit of 1.0, evaluation of operational changes to reduce the number or severity of future transients.
The staff reviewed the applicants proposed enhancement and finds it consistent with the GALL Report and on this basis acceptable.
Detection of Aging Effects:    Enhance the Program to utilize online fatigue analysis software for the periodic updating of cumulative fatigue usage calculations for high fatigue usage RCPB (including auxiliary system) components.
During the audit, the staff asked the applicant to clarify this enhancement with information on the timing of these periodic updates and whether the cumulative usage factor (CUF) update is for all components under the Fatigue Monitoring Program, only those under program, or only those with stress-based fatigue monitoring.
It its response, the applicant stated:
The current HNP Fatigue Monitoring Program requires a monthly evaluation of cyclic and transient data. When enhanced, the program will require a periodic update (at least once every 18 months) and review of monitored usage values in addition to the monthly cyclic and transient data monitored.
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In addition, the applicant amended the LRA in by letter dated August 31, 2007, to reflect the periodic update (at least every 18 months), specifically revising LRA Section A.3.1.1.38 to read (3) include a provision to utilize online fatigue analysis software for the periodic updating (not to exceed once every 18 months) of cumulative usage. In addition, the revised enhancement for detection of aging effects of this program states, Enhance the Program to utilize online fatigue analysis software for the periodic updating (at least once every 18 months) of cumulative fatigue usage calculations for high fatigue usage RCPB (including auxiliary system) components. The staff reviewed the LRA changes and finds the periodic update (at least every 18 months) a sufficient margin to ensure that components are within design limits or will be entered into the Corrective Actions Program. On this basis, the staff finds the applicants proposed enhancement acceptable.
Monitoring and Trending:        Enhance the Program to include: (a) the NUREG/CR-6260 locations that are analyzed for environmental effects, and (b) a description of the use of the online fatigue analysis software for monitoring and trending of cumulative fatigue usage for limiting component locations.
During the audit, the staff asked the applicant to clarify this enhancement with the alarm limits of components included in the stress-based fatigue monitoring portion as well as those in the cycle-counting portion of the program.
The applicant provided two lists of locations and alarm limits. The staff noted that all cycle or transient alarm limits are set conservatively with the current cycle numbers (as stated in the LRA) a small fraction of design cycles. The staff finds the limiting component locations appropriately selected for the online software with no transients cycles for these locations left to be counted administratively. On this basis, the staff finds the applicants proposed enhancement acceptable.
Acceptance Criteria: Enhance the Program to describe the acceptance criteria for maintaining the fatigue usage below the design code limit, taking into consideration the environmental fatigue effects for the NUREG/CR-6260 locations.
The staff reviewed this enhancement and finds it consistent with the GALL Report. On this basis, the staff finds the applicants proposed enhancement acceptable.
Corrective Actions:    Enhance the Program to address corrective actions if an analyzed component is determined to be approaching the design limit, with options to revise the fatigue analysis, repair, or replace the component.
The staff reviewed this enhancement and finds clarification needed. During the audit, the staff asked to applicant to describe the process to inform the program owner when an alarm limit is approached and on how the process is procedurally controlled.
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In its response, the applicant stated:
when program enhancements are implemented, the program will have established alarm limits for plant cycle and transient counts and alarm limits for monitored component usage values. When alarm limits are reached, corrective actions will be taken.
When alarm limits are reached, corrective actions will be taken as described above. Corrective actions are procedurally controlled by the corporate Corrective Action Program (CAP) procedure. Corrective Actions are implemented in accordance with the requirements of Appendix B to 10 CFR 50.
The staff reviewed the applicants response and noted that the LRA does not state specifically that the Corrective Actions Program will implement the corrective actions.
By letter dated August 31, 2007, the applicant revised LRA Subsection A.1.1.38 to read: (5) address corrective actions, to be implemented through the Corrective Action Program, for components that have exceeded alarm limits, with options to include a revised fatigue analysis or repair or replacement of the component. In addition, the applicant revised the enhancement for corrective actions of this program by adding the following sentence:  Corrective actions if required will be implemented through the HNP Corrective Action Program. The staff reviewed the revisions and finds the clarification and LRA changes will ensure management of components approaching design limits. On this basis, the staff finds the applicants proposed enhancement acceptable.
Operating Experience. LRA Section B.3.1 states that review of NRC information notices, bulletins, and generic letters, and the INPO operating experience database found no applicable operating experience with fatigue monitoring or exceeding fatigue design limits since January 1995. The program has been effective in tracking the high-fatigue usage components so they remain below the 1.0 design limit. Fatigue evaluation of the most limiting locations (e.g.,
pressurizer surge line, pressurizer lower head, surge line hot leg nozzle, surge line cold leg nozzle, and chemical and volume control system cold leg normal charging nozzle) showed that the calculated environmentally-adjusted cumulative usage factor would remain below the 1.0 design limit for the period of extended operation.
By letter dated August 31, 2007, the applicant amended its LRA by removing the last sentence of the operating experience section. The staff reviewed the change and finds it acceptable as the sentence relating to future performance is irrelevant to operating experience.
During the audit, the staff asked the application how it documents the periodic updates as well as how these updates undergo peer review.
In its response, the applicant stated that The current (prior to enhancement) HNP Fatigue Monitoring Program requires signatures by the Shift Technical Advisor and the Superintendent, Shift 3-160
 
Operations. The Shift Technical Advisor is responsible for the monthly evaluation of cyclic and transient data and the Superintendent, Shift Operations reviews the evaluation and cycle logs and forwards to document services to be stored as permanent records. Operations personnel provide an internal peer review to verify the monthly evaluations have been correctly completed.
The staff reviewed the response and finds that the applicants current documentation procedures adequately account for transients.
On the basis of this review, the staff finds the applicants proposed enhancement acceptable.
The staff confirmed that the operating experience program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program element acceptable.
FSAR Supplement. In LRA Section A.1.1.38, the applicant provided the FSAR supplement for the Reactor Coolant Pressure Boundary Fatigue Monitoring Program. The staff reviewed this section and its changes made by the applicants amendment letter dated August 31, 2007, and determines that the information in the FSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicants Reactor Coolant Pressure Boundary Fatigue Monitoring Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. Also, the staff reviewed the enhancements and confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the FSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.3 AMPs Not Consistent with or Not Addressed in the GALL Report In LRA Appendix B, the applicant identified no AMPs as plant-specific; however, during the audit and review, the staff questioned the adequacy of aging management for the high-voltage power cables. SER Section 3.6.2.3.1 documents details of the staff's evaluation.
In its response dated August 20, 2007, the applicant amended the LRA to include a plant-specific AMP. The following section documents the staffs evaluation of the applicants Oil-Filled Cable Testing Program.
3.0.3.3.1 Oil-Filled Cable Testing Program During the audit and review, the staff questioned the applicants lack of an AMP for the 3-161
 
high-voltage oil-filled cables.
In its response dated August 20, 2007, the applicant amended the LRA with Section B.2.38, Oil-Filled Cable Testing Program. This program will be implemented prior to the period of extended operation (Commitment No. 34 - HNP-07-112 dated August 20, 2007).
Summary of Technical Information in the Application. The LRA credits the Oil-Filled Cable Testing Program for aging management of the high-voltage, oil-filled cables which connect the 230KV switchyard to the startup transformers. Periodic cable testing will proceed at least every four years to indicate the condition of the cable insulation properties. The specific test type (e.g., power factor (Doble), partial discharge, polarization index) to be determined prior to the initial test will be proven for detecting deterioration of the insulation system or other state-of-the-art testing at the time. The program will verify management of the effects of aging from a loss of dielectric strength caused by thermal/thermoxidative degradation of organics, radiation-induced oxidation (radiolysis) of organics, voltage (partial discharge), moisture, or the presence of other impurities during the period of extended operation.
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed LRA Section B.2.38, Oil-Filled Cable Testing Program, and information in LRA Amendment 1, , Attachment 2 to the letter dated August 20, 2007, for adequate management of the effects of aging to maintain intended function(s) consistent with the CLB for the period of extended operation. The audit team reviewed the applicants AMP against the AMP elements of the SRP-LR Section A.1.2.3 and SRP-LR Table 1-1 as follows:
(1)    Scope of the Program - The scope of the program program element criterion in SRP-LR Section A.1.2.3.1 requires that the program scope include the specific structures and components addressed by this program.
LRA Section B.2.38 states for the scope of the program program element that this program addresses high-voltage oil-filled cables which connect the 230KV switchyard to the startup transformers.
The staff determined that the LRA indicates the specific components (high-voltage oil-filled cables) for which the program manages aging effects, satisfying SRP-LR Section A.1.2.3.1. On this basis, the staff finds the applicants scope of the program acceptable.
The staff confirmed that the scope of the program program element satisfies the criterion defined in SRP-LR Section A.1.2.3.1. The staff concludes that this program element is acceptable.
(2)    Preventive Actions - The preventive actions program element criterion of SRP-LR Section A.1.2.3.2 is that condition monitoring programs do not rely on preventive actions so preventive actions need not be provided.
LRA Section B.2.38 states for the preventive actions program element, that this 3-162
 
program monitors conditions; therefore, it takes no actions to prevent or mitigate aging degradation.
The staff determined that the preventive actions program element satisfies the criterion defined in SRP-LR Section B.1.2.3.2 because in this condition monitoring program there is no need for preventive actions. On this basis, the staff finds the applicants preventive actions program element acceptable.
(3) Parameters Monitored or Inspected - The parameters monitored or inspected program element criteria in SRP-LR Section A.1.2.3.3 are:
The parameter to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s). The parameter monitored or inspected should detect the presence and extent of aging effects.
LRA Section B.2.38 states for the parameters monitored or inspected program element that the specific test type (e.g., power factor (Doble), partial discharge, polarization index) to be determined prior to the initial test will be proven for detecting deterioration of the insulation system or other state-of-the-art testing at the time.
The parameters monitored include a loss of dielectric strength caused by thermal/
thermoxidative degradation of organics, radiation-induced oxidation (radiolysis) of organics, voltage (partial discharge), moisture, or the presence of other impurities.
The staff determined that the parameters monitored or inspected program element satisfies the SRP-LR Section A.1.2.3.3 criteria. Loss of dielectric strength leading to reduced IR and electrical failure are potential aging effects due to thermal/thermoxidative degradation of organics, radiation-induced oxidation (radiolysis) of organics, voltage (partial discharge), moisture, or the presence of other impurities.
The HNP cables are high-voltage, oil-filled, paper-insulated, lead-sheathed, and designed for submergence for extended periods. Impregnation of the paper tape improves the insulation's electrical resistance and adds an extra layer of defense against moisture ingress. Plant-specific and industry operating experience show this design to be extremely reliable in underground applications. Periodic cable testing will assure management of the effects of aging during the period of extended operation. On this basis, the staff finds the applicants parameters monitored or inspected program element acceptable.
(4) Detection of Aging Effects - The detection of aging effects program element criteria in SRP-LR Section A.1.2.3.4 are:
Provide information that links the parameters to be monitored or inspected to the aging effects being managed.
Describe when, where, and how program data are collected (i.e.,
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all aspects of activities to collect data as part of the program)
Link the method for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.
LRA Section B.2.38 states for the detection of aging effects program element, that the high-voltage, oil-filled cables within the scope of this program will be tested at least every four years, an adequate period to detect aging effects before a loss of component intended function as experience shows that aging degradation is a slow process. A four-year testing interval will provide during a 20-year period multiple data points which can characterize the degradation rate. The first tests for license renewal will be completed prior to the period of extended operation.
The staff determined that this program element satisfies the criteria defined in SRP-LR Section A.1.2.3.4. The staff also determined that the cable manufacturer's operating experience data indicate that lead sheath cables are designed for submergence for extended periods. The impregnation of the paper tape improves the insulation's electrical resistance and adds an extra layer of defense against moisture ingress.
Plant-specific and industry operating experience also show this design to be extremely reliable in underground applications. As the degradation mechanism is a slow process, a four-year testing interval is adequate to monitor any potential cable degradation. During the period of extended operation, multiple data points will be available to monitor the degradation rate. On this basis, the staff finds the applicants detection of aging effects program element acceptable.
(5) Monitoring and Trending - The monitoring and trending program element criteria in SRP-LR Section A Section A.1.2.3.5 are:
Monitoring and trending activities should be described, and they should provide predictability of the extend of degradation and thus effect timely corrective or mitigative actions.
This program element should describe how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.
LRA Section B.2.38 states for the monitoring and trending program element that trending actions are not included; however, trending of discrepancies (as required) is under the Corrective Action Program implemented by the HNP QA program in accordance with 10 CFR 50, Appendix B.
The staff determined that absence of trending for testing is acceptable because the test is periodic and the applicant's Corrective Action Program corrects any unacceptable 3-164
 
equipment performance. On this basis, the staff finds the applicants monitoring and trending program element acceptable.
The staff confirmed that the monitoring and trending program element satisfies the criterion defined in SRP-LR Section A.1.2.3.5 and concludes that this program element is acceptable.
(6) Acceptance Criteria - The acceptance criteria program element criteria in SRP-LR Section A.1.2.3.6 are:
The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the SC intended function(s) are maintained under all CLB design conditions during the period of extended operation.
LRA Section B.2.38 states for the acceptance criteria program element that acceptance criteria will be based on the test for this program. Acceptance criteria ensure maintenance of intended functions of the cables consistent with the CLB.
The staff determined that this program element satisfies the criteria defined in SRP-LR Section A.1.2.3.6. The staff finds it acceptable on the basis that acceptance criteria are based on the specific type of test for the cables. The applicant will follow current industry standards and vendor recommendations which, when implemented, will maintain the license renewal intended functions of the cable connections consistent with the CLB.
(7) Corrective Actions - SER Section 3.0.4 addresses the adequacy of the applicants 10 CFR 50, Appendix B Program for this program element.
The staff reviewed this program element to determine whether it satisfies the criteria defined in SRP-LR Section A.1.2.3.7. The staff found the requirements of 10 CFR Part 50, Appendix B, acceptable for corrective action. On this basis, the staff finds the applicants corrective actions program element acceptable.
(8) Confirmation Process - SER Section 3.0.4 addresses the adequacy of the applicants 10 CFR 50, Appendix B Program for this program element.
The staff reviewed this program to determine whether it satisfies the criteria defined in SRP-LR Section A.1.2.3.8.The staff found the requirements of 10 CFR Part 50, Appendix B, acceptable for the confirmation process. On this basis, the staff finds the applicants confirmation process program element acceptable.
(9) Administrative Controls - SER Section 3.0.4 addresses the adequacy of the applicants 10 CFR Part 50, Appendix B Program for this program element.
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The staff reviewed this program element to determine whether it satisfies the criteria defined in SRP-LR Section A.1.2.3.9. The staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable for administrative controls.
(10) Operating Experience - The operating experience program element criterion in SRP-LR Section A.1.2.3.10 that operating experience should be objective evidence of adequate management of the effects of aging to maintain structure and component intended functions during the period of extended operation.
LRA Section B.2.38 states for the operating experience program element that there is no plant-specific operating experience for this new program. Development of this program considered plant-specific and industry operating experience. This review confirms the reliability of high-voltage, oil-filled cables in underground applications; however, periodic cable testing will assure management of the effects of aging during the period of extended operation. HNP corrective action and operating experience programs will record operating experience in accordance with corporate procedures.
This ongoing review of operating experience will continue throughout the period of extended operation with the results maintained on site. The administrative controls that implement the Corrective Action and Operating Experience Programs are in accordance with the QA program in conformance with 10 CFR 50, Appendix B. These controls will verify continued program effectiveness in the management of aging effects.
Based on review of plant-specific corrective action documents and industry operating experience, the staff determined that the high-voltage, oil-filled cables in underground applications are highly reliable with no instances of cable degradation. The staff also determined that periodic cable testing will assure management of the effects of aging and that ongoing review of operating experience and the corrective action program will continue throughout the period of extended operation. On these bases, the staff finds the applicants operating experience program element acceptable.
The staff confirmed that the operating experience program element satisfies the criterion defined in SRP-LR Section A.1.2.3.10 and found this program element acceptable.
FSAR Supplement. The applicants FSAR supplement for the Oil-Filled Cable Testing Program is in the supplemental LRA Section A.1.1.40, which states that the Oil-Filled Cable Testing Program assures management of the aging effect of loss of dielectric strength so oil-filled cables perform intended functions for the period of extended operation.
The staff reviewed the applicants license renewal commitment list in LRA Amendment No. 1 dated August 20, 2007, and confirmed that this new program is Commitment No. 34 to be implemented before the period of extended operation. The staff reviewed LRA Appendix A.1.1.40 and determined that the information in the FSAR supplement is an adequate summary description of the program as required by 10 CFR 54.21(d).
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Conclusion. On the basis of its technical review of the applicants Oil-Filled Cable Testing Program, the staff concludes that the applicant has demonstrated adequate program management of the effects of aging to maintain intended functions consistent with the CLB for the period of extended operation as required by 10 CFR 54.21(a)(3).The staff also reviewed the FSAR supplement for this AMP and concludes that, with Commitment No. 34, it is an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.4 QA Program Attributes Integral to Aging Management Programs Pursuant to 10 CFR 54.21(a)(3), the applicant is required to demonstrate that the effects of aging on SCs subject to an AMR will be adequately managed so that their intended function(s) will be maintained consistent with the CLB for the period of extended operation. SRP-LR Branch Technical Position (BTP) RLSB-1, Aging Management Review - Generic, describes ten elements of an acceptable AMP. Elements (7), (8), and (9) are associated with the QA activities of corrective actions, confirmation process, and administrative controls.
BTP RLSB-1 Table A.1-1, Elements of an Aging Management Program for License Renewal, provides the following description of these program elements:
(7)    Corrective Actions - Corrective actions, including root cause determination and prevention of recurrence, should be timely.
(8)    Confirmation Process - The confirmation process should ensure that preventive actions are adequate and that appropriate corrective actions are completed and effective.
(9)    Administrative Controls - Administrative controls should provide for a formal review and approval process.
BTP IQMB-1, Quality Assurance for Aging Management Programs, notes that AMP aspects that affect the quality of safety-related SSCs are subject to the QA requirements of 10 CFR Part 50 Appendix B. Additionally, for nonsafety-related SCs subject to an AMR, the applicant may use the existing 10 CFR Part 50 Appendix B QA program to address the elements of corrective actions, confirmation process, and administrative controls.
BTP IQMB-1 provides the following guidance on the QA attributes of AMPs:
* Safety-related SCs are subject to 10 CFR Part 50 Appendix B requirements which are adequate to address all quality-related aspects of an AMP consistent with the CLB of the facility for the period of extended operation.
* For nonsafety-related SCs that are subject to an AMR, an applicant has an option to expand the scope of its 10 CFR Part 50 Appendix B program to include these SCs to address corrective action, confirmation process, and administrative controls for aging management during the period of extended operation. In this case, the applicant should document such commitment in the FSAR supplement in accordance with 10 CFR 54.21(d).
3.0.4.1 Summary of Technical Information in the Application LRA Section B.1.3, Quality Assurance Program and Administrative Controls, describes the elements of corrective action, confirmation process, and administrative controls applied to the 3-167
 
AMPs for both safety-related and nonsafety-related components. The HNP QA program, described in FSAR Section 17.3, implements the requirements of 10 CFR Part 50, Appendix B.
The Corrective Action Program applies corrective actions, confirmation, and administrative controls regardless of component safety classification. Specifically, LRA Section B.1.3 states that the QA program implements the requirements of 10 CFR Part 50, Appendix B. LRA Section B.2, Aging Management Programs, summarizes the AMPs.
3.0.4.2 Staff Evaluation The staff reviewed the applicants AMPs as described in LRA Appendix A, Final Safety Analysis Report Supplement, and LRA Appendix B, Aging Management Programs, and each AMP basis document for consistency in the use of the QA attributes for each program. This review was for the aging management consistent with staff guidance of SRP-LR Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1).
The staffs evaluation determined that the descriptions and applicability of plant-specific AMPs and their quality attributes described in LRA Section B1.3 were generally consistent with the staff position on QA for aging management; however, the AMP program description B2.8 in LRA Appendix B refers to Exceptions to NUREG 1801" and indicates and exception to the corrective actions area with, however, no indication or description of the use of any alternative method to the HNP 10 CFR Part 50, Appendix B QA Program.
The staffs review of LRA Section B.1.3 found an area in which additional information was necessary to complete the review of the applicants program elements. The applicant responded to the staffs RAI as discussed below.
In RAI 3.0-1 dated June 11, 2007, the staff requested from the applicant the following information to address these issues:
* A supplement to the description in LRA Section A1 clearly indicating application of the 10 CFR Part 50, Appendix B, QA program or an alternative for the corrective action, confirmation process, and administrative controls elements of each program.
Describe any alternative approaches to the application of the 10 CFR Part 50, Appendix B, QA program in sufficient detail for the staff to determine whether the quality attributes for the AMPs are consistent with the review acceptance criteria of NUREG-1800, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1).
* For AMPs described in LRA Appendix B taking exceptions to corrective actions, confirmation process, or administrative controls, indicate whether the exceptions include an alternative to the application of the HNP 10 CFR Part 50, Appendix B QA program as described in Section B.1.3. Describe any alternative approaches in sufficient detail for the staff to determine whether the quality attributes for the AMPs are consistent with the review acceptance criteria of NUREG-1800, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1).
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In its response dated July 10, 2007, the applicant indicated that the exception to corrective actions for the Bolting Integrity Program was to indicate the difference in the ASME Code edition specified in the GALL Report and the edition of record which the applicant has committed to use. The Bolting Integrity Program will apply the HNP QA program and the requirements of 10 CFR Part 50, Appendix B, to the area of corrective actions as stated in LRA Section B.1.3.
Based on its review, the staff finds the applicants commitment to apply 10 CFR Part 50, Appendix B, to corrective actions for the Bolting Integrity Program acceptable. The staffs concern described in RAI 3.0-1 is resolved.
3.0.4.3 Conclusion The staffs evaluation found the descriptions and applicability of the plant-specific AMPs and their quality attributes described in LRA Sections B.1.3 and B.2 and the RAI response consistent with the staff position on QA for aging management. The staff concludes that the QA attributes (corrective action, confirmation process, and administrative controls) of the applicant's AMPs are consistent with 10 CFR 54.21(a)(3).
3.1 Aging Management of Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System This section of the SER documents the staffs review of the applicants AMR results for the reactor vessel, reactor vessel internals (RVI), and reactor coolant system components and component groups of:
* reactor vessel and internals
* incore instrumentation system
* reactor coolant system
* reactor coolant pump and motor
* pressurizer
* steam generator 3.1.1 Summary of Technical Information in the Application LRA Section 3.1 provides AMR results for the reactor vessel, RVI, and reactor coolant system components and component groups. LRA Table 3.1.1, Summary of Aging Management Evaluations in Chapter IV of NUREG-1801 for Reactor Vessels, Internals, and Reactor Coolant System, is a summary comparison of the applicants AMRs with those evaluated in the GALL Report for the reactor vessel, RVI, and reactor coolant system components and component groups.
The applicants AMRs evaluated and incorporated applicable plant-specific and industry operating experience in the determination of AERMs. The plant-specific evaluation included condition reports and discussions with appropriate site personnel to identify AERMs. The 3-169
 
applicants review of industry operating experience included a review of the GALL Report and operating experience issues identified since the issuance of the GALL Report.
3.1.2 Staff Evaluation The staff reviewed LRA Section 3.1 to determine whether the applicant provided sufficient information to demonstrate that the effects of aging for the reactor vessel, RVI, and reactor coolant system components within the scope of license renewal and subject to an AMR will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
The staff conducted an onsite audit of AMRs to verify the applicants claim that certain AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters described in the GALL Report; however, the staff did verify that the material presented in the LRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The staffs evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs audit evaluation are documented in SER Section 3.1.2.1.
In the onsite audit, the staff also selected AMRs consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicants further evaluations were consistent with the SRP-LR Section 3.1.2.2 acceptance criteria. The staffs audit evaluations are documented in SER Section 3.1.2.2.
The staff also conducted a technical review of the remaining AMRs not consistent with or not addressed in the GALL Report. The technical review evaluated whether all plausible aging effects have been identified and whether the aging effects listed were appropriate for the material-environment combinations specified. The staffs evaluations are documented in SER Section 3.1.2.3.
For SSCs which the applicant claimed were not applicable or required no aging management, the staff reviewed the AMR line items and the plants operating experience to verify the applicants claims.
Table 3.1-1 summarizes the staffs evaluation of components, aging effects or mechanisms, and AMPs listed in LRA Section 3.1 and addressed in the GALL Report.
Table 3.1-1 Staff Evaluation for Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System Components in the GALL Report 3-170
 
Component Group      Aging Effect/    AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL        or Report    Amendments Steel pressure        Cumulative    TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA vessel support skirt  fatigue damage accordance with                                (See SER and attachment                      10 CFR 54.21(c)                                Section 3.1.2.2.1) welds (3.1.1-1)
Steel; stainless      Cumulative    TLAA, evaluated in  Yes        Not applicable Not applicable to steel; steel with    fatigue damage accordance with                                PWRs (See SER nickel-alloy or                      10 CFR 54.21(c)                                Section 3.1.2.2.1) stainless steel                      and environmental cladding;                            effects are to be nickel-alloy reactor                addressed for vessel components:                  Class 1 components flanges; nozzles; penetrations; safe ends; thermal sleeves; vessel shells, heads and welds (3.1.1-2)
Steel; stainless      Cumulative    TLAA, evaluated in  Yes        Not applicable Not applicable to steel; steel with    fatigue damage accordance with                                PWRs (See SER nickel-alloy or                      10 CFR 54.21(c)                                Section 3.1.2.2.1) stainless steel                      and environmental cladding;                            effects are to be nickel-alloy reactor                addressed for coolant pressure                    Class 1 components boundary piping, piping components, and piping elements exposed to reactor coolant (3.1.1-3)
Steel pump and        Cumulative    TLAA, evaluated in  Yes        Not applicable Not applicable to valve closure bolting fatigue damage accordance with                                PWRs (See SER (3.1.1-4)                            10 CFR 54.21(c)                                Section 3.1.2.2.1) check Code limits for allowable cycles (less than 7000 cycles) of thermal stress range Stainless steel and  Cumulative    TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA nickel alloy reactor  fatigue damage accordance with                                (See SER vessel internals                    10 CFR 54.21(c)                                Section 3.1.2.2.1) components (3.1.1-5) 3-171
 
Component Group      Aging Effect/    AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism          Report        Evaluation  Supplements, Item No.)                                            in GALL        or Report    Amendments Nickel Alloy tubes    Cumulative    TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA and sleeves in a      fatigue damage accordance with                              (See SER reactor coolant and                  10 CFR 54.21(c)                              Section 3.1.2.2.1) secondary feedwater/steam environment (3.1.1-6)
Steel and stainless  Cumulative    TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA steel reactor coolant fatigue damage accordance with                              (See SER pressure boundary                    10 CFR 54.21(c)                              Section 3.1.2.2.1) closure bolting, head closure studs, support skirts and attachment welds, pressurizer relief tank components, steam generator components, piping and components external surfaces and bolting (3.1.1-7)
Steel; stainless      Cumulative    TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA steel; and            fatigue damage accordance with                              (See SER nickel-alloy reactor                10 CFR 54.21(c)                              Section 3.1.2.2.1) coolant pressure                    and environmental boundary piping,                    effects are to be piping components,                  addressed for piping elements;                    Class 1 components flanges; nozzles and safe ends; pressurizer vessel shell heads and welds; heater sheaths and sleeves; penetrations; and thermal sleeves (3.1.1-8) 3-172
 
Component Group      Aging Effect/      AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report      Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL        or Report    Amendments Steel; stainless    Cumulative      TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA steel; steel with    fatigue damage  accordance with                                (See SER nickel-alloy or                      10 CFR 54.21(c)                                Section 3.1.2.2.1) stainless steel                      and environmental cladding;                            effects are to be nickel-alloy reactor                  addressed for vessel components:                    Class 1 components flanges; nozzles; penetrations; pressure housings; safe ends; thermal sleeves; vessel shells, heads and welds (3.1.1-9)
Steel; stainless    Cumulative      TLAA, evaluated in  Yes        TLAA          Fatigue is a TLAA steel; steel with    fatigue damage  accordance with                                (See SER nickel-alloy or                      10 CFR 54.21(c)                                Section 3.1.2.2.1) stainless steel                      and environmental cladding;                            effects are to be nickel-alloy steam                    addressed for generator                            Class 1 components components (flanges; penetrations; nozzles; safe ends, lower heads and welds)
(3.1.1-10)
Steel top head      Loss of material Water Chemistry      Yes        Not applicable Not applicable to enclosure (without  due to general, and One-Time                                    PWRs (See SER cladding) top head  pitting and      Inspection                                    Section 3.1.2.2.2.1) nozzles (vent, top  crevice head spray or RCIC,  corrosion and spare) exposed to reactor coolant (3.1.1-11)
Steel steam          Loss of material Water Chemistry      Yes        Not applicable Not applicable to generator shell      due to general, and One-Time                                    HNP assembly exposed    pitting and      Inspection                                    (See SER to secondary        crevice                                                        Section 3.1.2.2.2.1) feedwater and        corrosion steam (3.1.1-12) 3-173
 
Component Group        Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report          Mechanism            Report        Evaluation  Supplements, Item No.)                                                in GALL          or Report    Amendments Steel and stainless    Loss of material Water Chemistry      Yes        Not applicable Not applicable to steel isolation        due to general  and One-Time                                    PWRs (See SER condenser              (steel only),    Inspection                                      Section 3.1.2.2.2.2) components            pitting and exposed to reactor    crevice coolant                corrosion (3.1.1-13)
Stainless steel,      Loss of material Water Chemistry      Yes        Not applicable Not applicable to nickel-alloy, and      due to pitting  and One-Time                                    PWRs (See SER steel with            and crevice      Inspection                                      Section 3.1.2.2.2.3) nickel-alloy or        corrosion stainless steel cladding reactor vessel flanges,
: nozzles, penetrations, safe ends, vessel shells, heads and welds (3.1.1-14)
Stainless steel; steel Loss of material Water Chemistry      Yes        Not applicable Not applicable to with nickel-alloy or  due to pitting  and One-Time                                    PWRs (See SER stainless steel        and crevice      Inspection                                      Section 3.1.2.2.2.3) cladding; and          corrosion nickel-alloy reactor coolant pressure boundary components exposed to reactor coolant (3.1.1-15)
Steel steam            Loss of material Inservice            Yes        ASME          Consistent with the generator upper and    due to general,  Inspection (IWB,                Section XI    GALL Report with lower shell and        pitting and      IWC, and IWD), and              Inservice      exception transition cone        crevice          Water Chemistry                  Inspection,    (See SER exposed to            corrosion        and, for                        Subsections    Section 3.1.2.2.2.4) secondary                              Westinghouse                    IWB, IWC, and feedwater and                          Model 44 and                    IWD (B2.1) and steam                                  51 S/G, if general              Water (3.1.1-16)                              and pitting corrosion            Chemistry of the shell is known            (B2.2) to exist, additional inspection procedures are to be developed.
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Component Group        Aging Effect/    AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report          Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Steel (with or        Loss of fracture TLAA, evaluated in  Yes        TLAA          Loss of fracture without stainless    toughness due    accordance with                                toughness is a steel cladding)      to neutron      10 CFR 50,                                    TLAA reactor vessel        irradiation      Appendix G, and                                (See SER beltline shell,      embrittlement    RG 1.99. The                                  Section 3.1.2.2.3.1) nozzles, and welds                    applicant may (3.1.1-17)                            choose to demonstrate that the materials of the nozzles are not controlling for the TLAA evaluations.
Steel (with or        Loss of fracture Reactor Vessel      Yes        Reactor Vessel Consistent with the without stainless    toughness due    Surveillance                    Surveillance  GALL Report steel cladding)      to neutron                                      (B2.1.17)      (See SER reactor vessel        irradiation                                                    Section 3.1.2.2.3.2) beltline shell,      embrittlement nozzles, and welds; safety injection nozzles (3.1.1-18)
Stainless steel and  Cracking due to  A plant-specific    Yes        Not applicable Not applicable to nickel alloy top head stress corrosion aging management                              PWRs (See SER enclosure vessel      cracking and    program is to be                              Section 3.1.2.2.4.1) flange leak          intergranular    evaluated.
detection line        stress corrosion (3.1.1-19)            cracking Stainless steel      Cracking due to  Inservice            Yes        Not applicable Not applicable to isolation condenser  stress corrosion Inspection (IWB,                              PWRs (See SER components            cracking and    IWC, and IWD),                                Section 3.1.2.2.4.2) exposed to reactor    intergranular    Water Chemistry, coolant              stress corrosion and plant-specific (3.1.1-20)            cracking        verification program Reactor vessel shell Crack growth      TLAA                Yes        Not applicable Not applicable to fabricated of        due to cyclic                                                  HNP (See SER SA508-Cl 2 forgings loading                                                          Section 3.1.2.2.5) clad with stainless steel using a high-heat-input welding process (3.1.1-21) 3-175
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Stainless steel and  Loss of fracture FSAR supplement      No        FSAR          Consistent with the nickel alloy reactor toughness due    commitment to                  Supplement    GALL Report vessel internals    to neutron      (1) participate in              Section A.1.1  (See SER components          irradiation      industry RVI aging                            Section 3.1.2.2.6) exposed to reactor  embrittlement,  programs coolant and neutron  void swelling    (2) implement flux                                  applicable results (3.1.1-22)                            (3) submit for NRC approval > 24 months before the extended period an RVI inspection plan based on industry recommendation.
Stainless steel      Cracking due to A plant-specific      Yes        Water          Consistent with the reactor vessel      stress corrosion aging management                Chemistry      GALL Report closure head flange  cracking        program is to be                (B2.2) and    (See SER leak detection line                  evaluated.                      One-Time      Section 3.1.2.2.7.1) and                                                                  Inspection bottom-mounted                                                        (B.2.18) instrument guide tubes (3.1.1-23)
Class 1 cast        Cracking due to Water Chemistry      Yes        ASME          Consistent with the austenitic stainless stress corrosion and, for CASS                  Section XI    GALL Report steel piping, piping cracking        components that do              Inservice      (See SER components, and                      not meet the                    Inspection,    Section 3.1.2.2.7.2) piping elements                      NUREG-0313                      Subsections exposed to reactor                    guidelines, a                  IWB, IWC, and coolant                              plant-specific AMP              IWD (B2.1) and (3.1.1-24)                                                            Water Chemistry (B.2.2)
Stainless steel jet  Cracking due to A plant-specific      Yes        Not applicable Not applicable to pump sensing line    cyclic loading  aging management                              PWRs (See SER (3.1.1-25)                            program is to be                              Section 3.1.2.2.8.1) evaluated.
Steel and stainless  Cracking due to Inservice            Yes        Not applicable Not applicable to steel isolation      cyclic loading  Inspection (IWB,                              PWRs (See SER condenser                            IWC, and IWD) and                              Section 3.1.2.2.8.2) components                            plant-specific exposed to reactor                    verification program coolant (3.1.1-26) 3-176
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Stainless steel and  Loss of preload  FSAR supplement      No        FSAR          Consistent with the nickel alloy reactor due to stress    commitment to                  Supplement    GALL Report vessel internals    relaxation      (1) participate in              Section A.1.1  (See SER screws, bolts, tie                    industry RVI aging                            Section 3.1.2.2.9) rods, and hold-down                  programs springs                              (2) implement (3.1.1-27)                            applicable results (3) submit for NRC approval > 24 months before the extended period an RVI inspection plan based on industry recommendation.
Steel steam          Loss of material A plant-specific    Yes        One-Time      Consistent with the generator feedwater  due to erosion  aging management                Inspection    GALL Report impingement plate                    program is to be                (B.2.18)      (See SER and support                          evaluated.                                    Section 3.1.2.2.10) exposed to secondary feedwater (3.1.1-28)
Stainless steel      Cracking due to A plant-specific      Yes        Not applicable Not applicable to steam dryers        flow-induced    aging management                              PWRs (See SER exposed to reactor  vibration        program is to be                              Section 3.1.2.2.11) coolant                              evaluated.
(3.1.1-29) 3-177
 
Component Group        Aging Effect/      AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Stainless steel      Cracking due to  Water Chemistry      No        Water        Consistent with the reactor vessel        stress corrosion  and FSAR                        Chemistry    GALL Report internals            cracking,        supplement                      (B.2.2) and  (See SER components            irradiation-assis commitment to                  FSAR          Section 3.1.2.2.12)
(e.g., Upper          ted stress        (1) participate in              Supplement internals assembly,  corrosion        industry RVI aging              Section A.1.1 RCCA guide tube      cracking          programs assemblies,                            (2) implement Baffle/former                          applicable results assembly, Lower                        (3) submit for NRC internal assembly,                      approval > 24 shroud assemblies,                      months before the Plenum cover and                        extended period an plenum cylinder,                        RVI inspection plan Upper grid                              based on industry assembly, Control                      recommendation.
rod guide tube (CRGT) assembly, Core support shield assembly, Core barrel assembly, Lower grid assembly, Flow distributor assembly, Thermal
: shield, Instrumentation support structures)
(3.1.1-30)
Nickel alloy and      Cracking due to  Inservice            No        ASME          Consistent with the steel with            primary water    Inspection (IWB,                Section XI    GALL Report nickel-alloy cladding stress corrosion  IWC, and IWD) and              Inservice    (See SER piping, piping        cracking          Water Chemistry                Inspection,  Section 3.1.2.2.13) component, piping                      and FSAR                        Subsections elements,                              supplement                      IWB, IWC, and penetrations,                          commitment to                  IWD (B2.1),
nozzles, safe ends,                    implement                      Water and welds (other                        applicable plant                Chemistry than reactor vessel                    commitments to                  (B.2.2), and head); pressurizer                      (1) NRC Orders,                FSAR heater sheaths,                        Bulletins, and                  Supplement sleeves, diaphragm                      Generic Letters                Section A.1.2 plate, manways and                      associated with flanges; core                          nickel alloys and support pads/core                      (2) staff-accepted guide lugs                              industry guidelines.
(3.1.1-31)
Steel steam          Wall thinning    A plant-specific    Yes        One-Time      Consistent with the generator feedwater  due to            aging management                Inspection    GALL Report inlet ring and        flow-accelerate  program is to be                (B.2.18)      (See SER supports              d corrosion      evaluated.                                    Section 3.1.2.2.14)
(3.1.1-32) 3-178
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Stainless steel and  Changes in      FSAR supplement      No        FSAR          Consistent with the nickel alloy reactor  dimensions due commitment to                      Supplement    GALL Report vessel internals      to void swelling (1) participate in              Section A.1.1  (See SER components                            industry RVI aging                              Section 3.1.2.2.15)
(3.1.1-33)                            programs (2) implement applicable results (3) submit for NRC approval > 24 months before the extended period an RVI inspection plan based on industry recommendation.
Stainless steel and  Cracking due to  Inservice            No        ASME          Consistent with the nickel alloy reactor  stress corrosion Inspection (IWB,                Section XI    GALL Report control rod drive    cracking and    IWC, and IWD) and                Inservice      (See SER head penetration      primary water    Water Chemistry                  Inspection,    Section 3.1.2.2.16.1 pressure housings    stress corrosion and for nickel alloy,            Subsections    )
(3.1.1-34)            cracking        comply with                      IWB, IWC, and applicable NRC                  IWD (B.2.1)
Orders and provide              and a commitment in the              Water FSAR supplement                  Chemistry to implement                    (B.2.2) applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.
Steel with stainless  Cracking due to  Inservice            No        Not applicable Not applicable to steel or nickel alloy stress corrosion Inspection (IWB,                                HNP (See SER cladding primary      cracking and    IWC, and IWD) and                              Section 3.1.2.2.16.1 side components;      primary water    Water Chemistry                                )
steam generator      stress corrosion and for nickel alloy, upper and lower      cracking        comply with heads, tubesheets                      applicable NRC and tube-to-tube                      Orders and provide sheet welds                            a commitment in the (3.1.1-35)                            FSAR supplement to implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.
3-179
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Nickel alloy,        Cracking due to  Water Chemistry      No        Water          Consistent with the stainless steel      stress corrosion  and One-Time                    Chemistry      GALL Report pressurizer spray    cracking and      Inspection and, for            (B2.2) and    (See SER head                primary water    nickel alloy welded            One-Time      Section 3.1.2.2.16.2 (3.1.1-36)          stress corrosion  spray heads,                    Inspection    )
cracking          comply with                    (B.2.18) applicable NRC Orders and provide a commitment in the FSAR supplement to implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.
Stainless steel and  Cracking due to  Water Chemistry      No        Water          Consistent with the nickel alloy reactor stress corrosion  and FSAR                        Chemistry      GALL Report vessel internals    cracking,        supplement                      (B.2.2) and    (See SER components          primary water    commitment to                  FSAR          Section 3.1.2.2.17)
(e.g., Upper        stress corrosion  (1) participate in              Supplement internals assembly,  cracking,        industry RVI aging              Section A.1.1 RCCA guide tube      irradiation-assis programs assemblies, Lower    ted stress        (2) implement internal assembly,  corrosion        applicable results CEA shroud          cracking          (3) submit for NRC assemblies, Core                      approval > 24 shroud assembly,                      months before the Core support shield                    extended period an assembly, Core                        RVI inspection plan barrel assembly,                      based on industry Lower grid                            recommendation.
assembly, Flow distributor assembly)
(3.1.1-37)
Steel (with or      Cracking due to BWR Control Rod        No        Not applicable Not applicable to without stainless    cyclic loading    Drive Return Line                              PWRs steel cladding)                        Nozzle control rod drive return line nozzles exposed to reactor coolant (3.1.1-38)
Steel (with or      Cracking due to BWR Feedwater          No        Not applicable Not applicable to without stainless    cyclic loading    Nozzle                                        PWRs steel cladding) feedwater nozzles exposed to reactor coolant (3.1.1-39) 3-180
 
Component Group        Aging Effect/      AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report          Mechanism            Report      Evaluation Supplements, Item No.)                                              in GALL        or Report    Amendments Stainless steel and    Cracking due to BWR Penetrations    No        Not applicable Not applicable to nickel alloy          stress corrosion and Water                                    PWRs penetrations for      cracking,        Chemistry control rod drive      Intergranular stub tubes            stress corrosion instrumentation, jet  cracking, cyclic pump                  loading instrumentation, standby liquid control, flux monitor, and drain line exposed to reactor coolant (3.1.1-40)
Stainless steel and    Cracking due to  BWR Stress          No        Not applicable Not applicable to nickel alloy piping,  stress corrosion Corrosion Cracking                            PWRs piping components,    cracking and    and Water and piping elements    intergranular    Chemistry greater than or        stress corrosion equal to 4 NPS;        cracking nozzle safe ends and associated welds (3.1.1-41)
Stainless steel and    Cracking due to  BWR Vessel ID      No        Not applicable Not applicable to nickel alloy vessel    stress corrosion Attachment Welds                              PWRs shell attachment      cracking and    and Water welds exposed to      intergranular    Chemistry reactor coolant        stress corrosion (3.1.1-42)            cracking Stainless steel fuel  Cracking due to BWR Vessel          No        Not applicable Not applicable to supports and control  stress corrosion Internals and Water                          PWRs rod drive              cracking and    Chemistry assemblies control    intergranular rod drive housing      stress corrosion exposed to reactor    cracking coolant (3.1.1-43) 3-181
 
Component Group        Aging Effect/      AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation Supplements, Item No.)                                            in GALL        or Report    Amendments Stainless steel and  Cracking due to BWR Vessel            No        Not applicable Not applicable to nickel alloy core    stress corrosion Internals and Water                            PWRs shroud, core plate,  cracking,        Chemistry core plate bolts,    intergranular support structure,    stress corrosion top guide, core      cracking, spray lines,          irradiation-assis spargers, jet pump    ted stress assemblies, control  corrosion rod drive housing,    cracking nuclear instrumentation guide tubes (3.1.1-44)
Steel piping, piping  Wall thinning    Flow-Accelerated    No        Not applicable Not applicable to components, and      due to            Corrosion                                    PWRs piping elements      flow-accelerate exposed to reactor    d corrosion coolant (3.1.1-45)
Nickel alloy core    Cracking due to  Inservice          No        Not applicable Not applicable to shroud and core      stress corrosion  Inspection (IWB,                              PWRs plate access hole    cracking,        IWC, and IWD), and cover (mechanical    intergranular    Water Chemistry covers)              stress corrosion (3.1.1-46)            cracking, irradiation-assis ted stress corrosion cracking Stainless steel and  Loss of material  Inservice          No        Not applicable Not applicable to nickel-alloy reactor  due to pitting    Inspection (IWB,                              PWRs vessel internals      and crevice      IWC, and IWD), and exposed to reactor    corrosion        Water Chemistry coolant (3.1.1-47)
Steel and stainless  Cracking due to  Inservice          No        Not applicable Not applicable to steel Class 1 piping, stress corrosion  Inspection (IWB,                              PWRs fittings and branch  cracking,        IWC, and IWD),
connections          intergranular    Water chemistry,
< NPS 4 exposed to    stress corrosion  and One-Time reactor coolant      cracking (for    Inspection of ASME (3.1.1-48)            stainless steel  Code Class 1 only), and        Small-bore Piping thermal and mechanical loading 3-182
 
Component Group        Aging Effect/      AMP in GALL        Further  AMP in LRA,      Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Nickel alloy core    Cracking due to  Inservice            No        Not applicable    Not applicable to shroud and core      stress corrosion  Inspection (IWB,                                  PWRs plate access hole    cracking,        IWC, and IWD),
cover (welded        intergranular    Water Chemistry, covers)              stress corrosion  and, for BWRs with (3.1.1-49)            cracking,        a crevice in the irradiation-assis access hole covers, ted stress        augmented corrosion        inspection using UT cracking          or other demonstrated acceptable inspection of the access hole cover welds High-strength low    Cracking due to Reactor Head          No        Not applicable    Not applicable to alloy steel top head  stress corrosion Closure Studs                                      PWRs closure studs and    cracking and nuts exposed to air  intergranular with reactor coolant  stress corrosion leakage              cracking (3.1.1-50)
Cast austenitic      Loss of fracture  Thermal Aging and    No        Not applicable    Not applicable to stainless steel jet  toughness due    Neutron Irradiation                              PWRs pump assembly        to thermal        Embrittlement of castings; orificed    aging and        CASS fuel support          neutron (3.1.1-51)            irradiation embrittlement Steel and stainless  Cracking due to Bolting Integrity      No        Bolting Integrity Consistent with the steel reactor coolant stress corrosion                                  (B.2.8)          GALL Report pressure boundary    cracking, loss (RCPB) pump and      of material due valve closure        to wear, loss of bolting, manway      preload due to and holding bolting,  thermal effects, flange bolting, and  gasket creep, closure bolting in    and high-pressure and    self-loosening high-temperature systems (3.1.1-52)
Steel piping, piping  Loss of material Closed-Cycle          No        Closed-Cycle      Consistent with the components, and      due to general, Cooling Water                    Cooling Water    GALL Report piping elements      pitting and      System                          System (B.2.11) exposed to closed    crevice cycle cooling water  corrosion (3.1.1-53) 3-183
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism              Report      Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Copper alloy piping,  Loss of material Closed-Cycle        No        Not applicable Not applicable to piping components,    due to pitting,  Cooling Water                                  HNP (See SER and piping elements  crevice, and    System                                        Section 3.1.2.1.1) exposed to closed    galvanic cycle cooling water  corrosion (3.1.1-54)
Cast austenitic      Loss of fracture Inservice            No        ASME          Consistent with the stainless steel      toughness due    Inspection (IWB,                Section XI    GALL Report Class 1 pump          to thermal      IWC, and IWD).                  Inservice casings, and valve    aging            Thermal aging                  Inspection, bodies and bonnets    embrittlement    susceptibility                  Subsections exposed to reactor                    screening is not                IWB, IWC, and coolant > 250EC                        necessary, inservice            IWD (B.2.1)
(> 482EF)                              inspection (3.1.1-55)                            requirements are sufficient for managing these aging effects. ASME Code Case N-481 also provides an alternative for pump casings.
Copper alloy          Loss of material Selective Leaching  No        Not applicable Not applicable to
> 15% Zn piping,      due to selective of Materials                                  HNP (See SER piping components, leaching                                                          Section 3.1.2.1.1) and piping elements exposed to closed cycle cooling water (3.1.1-56)
Cast austenitic      Loss of fracture Thermal Aging        No        Not applicable Not applicable to stainless steel      toughness due    Embrittlement of                              HNP (See SER Class 1 piping,      to thermal      CASS                                          Section 3.1.2.1.1) piping component,    aging and piping elements  embrittlement and control rod drive pressure housings exposed to reactor coolant > 250EC
(> 482EF)
(3.1.1-57)
Steel reactor        Loss of material Boric Acid Corrosion No        Boric Acid    Consistent with the coolant pressure      due to boric                                    Corrosion      GALL Report boundary external    acid corrosion                                  (B.2.4) surfaces exposed to air with borated water leakage (3.1.1-58) 3-184
 
Component Group        Aging Effect/    AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report          Mechanism          Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Steel steam            Wall thinning    Flow-Accelerated    No        Flow-Accelerate Consistent with the generator steam        due to          Corrosion                      d Corrosion    GALL Report nozzle and safe        flow-accelerate                                (B.2.7) end, feedwater        d corrosion nozzle and safe end, AFW nozzles and safe ends exposed to secondary feedwater/steam (3.1.1-59)
Stainless steel flux  Loss of material Flux Thimble Tube  No        Flux Thimble    Consistent with the thimble tubes (with    due to wear      Inspection                    Tube Inspection GALL Report or without chrome                                                      (B.2.23) plating)
(3.1.1-60)
Stainless steel, steel Cracking due to Inservice            No        Not applicable  Not applicable to pressurizer integral cyclic loading    Inspection (IWB,                              HNP (See SER support exposed to                      IWC, and IWD)                                  Section 3.1.2.1.1) air with metal temperature up to 288EC (550EF)
(3.1.1-61)
Stainless steel, steel Cracking due to Inservice            No        Not applicable  Not applicable to with stainless steel  cyclic loading  Inspection (IWB,                              HNP (See SER cladding reactor                        IWC, and IWD)                                  Section 3.1.2.1.1) coolant system cold leg, hot leg, surge line, and spray line piping and fittings exposed to reactor coolant (3.1.1-62)
Steel reactor vessel Loss of material Inservice            No        ASME            Consistent with the flange, stainless      due to wear      Inspection (IWB,              Section XI      GALL Report steel and nickel                        IWC, and IWD)                  Inservice alloy reactor vessel                                                  Inspection, internals exposed to                                                  Subsections reactor coolant                                                        IWB, IWC, and (e.g., upper and                                                      IWD (B.2.1) lower internals assembly, CEA shroud assembly, core support barrel, upper grid assembly, core support shield assembly, lower grid assembly)
(3.1.1-63) 3-185
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Stainless steel and  Cracking due to  Inservice          No        ASME          Consistent with the steel with stainless  stress corrosion Inspection (IWB,              Section XI    GALL Report steel or nickel alloy cracking,        IWC, and IWD) and              Inservice cladding pressurizer  primary water    Water Chemistry                Inspection, components            stress corrosion                                Subsections (3.1.1-64)            cracking                                        IWB, IWC, and IWD (B.2.1) and Water Chemistry (B.2.2)
Nickel alloy reactor  Cracking due to  Inservice          No        ASME          Consistent with the vessel upper head    primary water    Inspection (IWB,              Section XI    GALL Report and control rod drive stress corrosion IWC, and IWD) and              Inservice penetration nozzles,  cracking        Water Chemistry                Inspection, instrument tubes,                      and Nickel-Alloy              Subsections head vent pipe (top                    Penetration Nozzles            IWB, IWC, and head), and welds                      Welded to the                  IWD (B.2.1),
(3.1.1-65)                            Upper Reactor                  Water Vessel Closure                Chemistry Heads of                      (B.2.2), and Pressurized Water              Nickel-Alloy Reactors                      Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors (B.2.5)
Steel steam          Loss of material Inservice          No        Not applicable Not applicable to generator            due to erosion  Inspection (IWB,                              HNP (See SER secondary manways                      IWC, and IWD) for                            Section 3.1.2.1.1) and handholds                          Class 2 components (cover only) exposed to air with leaking secondary-side water and/or steam (3.1.1-66)
Steel with stainless  Cracking due to Inservice            No        Not applicable Not applicable to steel or nickel alloy cyclic loading  Inspection (IWB,                              HNP (See SER cladding; or                          IWC, and IWD), and                            Section 3.1.2.1.1) stainless steel                        Water Chemistry pressurizer components exposed to reactor coolant (3.1.1-67) 3-186
 
Component Group        Aging Effect/    AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Stainless steel, steel Cracking due to  Inservice          No        ASME            Consistent with the with stainless steel  stress corrosion Inspection (IWB,              Section XI      GALL Report cladding Class 1      cracking        IWC, and IWD), and            Inservice piping, fittings,                      Water Chemistry                Inspection, pump casings, valve                                                    Subsections bodies, nozzles,                                                      IWB, IWC, and safe ends,                                                            IWD (B.2.1) manways, flanges,                                                      and CRD housing;                                                          Water pressurizer heater                                                    Chemistry sheaths, sleeves,                                                      (B.2.2) diaphragm plate; pressurizer relief tank components, reactor coolant system cold leg, hot leg, surge line, and spray line piping and fittings (3.1.1-68)
Stainless steel,      Cracking due to  Inservice          No        ASME            Consistent with the nickel alloy safety    stress corrosion Inspection (IWB,              Section XI      GALL Report injection nozzles,    cracking,        IWC, and IWD), and            Inservice safe ends, and        primary water    Water Chemistry                Inspection, associated welds      stress corrosion                                Subsections and buttering          cracking                                        IWB, IWC, and exposed to reactor                                                    IWD (B.2.1) coolant                                                                and (3.1.1-69)                                                            Water Chemistry (B.2.2)
Stainless steel; steel Cracking due to  Inservice          No        ASME            Consistent with the with stainless steel  stress corrosion Inspection (IWB,              Section XI      GALL Report cladding Class 1      cracking,        IWC, and IWD),                Inservice piping, fittings and  thermal and      Water chemistry,              Inspection, branch connections    mechanical      and One-Time                  Subsections
< NPS 4 exposed to    loading          Inspection of ASME            IWB, IWC, and reactor coolant                        Code Class 1                  IWD (B.2.1),
(3.1.1-70)                              Small-bore Piping              Water Chemistry (B.2.2), and One-Time Inspection Of ASME Code Class 1 Small-Bore Piping (B.2.21) 3-187
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,      Staff Evaluation (GALL Report      Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments High-strength low  Cracking due to Reactor Head          No        Reactor Head      Consistent with the alloy steel closure stress corrosion Closure Studs                  Closure Studs    GALL Report head stud assembly  cracking; loss                                  (B.2.3) exposed to air with of material due reactor coolant    to wear leakage (3.1.1-71)
Nickel alloy steam  Cracking due to Steam Generator      No        Steam            Consistent with the generator tubes and OD stress        Tube Integrity and            Generator Tube GALL Report sleeves exposed to  corrosion        Water Chemistry                Integrity (B.2.9) secondary          cracking and                                    and feedwater/steam    intergranular                                    Water (3.1.1-72)          attack, loss of                                  Chemistry material due to                                  (B.2.2) fretting and wear Nickel alloy steam  Cracking due to Steam Generator      No        Steam            Consistent with the generator tubes,    primary water    Tube Integrity and            Generator Tube GALL Report repair sleeves, and stress corrosion Water Chemistry                Integrity (B.2.9) tube plugs exposed  cracking                                        and to reactor coolant                                                  Water (3.1.1-73)                                                          Chemistry (B.2.2)
Chrome plated      Cracking due to Steam Generator      No        Steam            Consistent with the steel, stainless    stress corrosion Tube Integrity and              Generator Tube GALL Report steel, nickel alloy cracking, loss    Water Chemistry                Integrity (B.2.9) steam generator    of material due                                  and anti-vibration bars to crevice                                      Water exposed to          corrosion and                                    Chemistry secondary          fretting                                        (B.2.2) feedwater/steam (3.1.1-74)
Nickel alloy        Denting due to    Steam Generator    No        Not applicable    Not applicable to once-through steam  corrosion of      Tube Integrity and                              HNP (See SER generator tubes    carbon steel      Water Chemistry                                  Section 3.1.2.1.1) exposed to          tube support secondary          plate feedwater/steam (3.1.1-75)
Steel steam        Loss of material Steam Generator      No        Not applicable    Not applicable to generator tube      due to erosion, Tube Integrity and                                HNP (See SER support plate, tube general, pitting, Water Chemistry                                  Section 3.1.2.1.1) bundle wrapper      and crevice exposed to          corrosion, secondary          ligament feedwater/steam    cracking due to (3.1.1-76)          corrosion 3-188
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Nickel alloy steam  Loss of material Steam Generator      No        Not applicable Not applicable to generator tubes and  due to wastage Tube Integrity and                              HNP (See SER sleeves exposed to  and pitting      Water Chemistry                                Section 3.1.2.1.1) phosphate            corrosion chemistry in secondary feedwater/steam (3.1.1-77)
Steel steam          Wall thinning    Steam Generator      No        Not applicable Not applicable to generator tube      due to          Tube Integrity and                            HNP (See SER support lattice bars flow-accelerate  Water Chemistry                                Section 3.1.2.1.1) exposed to          d corrosion secondary feedwater/steam (3.1.1-78)
Nickel alloy steam  Denting due to  Steam Generator      No        Not applicable Not applicable to generator tubes      corrosion of    Tube Integrity;                                HNP (See SER exposed to          steel tube      Water Chemistry                                Section 3.1.2.1.1) secondary            support plate    and, for plants that feedwater/steam                      could experience (3.1.1-79)                            denting at the upper support plates, evaluate potential for rapidly propagating cracks and then develop and take corrective actions consistent with NRC Bulletin 88-02.
Cast austenitic      Loss of fracture Thermal Aging and    No        Thermal Aging  Consistent with the stainless steel      toughness due    Neutron Irradiation            and Neutron    GALL Report reactor vessel      to thermal      Embrittlement of                Irradiation internals            aging and        CASS                            Embrittlement (e.g., upper        neutron                                          of internals assembly,  irradiation                                      CASS (B.2.6) lower internal      embrittlement assembly, CEA shroud assemblies, control rod guide tube assembly, core support shield assembly, lower grid assembly)
(3.1.1-80) 3-189
 
Component Group        Aging Effect/      AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report          Mechanism            Report      Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Nickel alloy or        Cracking due to Water Chemistry      No        Water          Consistent with the nickel-alloy clad      primary water                                  Chemistry      GALL Report steam generator        stress corrosion                                (B.2.2) divider plate          cracking exposed to reactor coolant (3.1.1-81)
Stainless steel        Cracking due to Water Chemistry      No        Not applicable Not applicable to steam generator        stress corrosion                                              HNP (See SER primary side divider  cracking                                                      Section 3.1.2.1.1) plate exposed to reactor coolant (3.1.1-82)
Stainless steel; steel Loss of material Water Chemistry    No        Water          Consistent with the with nickel-alloy or  due to pitting                                  Chemistry      GALL Report stainless steel        and crevice                                    (B.2.2) cladding; and          corrosion nickel-alloy reactor vessel internals and reactor coolant pressure boundary components exposed to reactor coolant (3.1.1-83)
Nickel alloy steam    Cracking due to Water Chemistry      No        Not applicable Not applicable to generator              stress corrosion and One-Time                                  HNP (See SER components such        cracking        Inspection or                                Section 3.1.2.1.1) as, secondary side                      Inservice nozzles                                Inspection (IWB, (vent, drain, and                      IWC, and IWD).
instrumentation) exposed to secondary feedwater/steam (3.1.1-84)
Nickel alloy piping,  None            None                No        None          Consistent with the piping components,                                                                    GALL Report and piping elements exposed to air -
indoor uncontrolled (external)
(3.1.1-85) 3-190
 
Component Group      Aging Effect/  AMP in GALL      Further    AMP in LRA,    Staff Evaluation (GALL Report      Mechanism        Report      Evaluation  Supplements, Item No.)                                      in GALL          or Report    Amendments Stainless steel      None          None            No          None          Consistent with the piping, piping                                                                  GALL Report components, and piping elements exposed to air -
indoor uncontrolled (External); air with borated water leakage; concrete; gas (3.1.1-86)
Steel piping, piping None          None            No          Not applicable Not applicable to components, and                                                                HNP piping elements in concrete (3.1.1-87)
The staffs review of the reactor vessel, RVI, and reactor coolant system component groups followed any one of several approaches. One approach, documented in SER Section 3.1.2.1, reviewed AMR results for components that the applicant indicated are consistent with the GALL Report and require no further evaluation. Another approach, documented in SER Section 3.1.2.2, reviewed AMR results for components that the applicant indicated are consistent with the GALL Report and for which further evaluation is recommended. A third approach, documented in SER Section 3.1.2.3, reviewed AMR results for components that the applicant indicated are not consistent with, or not addressed in, the GALL Report. The staffs review of AMPs credited to manage or monitor aging effects of the reactor vessel, RVI, and reactor coolant system components is documented in SER Section 3.0.3.
3.1.2.1 AMR Results Consistent with the GALL Report LRA Section 3.1.2.1 identifies the materials, environments, AERMs, and the following programs that manage aging effects for the reactor vessel, RVI, and reactor coolant system components:
* ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD Program
* Water Chemistry Program
* Reactor Head Closure Studs Program
* Boric Acid Corrosion Program
* Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head of Pressurized Water Reactors Program
* Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program
* Flow-Accelerated Corrosion Program
* Bolting Integrity Program
* Steam Generator Tube Integrity Program 3-191
* Closed-Cycle Cooling Water System Program
* Reactor Vessel Surveillance Program
* One-Time Inspection Program
* One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program
* External Surfaces Monitoring Program
* Lubricating Oil Analysis Program LRA Tables 3.1.2-1 through 3.1.2-6 summarize AMRs for the reactor vessel, RVI, and reactor coolant system components and indicate AMRs claimed to be consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant claimed consistency with the report and for which it does not recommend further evaluation, the staffs audit and review determined whether the plant-specific components of these GALL Report component groups were bounded by the GALL Report evaluation.
The applicant noted for each AMR line item how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with Notes A through E indicating how the AMR is consistent with the GALL Report.
Note A indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report and validity of the AMR for the site-specific conditions.
Note B indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report and verified that the identified exceptions to the GALL Report AMPs have been reviewed and accepted. The staff also determined whether the applicants AMP was consistent with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
Note C indicates that the component for the AMR line item, although different from, is consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. This note indicates that the applicant was unable to find a listing of some system components in the GALL Report; however, the applicant identified in the GALL Report a different component with the same material, environment, aging effect, and AMP as the component under review. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the AMR line item of the different component was applicable to the component under review and whether the AMR was valid for the site-specific conditions.
Note D indicates that the component for the AMR line item, although different from, is consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP takes some exceptions to the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report. The staff verified whether the AMR line item of the different component was applicable to the component under review and whether the identified 3-192
 
exceptions to the GALL Report AMPs have been reviewed and accepted. The staff also determined whether the applicants AMP was consistent with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
Note E indicates that the AMR line item is consistent with the GALL Report for material, environment, and aging effect, but credits a different AMP. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the credited AMP would manage the aging effect consistently with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
The staff audited and reviewed the information in the LRA. The staff did not repeat its review of the matters described in the GALL Report; however, the staff did verify that the material presented in the LRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The staffs evaluation follows.
3.1.2.1.1 AMR Results Identified as Not Applicable AMR line items in GALL Report Volume 2, Table 1, items 10, 35, 59, 66, 75, 84, apply only to the extent that the corresponding GALL Report AMR result lines do not apply to once-through steam generators. The LRA states that because HNP has recirculating, not once-through steam generators, those line items do not apply to HNP steam generators. The staff reviewed the documentation supporting the applicants AMR evaluations and confirmed the applicants statement that HNP has no once-through steam generators. On this basis, the staff agrees with the applicants determination that the GALL Report AMR item for once-through steam generators does not apply.
LRA Table B-1 states that, based on a thermal aging susceptibility evaluation, CASS components are not susceptible to thermal aging; therefore, GALL AMP XI.M12 does not apply.
Further, LRA Table 3.1.1, item 3.1.1-57, states that the subject components have been screened and found to be not susceptible to thermal aging embrittlement based on the information provided in a letter from C. I. Grimes dated May 19, 2000.
Acceptable screening criteria for susceptibility to thermal aging applicable to all primary pressure boundary and RVI are outlined in the letter from C. I. Grimes dated May 19, 2000.
From this letter, the susceptibility of CASS components can be determined by molybdenum content, casting method, and ferrite content. During the audit, the staff asked the applicant to describe the casting method, molybdenum content, and ferrite content for HNP components and explain why GALL AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) program does not apply.
In its response dated August 20, 2007, the applicant stated that:
Per Table 3 of the Grimes Letter, valve bodies and pump casings do not require a susceptibility evaluation because both susceptible and non-susceptible components are examined to ASME Section XI requirements. As shown on page 3.1-62 of the LRA, CASS components of the reactor vessel internals are 3-193
 
managed by the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program for loss of fracture toughness due to thermal embrittlement. The remaining population of CASS components that require a susceptibility review included the reactor coolant loop elbows and the pressurizer spray head. The d-ferrite level for the reactor coolant loop elbows was calculated as part of the leak-before-break evaluation performed in WCAP-14549-P, Addendum 1, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the Harris Nuclear Plant for the License Renewal Program. The reactor coolant loop elbows are low-molybdenum statically cast components. Since the maximum calculated d-ferrite level is # 20 percent, the elbows are not susceptible to thermal aging.
For the pressurizer spray head, the Certified Material Test Report (CMTR) information was reviewed and the d-ferrite level calculated. The resultant d-ferrite level was below the screening threshold regardless of casting method; therefore, the pressurizer spray head is not susceptible to thermal aging.
Since the population of components reviewed for thermal aging were shown not to be susceptible to thermal aging, the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is not required for license renewal.
The staff reviewed specific details of the material composition and casting methods during the audit and found the applicants evaluation of the CASS components for susceptibility to thermal aging acceptable. The staff also agreed with the applicant that the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program does not apply because HNP CASS components are not susceptible to thermal aging.
LRA Table 3.1.1, item 54 states that this item does not apply; however, the staff noted that GALL Report item IV.C2-11, corresponding to the GALL Report Table 1, item 54, shows loss of material due to pitting, crevice, and galvanic corrosion as an aging effect for copper alloy piping, piping components, and piping elements in closed-cycle cooling water environments.
The GALL Report recommends GALL AMP XI.M21, Closed-Cycle Cooling Water System, to manage this aging effect. During the audit, the staff asked the applicant to explain why a comparable line item for this material, environment, aging effects, and aging management program (MEAP) is not in the LRA tables.
In its response dated August 20, 2007, the applicant stated that the reactor coolant pump lube oil coolers include copper alloy tubing in a component cooling water system (closed-cycle cooling water) environment; however, the tubing is of a copper nickel alloy with less than 15 percent zinc. Loss of material due to pitting and crevice corrosion is not present because these mechanisms do not affect such copper alloys. Loss of material due to galvanic corrosion is not present because the copper alloy tubing is not in contact with a material higher in the galvanic series; therefore, there are no aging effects for this material-environment and it is not appropriate to align this component with GALL Report, Volume 2, item IV.C2-11. The applicant further confirmed that no other RCS component has this material-environment combination.
The staff reviewed the documentation supporting the applicants AMR evaluation of cooper alloy 3-194
 
tubing materials for reactor coolant pump oil coolers, confirmed that the tubing material is a copper nickel alloy with less than 15 percent zinc, and found the applicants claim that loss of material due to pitting, crevice, and galvanic corrosion is not present for this component acceptable. On this basis, the staff agrees with the applicants determination that the corresponding AMR result line in the GALL Report does not apply.
LRA Table 3.1.1, item 56 shows that this item does not apply; however, GALL Report, Volume 2, item IV.C2-12, corresponding to GALL Report Volume 1, Table 1, item 56, shows loss of material due to selective leaching as an aging effect for copper alloy with less than 15 percent zinc in piping, piping components, and piping elements in closed-cycle cooling water environments. The GALL Report recommends GALL AMP XI.M33, Selective Leaching of Materials, to manage this aging effect. During the audit, the staff asked the applicant to explain why a comparable line item for this MEAP is not in the LRA tables.
In its response dated August 20, 2007, the applicant stated that there is no copper alloy with less than 15 percent zinc in closed-cycle cooling water environments within the systems evaluated in Chapter IV of the GALL Report; thus, GALL Report, Volume 2, item IV.C2-12 does not apply. The staff finds the response acceptable as it confirms that HNP has no copper alloy component with less than 15 percent zinc in a closed-cycle cooling water environment. On this basis, the staff agrees with the applicants determination that the corresponding AMR result line in the GALL Report does not apply.
LRA Table 3.1.1, items 61 and 62 show that this item does not apply; however, the staff noted that GALL Report item IV.C2-16, corresponding to GALL Report Table 1, item 61, shows cracking due to cyclic loading as an aging effect for stainless steel or steel pressurizer integral supports in air with metal temperature up to 288 EC (550 EF). The GALL Report recommends GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, to manage this aging effect for Class 1 components in the line-items corresponding to GALL Report Table 1, items 61, 62, and 67.
During the audit, the staff asked the applicant to explain why a comparable line item for this MEAP is not in the LRA tables.
In its response dated August 20, 2007, the applicant stated that cracking due to cyclic loading does not affect this specific pressurizer subcomponent; however, the ASME Inservice Inspection, Subsections IWB, IWC, and IWD Program manages the cracking aging effect for the pressurizer. The staff noted that cracking aging effect for components in Table 3.1.1, line-items 61, 62, and 67 is addressed in line item 68 and managed adequately by the ASME Inservice Inspection, Subsections IWB, IWC, and IWD Program; therefore, the staff finds the applicants response acceptable.
The staff noted that GALL Report item IV.A2-25 shows loss of material due to wear as an aging effect for vessel shell flanges made of steel material in reactor coolant environments. The GALL Report recommends GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, for Class 1 components to manage this aging effect. This line corresponds to GALL Report Table 1, item 63. During the audit, the staff asked the applicant to explain why a comparable line item for this MEAP is not in the LRA tables.
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In its response dated August 20, 2007, the applicant stated that the AMR included operating experience and found no history of wear on the reactor flanges; therefore, wear is not an aging effect for this component. The applicant, however, credits the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program in LRA Table 3.1.2-1 to manage SCC for this component. On the basis of the plant-specific operating experience, the staff finds the applicants response acceptable.
LRA Table 3.1.2-6 shows SCC, loss of material due to crevice corrosion, and loss of material due to pitting corrosion as aging effects for stainless steel steam generator tube support plates and flow distribution baffles in treated water (outside) environments. The LRA credits the Steam Generator Tube Integrity Program and the Water Chemistry Program for managing these aging effects. Although the LRA uses Note F, which means the material is not in the GALL Report for this component, it refers to GALL Report item IV.D-17. Further, this reference is not consistent with LRA Table 3.1.1, item 3.1.1-76 showing that ligament cracking due to corrosion of the steel steam generator tube support plate (Unique Item IV.D1-17) is not present and that all tube support plates are made of Type 405 ferritic stainless steel. During the audit, the staff asked the applicant to clarify this discrepancy with supporting documents and basis to demonstrate how the Steam Generator Tube Integrity and Water Chemistry Programs will manage the aging effects for stainless steam generator tube support plates and flow distribution baffles in treated water.
In its response dated August 20, 2007, the applicant stated that the material for these components is stainless steel. The GALL Report item IV.D1-17 shows the material for the line item as steel. As defined in GALL AMP IX.C, steel does not include stainless steel; therefore, as the HNP material is not in the GALL Report for this component, Note F is appropriate is consistent with LRA Table 3.1.1, item 3.1.1-76. The staff finds the applicants response acceptable because it explained that HNP steam generator tube support plate material is stainless steel and that the MEAP corresponding to GALL Report item IV.D1-17 does not apply.
The applicant further clarified that the aging management strategy for these components (steam generator secondary side components fabricated from carbon or low-alloy steel and exposed treated water) includes the Water Chemistry Program and Steam Generator Tube Integrity Program. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the loss of material and cracking aging effects. The Steam Generator Tube Integrity Program manages aging effects by a balance of prevention, inspection, evaluation, repair, and leakage monitoring. The staffs evaluation of the applicants Water Chemistry Program is documented in SER Section 3.0.3.1.1, the staffs evaluation of the applicants Steam Generator Tube Integrity Program in SER Section 3.0.3.2.6.
On these bases, the staff agrees with the applicant that the loss of material aging effect for carbon steel and low-alloy steel steam generator components will be adequately managed during the period of extended operation.
LRA Table 3.1.1, item 77 shows that this item does not apply. HNP does not use phosphate chemistry. On the basis that the staff verified that HNP does not use phosphate chemistry in its feedwater-steam environment, the staff agrees with the applicants determination that the corresponding AMR result line in the GALL Report does not apply.
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LRA Table 3.1.1, item 78 shows that the corresponding AMR result line in the GALL Report does not apply because the steam generators have no lattice bars. On the basis that the staff verified that the HNP has no lattice bars in its steam generators, the staff agrees with the applicants determination that the corresponding AMR result line in the GALL Report does not apply.
LRA Table 3.1.1, item 79 shows that the corresponding AMR result line in the GALL Report does not apply because all tube support plates are made of Type 405 ferritic stainless steel.
During the audit, the staff verified that the tube support plates are made of Type 405 ferritic stainless steel and that all tube support plates feature a flat contact geometry to reduce the tube-to-tube support plate crevice area. On these bases the staff agrees with the applicants determination that the corresponding AMR result line in the GALL Report does not apply.
LRA Table 3.1.1, item 82 shows that the corresponding AMR result line in the GALL Report does not apply because the steam generator primary side divider plate is fabricated from thermally-treated Alloy 690. On the basis that HNP has no stainless steel as a material of construction for its steam generator primary side divider plate, the staff agrees with the applicants determination that the corresponding AMR result line in the GALL Report does not apply.
The staff noted that FSAR Section 4.5.1.1, Materials Specifications, states that all parts of the control rod dive mechanism (CRDM) exposed to reactor coolant are made of metals which resist the corrosive action of the water. Three types of materials used exclusively are stainless steel, nickel-chromium-iron, and cobalt-based alloys. Further, FSAR Section 4.5.1.1 refers to other materials (Haynes 25, Inconel X-750, ductile iron, and Dow Corning 302) for the coil stack assembly and latch assembly; however, most of these materials, except stainless steel, are not in LRA tables for the CRDM assembly. During the audit, the staff asked the applicant to explain why these CRDM materials are not in LRA Section 3.1.
In its response dated August 20, 2007, the applicant stated that only the subcomponents of the CRDM having component intended functions were evaluated in the AMR. Active subcomponents are excluded from review based on 10 CFR 54.21(a)(1)(i). As stated in FSAR Section 4.5.1.1(a), All pressure containing materials of the CRDM comply with Section III of the ASME Boiler and Pressure Vessel Code, and are fabricated from austenitic (Type 304) stainless steel. The pressure boundary components of the CRDM include only the CRDM Latch Housings and the CRDM Rod Travel Housings which are identified in FSAR Table 5.2.3-1 as type 304 stainless steel.
The staff finds the applicants response acceptable because it clarifies that the CRDM subcomponents with materials other than stainless steel have no intended functions and, therefore, are not addressed in the AMR reviews.
3.1.2.1.2 Cracking Due to SCC, Loss of Material Due to Wear, and Loss of Preload In reviewing LRA Table 3.1.1, item 52, the staff noted that GALL Report items IV.A2-6, IV.A2-7, and IV.A2-8 show SCC, loss of material due to wear, and loss of preload as aging effects for 3-197
 
stainless steel control rod drive head penetration flange bolting in air with reactor coolant leakage environments. The GALL Report recommends GALL AMP XI.M18, Bolting Integrity, for managing these aging effects. These lines correspond to GALL Report Table 1, item 52.
During the audit, the staff asked the applicant to explain why comparable line items for these GALL Report items are not in the LRA tables.
In its response dated August 20, 2007, the applicant stated that the HNP reactor vessel head has 65 CRDM head penetration nozzles. Of these, 52 CRDM penetrations are for actual CRDMs, four are for the core exit thermocouples, eight spare CRDM penetrations are capped with head adapter plugs, and one spare is for reactor vessel level indicator/switch piping. The top of each CRDM head penetration flange welded to top of each CRDM head penetration nozzle is threaded externally (male) to receive an internally-threaded (female) CRDM assembly, core exit thermocouple assembly, head adapter plug, or reactor vessel level indicator/switch adapter. These components are seal-welded to the head penetration flanges. No bolted flange is used for any of these locations; therefore, GALL Report, Volume 2, items IV.A2-6, IV.A2-7, and IV.A2-8 do not apply. The staff finds the applicants response acceptable because it explained that HNP uses no bolted flange for comparable GALL Report items in Table 1, item 52 and these line items do not apply.
3.1.2.1.3 Loss of Material Due to General, Crevice, and Pitting Corrosion In reviewing LRA Table 3.1.2-4, the staff noted that it shows loss of material due to general, crevice, and pitting corrosion for carbon steel reactor coolant pump (RCP) oil cooler/heat exchanger components in treated water environments and that it credits the Closed-Cycle Cooling Water Program (LRA Section B.2.11) to manage this aging effect. The LRA shows consistency with GALL Report item IV.C2-14 and GALL Report Table 1, item 53. The LRA uses Note B, indicating that the program has an exception to the GALL Report program.
Further, LRA Section B.2.11, Closed-Cycle Cooling Water System Program, under the program elements affected by the exception states that:
* Parameters monitored or inspected Some heat exchangers are not monitored for flow, inlet and outlet temperatures, and differential pressure. In these cases, either the functionality of these heat exchangers is verified by activities outside the Closed-Cycle Cooling Water Program or the specific operating conditions of the heat exchanger render performance testing unreliable.
* Detection of aging effects Some heat exchangers that are not normally in operation are not periodically tested to ensure operability; however, the functionality of these heat exchangers is verified by activities outside the Closed-Cycle Cooling Water Program.
During the audit, the staff asked the applicant to clarify whether this exception affects the RCP oil cooler/heat exchanger and, if so, to explain verification of the functionality of these heat 3-198
 
exchangers.
In its response dated August 20, 2007, the applicant stated that the RCP oil cooler/heat exchanger component intended function is pressure boundary and that these components maintain pressure boundary integrity of the component cooling water system. The applicant concluded that verification of functionality as to heat transfer is not required. The staff finds the response acceptable because it explained that functionality tests are not required for managing loss of material due to general, crevice, and pitting corrosion for the RCP oil cooler/heat exchanger components and the LRA Section B.2.11 exception does not affect these components.
3.1.2.1.4 Loss of Material Due to Flow Accelerated Corrosion In reviewing LRA Table 3.1.2-6, the staff noted that the LRA shows loss of material due to FAC as an aging effect for the internal surfaces of feedwater nozzle fabricated from carbon or low-alloy steel in treated water. The LRA uses Note A indicating consistency with GALL Report Table 1, item 59 (the LRA listed 3.3.1-59, apparently a typographic error) and GALL Report item IV.D1-5, which shows wall thinning due to FAC. The staff asked the applicant to explain why the LRA shows an aging effect consistent with the GALL Report for this line item. Also, the staff noted that LRA Table 3.1.1, item 59 shows the steam generator steam nozzle and auxiliary feedwater nozzle as not susceptible to this aging effect. The staff asked the applicant for bases for this determination.
In its response dated August 20, 2007, the applicant stated that HNP considers the aging effects wall thinning and loss of material equivalent as to FAC. The applicant amended the LRA to correct the typographical error 3.3.1-59. The staff finds this response acceptable because the applicant clarified that it considers wall thinning due to FAC equivalent to loss of material due to FAC.
3.1.2.1.5 Cracking Due to Intergranular Attack In reviewing LRA Table 3.1.1, item 72, the staff noted that GALL Report item IV.D1-22 corresponding to the GALL Report Table 1, item 72, shows cracking due to intergranular attack as an aging effect for nickel-alloy steam generator tubes and sleeves in secondary feedwater/steam environments. The GALL Report recommends GALL AMP XI.M19, Steam Generator Tubing Integrity, and GALL AMP XI.M2, Water Chemistry, for PWR secondary water to manage this aging effect. During the audit, the staff asked the applicant to explain why a comparable line item for this MEAP is not in the LRA tables.
In its response dated August 20, 2007, the applicant stated that, for purposes of the AMR, the AMR methodology for predicting the cracking aging effect does not distinguish between this intergranular attack and IGSCC but records both AERMs as SCC. The applicant added that HNP manages this AERM by a combination of the Steam Generator Tube Integrity Program and the Water Chemistry Program, which is aligned to GALL Report item IV.D1-20, and that the HNP proposed AMPs are consistent with the AMPs recommended in GALL Report item IV.D1-22. The staff finds this response acceptable because the applicant clarified that the 3-199
 
aging effect for this component is consistent with the GALL Report.
The staff evaluated the applicants claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicants consideration of recent operating experience and proposals for managing aging effects. On the basis of its review, the staff concludes that the AMR results, which the applicant claimed to be consistent with the GALL Report, are indeed consistent with its AMRs; therefore, the staff concludes that the applicant has demonstrated that the effects of aging for these components will be adequately managed so that their intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended In LRA Section 3.1.2.2, the applicant further evaluates aging management, as recommended by the GALL Report, for the reactor vessel, RVI, and reactor coolant system components and provides information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* loss of material due to general, pitting, and crevice corrosion
* loss of fracture toughness due to neutron irradiation embrittlement
* SCC and IGSCC
* crack growth due to cyclic loading
* loss of fracture toughness due to neutron irradiation embrittlement and void swelling
* SCC
* cracking due to cyclic loading
* loss of preload due to stress relaxation
* loss of material due to erosion
* cracking due to flow-induced vibration
* SCC and irradiation-assisted SCC
* primary water SCC
* wall thinning due to flow-accelerated corrosion
* changes in dimensions due to void swelling
* SCC and primary water SCC
* SCC, primary water SCC, and irradiation-assisted SCC
* QA for aging management of nonsafety-related components For component groups evaluated in the GALL Report, for which the applicant claimed consistency with the report and for which the report recommends further evaluation, the staff audited and reviewed the applicants evaluation to determine whether it adequately addressed the issues further evaluated. In addition, the staff reviewed the applicants further evaluations against the criteria contained in SRP-LR Section 3.1.2.2.The staffs review of the applicants further evaluation follows.
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3.1.2.2.1 Cumulative Fatigue Damage LRA Section 3.1.2.2.1 states that fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must evaluate TLAAs (here for LRA Table 3.1.1, items 3.1.1-01 and 3.1.1-05 through 3.1.1-10) in accordance with 10 CFR 54.21(c)(1). SER Section 4.3 documents the staffs review of the applicants evaluation of this TLAA.
LRA Section 3.1.2.2.1 notes that the SRP-LR and the GALL Report incorrectly show LRA Table 3.1.1, item 1 as applicable only to BWR plants; however, GALL Report item IV.A2-20, pressure vessel support skirt and attachment welds, applies to PWR plants. LRA Section 3.1.2.2.1 states that the reactor vessel has no support skirt or attachment welds; however, the reactor vessel primary nozzle support pads are aligned to this item based on material, environment, aging effect, and program. The staff reviewed the documentation supporting the applicants AMR evaluation and confirmed that HNP has no pressure vessel support skirt. On the basis that the AERM for GALL Report item IV.A2-20 applies to HNPs reactor vessel primary nozzle support pads, the staff agrees with the applicants determination that the AMR result line in the GALL Report applies to the HNPs reactor vessel primary nozzle support pads.
LRA Table 3.1.1, items 3.1.1-02, 3.1.1-03, and 3.1.1-04, indicate that the AMR result lines are applicable to BWRs. The staff reviewed those AMR result lines in the SRP-LR and in the GALL Report and agrees with the applicants determination that the lines do not apply to HNP, a PWR.
In reviewing LRA Tables 3.1.2-1 through 3.1.2-6, the staff noted that some AMRs credit the TLAA on thermal fatigue with the management of cracking due to thermal fatigue in the components. The corresponding AMR items in the GALL Report refer to this aging effect as cumulative fatigue damage and recommend that the TLAA on metal fatigue to manage it. The TLAA on metal fatigue is not acceptable for aging management in a component with a fatigue crack already initiated. During the audit, the staff asked the applicant to clarify (1) why the aging effect description (i.e., cracking due to thermal fatigue) differs from that in the GALL Report, and (2) why the TLAA on metal fatigue can manage cracking due to thermal fatigue with fatigue-induced cracking already initiated.
In its response dated August 20, 2007, the applicant stated that:
: 1. The terminology used in the LRA is adopted from the EPRI Mechanical Tools. This methodology will identify this as a potential AERM under two conditions. First, if an explicit fatigue evaluation has been performed and is part of the current licensing basis. Second, when using the temperature screening criterion for piping and equipment designed to ASME Section III, Class 2 and 3 and ANSI B31.1 that account for fatigue through use of the stress range reduction factor, f. At this point in the AMR process, the AERM is used as a placeholder to indicate that further evaluation is required.
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: 2. A TLAA on metal fatigue is not considered capable of managing cracking due to metal fatigue. After the process described in 1 above, the AMR process ends and the TLAA evaluation begins. LRA Section 4.3 documents the resolution of those AMR lines where the potential aging effect of cracking has been postulated.
: 3. This methodology was used for the Brunswick license renewal project.
The Safety Evaluation Report (page 3-185) addressed this issue as follows:
The applicant's supplemental response to RAI 3.1.2.3.1.1-1, Part B, clarified that the phrase cracking due to thermal fatigue, as defined in the applicable AMR line items for Table 2" in LRA Sections 3.1, 3.2, 3.3, 3.4, and 3.5, corresponds to the definition cumulative fatigue damage in the applicant AMR line items for Table 1" in LRA Sections 3.1, 3.2, 3.3, 3.4, and 3.5. The applicant changed the terminology because it recognized that 10 CFR 54.21(a) requires that aging effects be managed for the period of extended operation and because the term cumulative fatigue damage referred to a parameter that is used to assess the aging effect of cracking due to thermal fatigue and was not referring to the aging effect itself. Based on this assessment, the change in the terminology from cumulative fatigue damage in the Table 1" to cracking due to thermal fatigue in the Table 2" was done to satisfy the provision and criteria of 10 CFR 54.21(a).
This meets the provisions in SRP-LR Sections 3.1, 3.2, 3.3, 3.4, and 3.5 for assessing cracking due to thermal fatigue/cumulative fatigue damage in ASME Code Class 1, 2, and 3 components and any applicable NSR components that are required to have thermal fatigue assessments for license renewal and, therefore, is acceptable. Refer to SER Section 4.3 for the staff's assessment of those plant components that are required to have thermal fatigue analyses for the LRA.
The staff finds the applicants response acceptable. The staff has evaluated and accepted the methodology in the LRA tables for the cumulative fatigues aging effect.
3.1.2.2.2 Loss of Material Due to General, Pitting, and Crevice Corrosion The staff reviewed LRA Section 3.1.2.2.2 against the criteria in SRP-LR Section 3.1.2.2.2:
(1)  LRA Section 3.1.2.2.2.1, PWR Steam Generator Shell and BWR Reactor Vessel Components Exposed to Treated Water and Steam, states that loss of material for BWR reactor vessel components applies to BWR plants only and that loss of material of once-through type steam generators, as in Babcock & Wilcox PWRs, is not present as HNP steam generators are of a recirculating design supplied by Westinghouse as described in FSAR Section 5.4.2.
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SRP-LR Section 3.1.2.2.2, item 1, states that loss of material due to general, pitting, and crevice corrosion may occur in the steel PWR steam generator shell assembly exposed to secondary feedwater and steam. Loss of material due to general, pitting, and crevice corrosion also may occur in the steel top head enclosure (without cladding) top head nozzles (vent, top head spray or reactor core isolation cooling (RCIC), and spare) exposed to reactor coolant.
The staff reviewed GALL Report Table 1, SRP-LR items 11 and 12, and the comparable AMR result lines in the GALL Report (IV.A1-11 and IV.D2-8, respectively). The staff confirmed that the GALL Report and SRP-LR item 11 apply to BWRs and the GALL Report and SRP-LR for item 12 to once-through steam generators only. On the bases that HNP is not a BWR and has Westinghouse recirculating steam generators, the staff agrees with the applicants determination that LRA Table 3.1.1, items 11 and 12 do not apply.
(2) LRA Section 3.1.2.2.2.2, BWR Isolation Condenser Components Exposed to Reactor Coolant, states that loss of material of BWR isolation condenser components applies to BWR plants only.
SRP-LR Section 3.1.2.2.2, item 2, states that loss of material due to pitting and crevice corrosion may occur in stainless steel BWR isolation condenser components exposed to reactor coolant. Loss of material due to general, pitting, and crevice corrosion may occur in steel BWR isolation condenser components.
The staff reviewed GALL Report Table 1, item 13 and the comparable AMR result lines in the GALL Report (IV.C1-6) and in the SRP-LR. The staff confirmed that GALL Report Table 1, item 13 applies only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicants determination that LRA Table 3.1.1, item 13 does not apply.
(3) LRA Section 3.1.2.2.2.3, Reactor Vessel Shells, Heads, and Welds; Flanges, Nozzles; Penetrations; Pressure Housings; and Safe Ends, states that loss of material of BWR reactor vessel and RCPB components affects BWR plants only.
SRP-LR Section 3.1.2.2.2, item 3, states that loss of material due to pitting and crevice corrosion may occur in stainless steel, nickel alloy, and steel with stainless steel or nickel alloy cladding flanges, nozzles, penetrations, pressure housings, safe ends, and vessel shells, heads, and welds exposed to reactor coolant.
The staff reviewed GALL Report Table 1, items 14 and 15, and the comparable AMR result lines in the GALL Report (IV.A1-8 and IV.C1-14, respectively) and in SRP-LR Table 3.1.1, items 14 and 15. The staff confirmed that the GALL Report and SRP-LR comparable line items apply only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicants determination that LRA Table 3.1.1, items 14 and 15 are not applicable to HNP.
(4) LRA Section 3.1.2.2.2.4, PWR Steam Generator Shell and Transition Cone, states that 3-203
 
loss of material due to general, pitting, and crevice corrosion could occur in the steel steam generator upper and lower shell and transition cone exposed to secondary feedwater and steam. The applicant manages the steam generator shell and transition cone with a combination of the Water Chemistry Program and the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program for Class 2 components. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the loss of material aging effect. The ASME Section XI Inservice Inspection, Subsections IWB, IWC, or IWD Program has been effective in managing aging effects in Class 1, 2, or 3 components and their attachments in light-water cooled power plants. The replacement steam generators are of the Westinghouse Delta 75 model as described in FSAR Section 5.4.2; therefore, the augmented inspection recommended by the GALL Report is not applicable.
SRP-LR Section 3.1.2.2.2, item 4, states that loss of material due to general, pitting, and crevice corrosion may occur in the steel PWR steam generator upper and lower shell and transition cone exposed to secondary feedwater and steam. The existing program controls chemistry to mitigate corrosion and ISI to detect loss of material. The extent and schedule of the existing steam generator inspections are designed to ensure that flaws cannot attain a depth sufficient to threaten the integrity of the welds; however, according to NRC Information Notice (IN) 90-04, the program may not be sufficient to detect pitting and crevice corrosion, if general and pitting corrosion of the shell is known to occur. The GALL Report recommends augmented inspection to manage this aging effect. Furthermore, the GALL Report Table 1, item 16, clarifies that this issue is limited to Westinghouse Model 44 and 51 steam generators with a high-stress region at the shell to transition cone weld.
The staff confirmed that the replacement steam generators are Westinghouse Delta 75 models. On the bases that the GALL Report clarifies that this issue is limited to Westinghouse Model 44 and 51 steam generators and that HNP replacement steam generators are Westinghouse Delta 75 models, the staff finds the applicant's statement that augmented inspection of the steam generators as described in SRP-LR Section 3.1.2.2.2.4 and the GALL Report does not apply. The LRA AMR result line states that the ASME Section XI Inservice Inspection, Subsection IWB, IWC, and IWD Program and the Water Chemistry Program (without augmented inspection) will manage the aging effect of loss of material due to general, pitting, and crevice corrosion. The staff finds the AMR result consistent with the corresponding AMR result in the GALL Report and acceptable.
The staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.2 criteria. For those line items that apply to LRA Section 3.1.2.2.2, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.3 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement 3-204
 
The staff reviewed LRA Section 3.1.2.2.3 against the criteria in SRP-LR Section 3.1.2.2.3:
(1)  LRA Section 3.1.2.2.3 states that certain aspects of the loss of fracture toughness due to neutron irradiation embrittlement are TLAAs as defined in 10 CFR 54.3. Applicants must evaluate TLAAs (here for LRA Table 3.1.1, item 3.1.1-17) in accordance with 10 CFR 54.21(c)(1). SER Section 4.2 documents the staffs review of the applicants evaluation of this TLAA.
In reviewing LRA Table 3.1.1, item 17, the staff noted that GALL Report item IV.A2-16, which corresponds to GALL Report, Table 1, line 17, lists inlet and outlet safety injection nozzles made of steel with stainless steel cladding and that the GALL Report recommends a TLAA to be evaluated to manage loss of fracture toughness due to neutron irradiation embrittlement in reactor coolant and neutron flux environments for this item. During the audit the staff asked the applicant to explain why a comparable line item for inlet and outlet safety injection nozzles is not in LRA Table 3.1.2-1.
In its response dated August 20, 2007, the applicant stated that the reactor vessel has no safety-injection nozzles and the reactor vessel outlet nozzles were not components likely to receive fluences greater than 1017 n/cm2 (E > 1.0 MeV); therefore, the reactor vessel outlet nozzles do not relate to GALL Report, Volume 2, item IV.A2-16 (R81). The applicant added that four other RCPB components outside the beltline region are likely to receive fluences greater than 1017 n/cm2 (E > 1.0 MeV). These include (1) the circumferential weId between the upper and intermediate shells, (2) the upper shell, (3) the inlet nozzle welds, and (4) the inlet nozzle.
Evaluation of these components were evaluated found none of these materials limiting in ART, charpy upper-shelf energy or reference temperature for pressurized thermal shock values. In  of its letter dated August 20, 2007, the applicant added an AMR line-item for the reactor vessel primary nozzles internally exposed to treated water. Consistent with GALL Report Table 1, line item 17, the applicant stated that loss of fracture toughness due to neutron irradiation embrittlement will be evaluated by TLAA in accordance with 10 CFR Part 50 Appendix G and RG1.99.
In addition the applicant added the new Plant-Specific Note 126 to read:
The HNP reactor vessel does not have safety injection nozzles. The reactor vessel outlet nozzles were not identified as components expected to receive fluences greater than 1017 n/cm2 (E > 1.0 MeV); therefore, the reactor vessel outlet nozzles do not apply to GALL Report, Volume 2, Item IV.A2-16 (R-81).
Five other reactor coolant pressure boundary components outside the beltline region are expected to receive fluences greater than 1017 n/cm2, (E > 1.0 MeV).
These components include: (1) the circumferential weId that is between the upper and intermediate shells, (2) the upper shell, (3) the inlet nozzle welds, (4) the inlet nozzle, and (5) upper shell longitudinal welds. These components were evaluated and none of these materials were determined to be limiting in adjusted reference temperature, CVUSE or RTPTS values.
The staff finds the applicants response acceptable because it clarified that either HNP does not have the comparable GALL Report components or the component does not receive fluences 3-205
 
greater than 1017 n/cm2. The applicant also committed to revise the LRA to add appropriate AMR lines for components outside the beltline region.
(2)  LRA Section 3.1.2.2.3 addresses loss of fracture toughness due to neutron irradiation embrittlement by stating that such loss could occur in the reactor vessel beltline, shell, nozzle, and welds. A materials surveillance program monitors neutron irradiation embrittlement of the reactor vessel. Evaluation of the materials outside of the traditional beltline region expected to receive fluence values greater than 1017 n/cm2 determined that none of these materials was limiting. LRA Appendix B presents the Reactor Vessel Surveillance Program and the results of its evaluation for license renewal.
SRP-LR Section 3.1.2.2.3 states that loss of fracture toughness due to neutron irradiation embrittlement may occur in BWR and PWR reactor vessel beltline shell, nozzle, and welds exposed to reactor coolant and neutron flux. A reactor vessel materials surveillance program monitors neutron irradiation embrittlement of the reactor vessel. Reactor vessel surveillance programs are plant-specific, depending on matters such as the composition of limiting materials, availability of surveillance capsules, and projected fluence levels. In accordance with 10 CFR Part 50, Appendix H, an applicant is required to submit its proposed withdrawal schedule for approval prior to implementation. Untested capsules placed in storage must be maintained for future insertion; thus, further staff evaluation is required for license renewal. Specific recommendations for an acceptable AMP are provided in GALL Report Chapter XI, Section M31.
The staff determined that the LRA correctly shows components subject to the aging effect of loss of fracture toughness due to neutron irradiation embrittlement and that AMR results in LRA Table 3.1.1, items 3.1.1-18 and 3.1.2-1 are consistent with GALL Report recommendations. The staff review of the applicants Reactor Vessel Surveillance Program is documented in SER Section 3.0.3.2.13. On the basis of the staffs evaluation of the AMP and the staffs determination that the applicants AMR results are consistent with the GALL Report, the staff finds the results acceptable. The staff finds this program consistent with GALL Report recommendations and adequate to manage the aging effect of loss of fracture toughness due to neutron irradiation embrittlement for carbon steel components clad with stainless steel exposed to reactor coolant.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.3 criteria. For those line items that apply to LRA Section 3.1.2.2.3, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.4 Cracking Due to Stress Corrosion Cracking and Intergranular Stress Corrosion Cracking The staff reviewed LRA Section 3.1.2.2.4 against the criteria in SRP-LR Section 3.1.2.2.4:
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(1)    LRA Section 3.1.2.2.4.1, BWR Vessel Leak Detection Lines, addresses SCC and IGSCC in BWR vessel leak detection lines by stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.1.2.2.4 states that cracking due to SCC and IGSCC may occur in the stainless steel and nickel alloy BWR top head enclosure vessel flange leak detection lines.
The staff reviewed GALL Report Table 1, SRP-LR line item 19, and comparable AMR result lines in the GALL Report. The staff confirmed that the GALL Report and the SRP-LR apply this line item only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicant's determination that LRA Table 3.1.1, item 19, does not apply.
(2)    LRA Section 3.1.2.2.4.2 addresses SCC and IGSCC in BWR isolation condenser components by stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.1.2.2.4, item 2, states that cracking due to SCC and IGSCC may occur in stainless steel BWR isolation condenser components exposed to reactor coolant.
The staff reviewed GALL Report Table 1, SRP-LR Table 3.1.1, item 20, and the comparable AMR result lines in the GALL Report. The staff confirmed that the GALL Report and SRP-LR apply this line item, only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicant's determination that LRA Table 3.1.1, item 20, does not apply.
3.1.2.2.5 Crack Growth Due to Cyclic Loading The staff reviewed LRA Section 3.1.2.2.5 against SRP-LR Section 3.1.2.2.5 criteria.
LRA Section 3.1.2.2.5 states that growth of intergranular separations (underclad cracks) in the heat-affected zone under austenitic steel cladding is not an applicable aging effect because, as addressed in the initial (November 1983) HNP SER (NUREG-1038), the steel was melted according to fine-grain practice with low-heat input weld cladding processes.
SRP-LR Section 3.1.2.2.5 states that crack growth due to cyclic loading could occur in reactor vessel shell forgings clad with stainless steel by a high-heat-input welding process. Growth of intergranular separations (underclad cracks) in the heat-affected zone under austenitic stainless steel cladding is a TLAA to be evaluated for the period of extended operation for all SA 508-Cl 2 forgings with cladding deposited by high-heat-input welding.
The staff reviewed GALL Report Table 1, SRP-LR Table 3.1.1, item 21, the comparable AMR result lines in the GALL Report, and the cited document. The staff confirmed that the GALL Report and SRP-LR apply this line item only to cladding deposited by high-heat-input welding.
On the basis that HNP uses a fine-grain practice with low-heat input cladding processes, the 3-207
 
staff agrees with the applicant's determination that SRP-LR Table 3.1.1, item 21, does not apply.
3.1.2.2.6 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement and Void Swelling The staff reviewed LRA Section 3.1.2.2.6 against the criteria in SRP-LR Section 3.1.2.2.6.
LRA Section 3.1.2.2.6 addresses loss of fracture toughness due to neutron irradiation embrittlement and void swelling by stating that loss of fracture toughness could occur in stainless steel and nickel alloy RVI exposed to reactor coolant and neutron flux. The FSAR Supplement, Section A.1.1, states commitments: (1) to participate in industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement results of the industry programs applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
SRP-LR Section 3.1.2.2.6 states that loss of fracture toughness due to neutron irradiation embrittlement and void swelling may occur in stainless steel and nickel alloy RVI components exposed to reactor coolant and neutron flux. The GALL Report recommends no further AMR if the applicant commits in the FSAR supplement (1) to participate in industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
In reviewing LRA Table 3.1.1, item 22, the staff the FSAR supplement commits to management of loss of fracture toughness due to neutron irradiation embrittlement and change in dimension due to void swelling; however, LRA Table 3.1.2-1 AMR line items for RVI components fabricated from stainless steel, nickel alloy, CASS corresponding to GALL Report Volume 1, line 22 do not provide for the commitment in the FSAR supplement.
During the audit, the staff asked the applicant to revise the LRA Table 3.1.2-1 AMR line items to include the commitment in the FSAR supplement.
In its response dated August 20, 2007, the applicant stated that the LRA currently states a commitment (1) to participate in industry (RVI aging programs, (2) to implement applicable results, and (3) to submit for NRC approval at least 24 months before the period of extended operation an RVI inspection plan based on industry recommendation. Review of the Table 2 items corresponding to Table 1 items 3.1.1-22, 3.1.1-27, 3.1.1-30, 3.1.1-33, and 3.1.1-37 demonstrates this commitment. For example, Table 1, item 3.1.1-22 on page 3.1-23 states that, The HNP commitment is described in the FSAR supplement. Further evaluation is documented in Subsection 3.1.2.2.6. LRA Section 3.1.2.2.6 and page 5 of LRA Appendix A (FSAR supplement) also refer to similar statements of this commitment. Further, the applicants response stated that the commitment in the Table 1 item (Table 3.1.1) applies to all 3-208
 
corresponding Table 2 AMR lines in LRA Section 3.1. The applicant clearly confirmed that the commitment in LRA Section 3.1.2.2.6 and FSAR Section A.1.1 applies to AMPs that manage loss of fracture toughness due to neutron irradiation embrittlement and change in dimension due to void swelling for all RVI made of stainless steel, nickel alloy, and CASS and exposed to treated water corresponding to GALL Report Table 1, item 22.
Based on these findings, for those line items that apply to LRA Section 3.1.2.2.6 the staff determines that the LRA meets SRP-LR Section 3.1.2.2.6 criteria and is consistent with the GALL Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.7 Cracking Due to Stress Corrosion Cracking The staff reviewed LRA Section 3.1.2.2.7 against the criteria in SRP-LR Section 3.1.2.2.7:
(1)  LRA Section 3.1.2.2.7.1 addresses SCC in PWR vessel leak detection piping and bottom-mounted instrument guide tubes by stating that SCC could occur in stainless steel PWR reactor vessel flange leak detection lines. Cracking from SCC of these lines is managed by a combination of the Water Chemistry Program and the One-Time Inspection Program. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain intended functions of affected components during the period of extended operation.
LRA Section 3.1.2.2.7 further clarifies that the flux thimble guide tubes are aligned to item 3.1.1-30 (GALL Report item IV.B2-12) for SCC.
SRP-LR Section 3.1.2.2.7 states that SCC may occur in the PWR stainless steel reactor vessel flange leak detection lines and bottom-mounted instrument guide tubes exposed to reactor coolant. The GALL Report recommends that a plant-specific AMP be evaluated to ensure that this aging effect is adequately managed.
LRA Table 3.1.1, item 23, under the discussion column, states that the flux thimble guide tubes are aligned to GALL Report Table 1, item 30, which corresponds to GALL Report item IV.B2-12, for SCC. The staff noted that GALL Report item IV.A2-1 corresponds to the GALL Report Table 1, item 23 for SCC for stainless steel bottom-mounted guide tubes in reactor coolant environments; however, the LRA does not address GALL Report item IV.A2-1 in Table 3.1.2-1 AMR line items.
During the audit, the staff requested from the applicant a basis for using GALL Report item IV.B-12 instead item IV.A2-1 for the flux thimble guide tubes line item.
In its response dated August 20, 2007, the applicant clarified that because all bottom-mounted instrumentation guide tubes are flux thimble guide tubes, they are 3-209
 
aligned to the GALL Report for the bottom-mounted instrumentation (IV.B2.12). The staff finds this response acceptable because it clarified that the LRA appropriately aligns the flux thimble guide tubes with the bottom-mounted instrumentation line items.
LRA Table 3.1.2-1 on page 3.1-41 credits the Water Chemistry and One-Time Inspection programs for managing SCC for stainless steel vessel flange leak detection lines. GALL Report Table 1, item 23 recommends a plant-specific program which should be further evaluated by the staff.
During the audit, the staff asked the applicant to describe any plant-specific or industry operating experience with stainless steel SS vessel flange leak detection line failure and explain how a one-time inspection detects SCC for this item. Further, the staff requested from the applicant a basis for using one-time inspection and water chemistry to manage SCC for the vessel flange leak detection line.
In its response dated August 20, 2007, the applicant stated that plant-specific and industry operating experience since January 1, 2005, shows no stainless steel vessel flange leak detection line failures. The applicant also clarified that the One-Time Inspection Program detects SCC for this item by enhanced visual (VT-1 or equivalent) or volumetric (radiographic test or UT) inspection or both. Unacceptable components/structures are processed by the corporate Corrective Action Program, which complies with 10 CFR Part 50 Appendix B. The applicant clarified that the vessel flange leak detection line is not ASME Code Class 1; therefore, it is not in the One-Time Inspection of Small Bore Class 1 RCS Piping Program. Although these lines are typically dry, any leaks at the vessel flange would expose the components internally to primary water; thus, the Water Chemistry Program is appropriate to manage SCC. As there is no operating experience with cracking in these lines, the One-Time Inspection Program is appropriate to confirm that the aging effect has not occurred.
The staff finds the applicants response to its question acceptable as a basis for use of the Water Chemistry and One-Time Inspection Programs to manage SCC for components in LRA Table 3.1.1-2.
(2) LRA Section 3.1.2.2.7.2 addresses SCC in CASS) RCS components, stating that SCC could occur in Class 1 PWR CASS piping exposed to reactor coolant. SCC of the CASS reactor coolant system components is managed by a combination of the Water Chemistry Program and the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. The Water Chemistry Program monitors and controls water chemistry using procedures and processes to prevent or mitigate the cracking aging effect. The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program has been effective in managing aging effects in Class 1, 2, or 3 components and their attachments in light-water cooled power plants.
SRP-LR Section 3.1.2.2.7, item 2, states that SCC may occur in Class 1 PWR CASS) reactor coolant system piping, piping components, and piping elements exposed to reactor coolant. The existing program controls water chemistry to mitigate SCC; however SCC may occur in CASS components that do not meet the NUREG-0313 3-210
 
guidelines with regard to ferrite and carbon content. The GALL Report recommends further evaluation of a plant-specific program for these components to ensure this aging effect is adequately managed.
LRA Table 3.1.2-3 on page 3.1-109 lists CASS piping, piping components, and piping elements in treated water environments. The LRA credits the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program and the Water Chemistry Program to manage SCC. The LRA shows consistency with GALL Report item IV.C2-3 and GALL Report Table 1, item 24. The LRA uses Notes E, 109, and 112 for these line items. Note E indicates that the program is different from the GALL Report for this component, material, environment, and aging effect combination. Note 109 states that the elbows in the primary loop piping are fabricated from SA351 CF8A material and Note 112 states that cracking due to SCC could occur in PWR CASS reactor coolant system piping and fittings. For PWRs, the GALL Report recommends further evaluation of piping that does not meet reactor water chemistry guidelines of TR-105714, PWR Primary Water Chemistry Guidelines, Revision 3, November 1995, or later. HNP use of the EPRI Water Chemistry Guidelines minimizes the potential for SCC in accordance with the GALL Report and no further evaluation of a plant-specific AMP is required. In addition, HNP uses the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program to verify the effectiveness of the Water Chemistry Program in preventing cracking of CASS components.
GALL Report Table 1, item 24 recommends the Water Chemistry Program and a plant-specific program for CASS components that do not meet NUREG-0313 guidelines.
GALL Report item IV.C2-03, which corresponds to GALL Report Table 1, item 24 and is addressed in the LRA, states that monitoring and control of primary water chemistry in accordance with the guidelines in EPRI TR-105714 (Revision 3 or later) minimize the potential of SCC, and material selection according to NUREG-0313, Revision 2 guidelines of 0.035 percent C and 7.5 percent ferrite reduces susceptibility to SCC. The GALL Report recommends for CASS components that meet neither guideline evaluation of any plant-specific AMP. The GALL Report recommends further evaluation of any plant-specific AMP used.
During the audit, staff reviewed the applicants license renewal AMR basis document for RCPB systems and other supporting documents. The staff verified that piping, piping components, and piping elements exposed to treated water are fabricated from CASS material with less than 0.035 percent carbon and from a minimum of 7.5 percent ferrite. Based on its review and audit, the staff agreed with the applicant that HNP meets the guidelines of EPRI TR-105714 and NUREG-0313 and no further evaluation of a plant-specific AMP is required because HNP uses the Water Chemistry and ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Programs to manage cracking of CASS components. The staffs evaluation of the applicants Water Chemistry Program is documented in SER Section 3.0.3.1.1, the staffs evaluation of the applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program in SER Section 3.0.3.2.1. On the basis of its review of these programs, the staff finds that the applicants Water Chemistry Program and ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD 3-211
 
Program are adequate to mitigate and manage SCC for CASS components in treated water environments.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.7 criteria. For those line items that apply to LRA Section 3.1.2.2.7, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.8 Cracking Due to Cyclic Loading The staff reviewed LRA Section 3.1.2.2.8 against the criteria in SRP-LR Section 3.1.2.2.8:
(1)  LRA Section 3.1.2.2.8.1, "BWR Jet Pump Sensing Lines," states that cracking of BWR jet pump-sensing lines applies to BWR plants only.
SRP-LR Section 3.1.2.2.8, item 1, states that cracking due to cyclic loading may occur in the stainless steel BWR jet pump sensing lines.
The staff reviewed GALL Report Table 1, SRP-LR item 25, and the comparable AMR result lines in the GALL Report. The staff confirmed that the GALL Report and SRP-LR apply, for this line item, only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicant's determination that SRP-LR Table 3.1.1, item 25, does not apply.
(2)  LRA Section 3.1.2.2.8.2, "BWR Isolation Condenser Components," states that cracking of isolation condenser components applies to BWR plants only.
SRP-LR Section 3.1.2.2.8, item 2, states that cracking due to cyclic loading may occur in steel and stainless steel BWR isolation condenser components exposed to reactor coolant.
The staff reviewed GALL Report Table 1, SRP-LR item 26, and the comparable AMR result lines in the GALL Report. The staff confirmed that the GALL Report and SRP-LR apply, for this line item, only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicant's determination that SRP-LR Table 3.1.1, item 26, does not apply.
3.1.2.2.9 Loss of Preload Due to Stress Relaxation The staff reviewed LRA Section 3.1.2.2.9 against the criteria in SRP-LR Section 3.1.2.2.9.
LRA Section 3.1.2.2.9 addresses loss of preload due to stress relaxation by stating that such aging affect could occur in stainless steel and nickel alloy PWR RVI components exposed to 3-212
 
reactor coolant. The FSAR supplement states commitments: (1) to participate in industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of industry programs applicable to the reactor internals, and (3) upon completion of these programs but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation may occur in stainless steel and nickel alloy PWR RVI screws, bolts, tie rods, and hold-down springs exposed to reactor coolant. The GALL Report recommends no further AMR if the applicant commits in the FSAR supplement (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
In reviewing LRA Table 3.1.1, item 27, the staff noted that the FSAR supplement commits to managing loss of preload due to stress relaxation; however, LRA Table 3.1.2-1 AMR line items for stainless steel and nickel alloy PWR RVI components exposed to reactor coolant corresponding to GALL Report Volume 1, line 27 include no provision for the FSAR supplement commitment.
During the audit, the staff asked the applicant to revise the LRA Table 3.1.2-1 AMR line items to include the FSAR supplement commitment.
In its letter dated August 20, 2007, the applicant stated that the LRA states a commitment (1) to participate in industry RVI aging programs, (2) to implement applicable results, and (3) to submit for NRC approval at least 24 months before the period of extended operation an RVI inspection plan based on industry recommendation. Reviews of Table 2 items corresponding to Table 1 items 3.1.1-22, 3.1.1-27, 3.1.1-30, 3.1.1-33, and 3.1.1-37 demonstrates this commitment. During the audit, the applicant pointed out that Table 1, item 3.1.1-27 states that the commitment is described in the FSAR supplement with further evaluation is documented in LRA Section 3.1.2.2.9. Further, the applicants response stated that the commitment described in Table 1, item 3.1.1-27 applies to all corresponding Table 2 AMR lines in LRA Section 3.1.
The staff finds the applicants response acceptable on the basis that HNP confirmed that the commitment in LRA Section 3.1.2.2.9 and FSAR Section A.1.1 applies to AMPs that manage loss of preload due to stress relaxation for stainless steel and nickel alloy PWR RVI exposed to treated water corresponding to GALL Report Table 1, item 27.
Based on these findings, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.9 criteria. For those line items that apply to LRA Section 3.1.2.2.9, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
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3.1.2.2.10 Loss of Material Due to Erosion The staff reviewed LRA Section 3.1.2.2.10 against the criteria in SRP-LR Section 3.1.2.2.10.
LRA Section 3.1.2.2.10 addresses loss of material due to erosion by stating such loss could occur in steel steam generator feedwater impingement plates and supports exposed to secondary feedwater. The One-Time Inspection Program manages loss of material due to erosion of the steam generator feedwater impingement plate components. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.1.2.2.10 states that loss of material due to erosion may occur in steel steam generator feedwater impingement plates and supports exposed to secondary feedwater. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that this aging effect is adequately managed.
In reviewing LRA Table 3.1.1, item 3.1.1-28 that corresponds to this section, the staff noted that LRA Table 3.1.2-6 shows loss of material due to erosion as an aging effect for external surfaces of steam generator feedwater impingement plate and support fabricated from carbon or low-alloy steel in treated water. The LRA uses Note E, which indicates consistency with GALL Report Table 1, item 28 and GALL Report item IV.D1-13 for component, material, environment, and aging effect, but the LRA does not credit the GALL Report's AMP. GALL Report item IV.D1-13 recommends plant-specific AMP that needs further evaluation. The LRA credits the One-Time Inspection Program for managing loss of material due to erosion.
During the audit, the staff requested from the applicant a basis for the One-Time Inspection Program for this line item and an explanation of how the One-Time Inspection Program manages loss of material due to erosion for steam generator feedwater impingement plates and supports exposed to secondary feedwater.
In its response dated August 20, 2007, that IN 97-88, Experiences During Recent Steam Generator Inspections, dated December 16, 1997, states that in May 1997 the licensee for the Shearon Harris Nuclear Power Plant found that four perforated, carbon steel ribs in a steam generator had been extensively damaged. The ribs are welded to the feedwater impingement plate which shields the steam generator tubes from direct impact of the feedwater flow. The licensee concluded that the high flow velocities of the feedwater eroded the ligaments between the perforations on the ribs.
The applicant added that the steam generators have been replaced and the Westinghouse replacement Model Delta 75 steam generators have no feedwater impingement plates as with preheater model steam generators installed in the old model D4s. Further, the applicant explained that the impingement plates in the LRA are ten .25-inch thick carbon steel (ASME-SA-285, Gr. C) baffles located between the primary separator outer riser barrels to prevent direct impingement of feedwater onto the upper shell. There has been no operating experience showing erosion of the baffles or supports. The One-Time Inspection Program 3-214
 
inspections should be scheduled no earlier than 10 years prior to the period of extended operation. HNP will have at least 30 years of use before inspections under this program begin, sufficient time for aging effects, if any, to be manifest.
The staff finds the applicants response acceptable on the basis that no operating experience shows erosion of baffles in the replaced steam generators. In addition, the One-Time Inspection Program inspections will be adequate to detect any loss of material due erosion.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.10 criteria. For those line items that apply to LRA Section 3.1.2.2.10, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.11 Cracking Due to Flow-Induced Vibration The staff reviewed LRA Section 3.1.2.2.11 against the criteria in SRP-LR Section 3.1.2.2.11.
LRA Section 3.1.2.2.11 states that cracking of BWR steam dryer components applies to BWR plants only.
SRP-LR Section 3.1.2.2.11 states that cracking due to flow-induced vibration could occur for the BWR stainless steel steam dryers exposed to reactor coolant.
The staff reviewed GALL Report Table 1, SRP-LR Table 3.1.1, item 29, and the comparable AMR result lines in the GALL Report. The staff confirmed that the GALL Report and SRP-LR apply, for this line item, only to BWRs. On the basis that HNP is not a BWR, the staff agrees with the applicants determination that SRP-LR Table 3.1.1, item 29, does not apply.
3.1.2.2.12 Cracking Due to Stress Corrosion Cracking and Irradiation-Assisted Stress Corrosion Cracking The staff reviewed LRA Section 3.1.2.2.12 against the criteria in SRP-LR Section 3.1.2.2.12.
LRA Section 3.1.2.2.12 addresses SCC and irradiation-assisted stress corrosion cracking (IASCC) by stating that either SCC and IASCC could occur in PWR stainless steel reactor internals exposed to reactor coolant. The Water Chemistry Program manages RVI components exposed to reactor coolant by monitoring and controlling of water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. In addition, the FSAR supplement states commitments: (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
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SRP-LR Section 3.1.2.2.12 states that SCC and IASCC may occur in PWR stainless steel reactor internals exposed to reactor coolant. The existing program controls water chemistry to mitigate these aging effects. The GALL Report recommends no further AMR if the applicant commits in the FSAR supplement (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
GALL Report Table 1, item 30, and GALL Report, Volume 2, Section IV components corresponding to GALL Report Table 1, item 30 and addressed in the LRA for this Table 1 item recommend the Water Chemistry Program and a commitment in the FSAR supplement, as stated in SRP-LR Section 3.1.2.2.12, to manage SCC and IASCC for stainless steel and CASS RVI components exposed to reactor coolant environments.
LRA Table 3.1.1, item 30, and Table 3.1.2-1 AMR line items that correspond to GALL Report Table 1, item 30, credit water chemistry for managing cracking for these AMRs. The staffs evaluation of the applicants Water Chemistry Program is documented in SER Section 3.0.3.1.1. On the basis of its review of this program, the staff finds the applicants Water Chemistry Program consistent with the GALL Report and adequate to mitigate SCC for stainless CASS RVI components in treated water environments.
In reviewing LRA Table 3.1.1, item 30, the staff noted that the FSAR supplement commits to managing cracking due to SCC and IASCC; however, LRA Table 3.1.2-1 AMR line items for stainless steel and CASS RVI components exposed to reactor coolant corresponding to GALL Report Volume 1, line 30, do not provide for the commitment in the FSAR supplement.
During the audit, the staff asked the applicant to revise the LRA Table 3.1.2-1 AMR line items to include the commitment in the FSAR supplement.
In its response dated August 20, 2007, the applicant stated that the LRA states a commitment (1) to participate in industry RVI aging programs, (2) to implement applicable results, and (3) to submit for NRC approval at least 24 months before the period of extended operation an RVI inspection plan based on industry recommendation. Review of Table 2 items that correspond to Table 1 items 3.1.1-22, 3.1.1-27, 3.1.1-30, 3.1.1-33, and 3.1.1-37 demonstrates this commitment. The applicant also pointed out that Table 1, item 3.1.1-30, states that the commitment is described in the FSAR supplement with further evaluation in Section 3.1.2.2.12.
Further, the applicant, in its response, clarified that the commitment in Table 1, item 3.1.1-30 applies to all corresponding Table 2 AMR lines in LRA Section 3.1.
The staff finds the applicants response acceptable on the basis that it confirmed that the commitment in LRA Section 3.1.2.2.12 and FSAR Section A.1.1 applies to AMPs that manage cracking due to SCC and IASCC for stainless steel and CASS RVI exposed to treated water corresponding to GALL Report Table 1, item 30.
Based on these findings, the staff concludes that the applicants programs meet SRP-LR 3-216
 
Section 3.1.2.2.12 criteria. For those line items that apply to LRA Section 3.1.2.2.12, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.13 Cracking Due to Primary Water Stress Corrosion Cracking The staff reviewed LRA Section 3.1.2.2.13 against the criteria in SRP-LR Section 3.1.2.2.13.
LRA Section 3.1.2.2.13 addresses cracking due to primary water stress corrosion cracking (PWSCC) by stating that such PWSCC could occur in PWR components made with nickel alloy and steel with nickel alloy cladding exposed to reactor coolant. Cracking due to SCC (including PWSCC) of nickel alloy and low alloy steel with nickel alloy cladding, including reactor coolant pressure boundary components and penetrations inside the reactor coolant system (e.g.,
pressurizer heater sheaths and sleeves, nozzles, and other internal components) is managed by a combination of the Water Chemistry Program and the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program has been effective in managing aging effects in Class 1, 2, or 3 components and their attachments in light-water cooled power plants. In addition, the FSAR supplement states a commitment to comply with applicable NRC Orders and to implement applicable (1) bulletins and generic letters, and (2) staff-accepted industry guidelines.
SRP-LR Section 3.1.2.2.13 states that PWSCC may occur in PWR components made of nickel alloy and steel with nickel alloy cladding, including reactor coolant pressure boundary components and penetrations inside the reactor coolant system such as pressurizer heater sheathes and sleeves, nozzles, and other internal components. Except for reactor vessel upper head nozzles and penetrations, the GALL Report recommends ASME Code Section XI ISI (for Class 1 components) and control of water chemistry. For nickel alloy components, no further AMR is necessary if the applicant complies with applicable NRC orders and commits in the FSAR supplement to implement applicable (1) bulletins and generic letters, and (2) staff-accepted industry guidelines.
In reviewing the GALL Report Table 1, item 31, which corresponds to SRP Section 3.1.2.2.13, the staff noted that LRA tables do not include the AMR line items for the following GALL Report, Volume 2 components that correspond to GALL Report Table 1, item 31: IV.D1-4 (steam generator instrument penetrations and primary side nozzles, safe ends, and welds), IV.C2-21 (pressurizer instrumentation penetrations, heater sheaths and sleeves, heater bundle diaphragm plate, and manways and flanges), and IV.C2-13 (RCS piping, piping components, and elements) made of nickel alloy or steel with nickel alloy cladding and exposed to reactor coolant. During the audit, the staff asked the applicant to explain why comparable line items for these components with their MEAPs are not in the LRA tables.
In its response dated August 20, 2007, the applicant stated that the GALL Report items do not apply for the following reasons: (1) IV.D1-4: the HNP steam generators have no nickel-based 3-217
 
alloy instrument penetration, (2) IV.C2-21: the HNP pressurizer has no nickel alloy instrumentation, penetrations, heater sheaths and sleeves, heater bundle diaphragm plate, and manways and flanges, and (3) IV.C2-13: except for RCS components aligned to the GALL Report, there is no nickel alloy or steel with nickel alloy cladding that would align to this GALL Report item.
During the audit, the staff reviewed the applicants license renewal AMR basis document for RVI and other supporting documents and determined that the applicant appropriately indicated components that align to GALL Report Table 1, item 31; therefore, the staff finds the applicants response acceptable.
LRA Tables 3.1.2-1 and 3.1.2-5 credit the Water Chemistry and ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Programs to manage PWSCC of nickel-based alloy components. The staffs evaluation of the applicants Water Chemistry Program is documented in SER Section 3.0.3.1.1, the staffs evaluation of the applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program in SER Section 3.0.3.2.1.
GALL Report, Revision 1, Volumes 1and 2, include AMR items to manage various forms of SCC in nickel alloy and stainless steel RCPB components. For aging management, the GALL Report recommends that the FSAR supplement include a commitment to implement: (1) NRC orders, bulletins, and GLs on nickel alloy components and (2) staff-accepted industry guidelines. Based on its review of the AMR line items for LRA Table 3.1.1, item 31, the staff determined either that LRA tables lacked AMR items to manage SCC in some nickel-alloy RCPB components exposed to reactor coolant or that the existing AMR items did not provide for the commitment in the FSAR supplement.
During the audit, the staff asked the applicant to indicate all RCPB nickel-alloy components and weld locations exposed to reactor coolant and to clarify whether the LRA includes AMRs on management of SCC or any of its forms (e.g., PWSCC) in the components. The staff asked the applicant to revise the LRA to include any omitted AMR entries on management of SCC (or its forms) in specific nickel alloy components or welds. In addition, the staff asked the applicant to revise all AMRs on SCC of nickel-alloy components or welds to include the commitment for nickel-alloy AMR items in the GALL Report.
In its response dated August 20, 2007, the applicant stated that the nickel alloy components/welds are as follow: pressure safety and relief nozzle weld, surge nozzle safe end weld, spray nozzle safe end, CRDM nozzle head, CRDM nozzle weld, head vent, bottom head instrument penetration, core support pads, hot leg-to-reactor vessel weld, and cold leg-to-reactor vessel weld. The applicant stated that revised LRA tables will include pressurizer spray nozzle safe end, pressurizer relief safe end, and pressurizer safety nozzle safe end. In addition, the applicants response stated that the LRA states commitments to (1) NRC orders, bulletins, and GLs on nickel alloys and (2) staff-accepted industry guidelines. Review of the Table 2 items that correspond to the following Table 1, item 3.1.1-31 demonstrates these commitments. For example, Table 1, item 3.1.1-31 states: Consistent with NUREG-1801
[GALL Report] with exception. The aging effect is managed by a combination of the Water Chemistry Program and the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. The HNP commitment is described in the FSAR supplement. Also, LRA 3-218
 
Section 3.1.2.2.13 states that, In addition, HNP provides in the FSAR supplement a commitment to comply with applicable NRC Orders and to implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines. A similar statement is in FSAR Supplement Section A.1.2. The applicant clarified that the commitment in the Table 1 item (Table 3.1.1) applies to all corresponding Table 2 AMR lines in LRA Section 3.1.
The staff finds the applicants response acceptable on the basis that it confirmed that the commitment in LRA Section 3.1.2.2.13 and FSAR Section A.1.1 applies to AMPs that manage PWSCC for nickel-based alloy components internally exposed to treated water corresponding to GALL Report Table 1, item 31.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.13 criteria. For those line items that apply to LRA Section 3.1.2.2.13, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.14 Wall Thinning Due to Flow-Accelerated Corrosion The staff reviewed LRA Section 3.1.2.2.14 against the criteria in SRP-LR Section 3.1.2.2.14.
LRA Section 3.1.2.2.14 addresses wall thinning due to flow-accelerated corrosion by stating that such wall thinning could occur in steam generator feedwater inlet rings and supports. The One-Time Inspection Program manages loss of material due to flow-accelerated corrosion of the steam generator feedwater distribution ring and related components. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.1.2.2.14 states that wall thinning due to flow-accelerated corrosion may occur in steel feedwater inlet rings and supports. The GALL Report references IN 91-19,
?Steam Generator Feedwater Distribution Piping Damage, for evidence of flow-accelerated corrosion in steam generators and recommends that a plant-specific AMP be evaluated because existing programs may not be capable of mitigating or detecting wall thinning due to flow-accelerated corrosion.
LRA Table 3.1.2-6 shows loss of material due to FAC as an aging effect for external surfaces of steam generator feedwater impingement plate and support fabricated from carbon or low-alloy steel in treated water. The LRA uses Note E, which indicates consistency with GALL Report Table 1, item 32 and GALL Report item IV.D1-26 for component, material, environment, and aging effect, but the LRA does not credit the GALL Report AMP. GALL Report item IV.D1-26 indicates wall thinning due to FAC and recommends a plant-specific AMP. During the audit, the staff noted that the applicant considers the aging effects wall thinning and loss of material equivalent as to FAC. The staff finds this approach acceptable because loss of material due to FAC is comparable to the wall-thinning aging effect.
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The staff reviewed IN 91-19 and noted that it describes a problem with combustion engineering steam generator designs. The staff also noted that the applicant credits the Water Chemistry and One-Time Inspection Programs for managing loss of material due to FAC for steam generator feedwater impingement plates and supports during the period of extended operation for the Westinghouse-designed steam generators.
During the audit and review, the staff asked the applicant to clarify how the One-Time Inspection Program manages loss of material due to FAC for steam generator feedwater impingement plates and supports.
In its response dated December 11, 2007, the applicant stated that HNP inspected the interior of the feedwater inlet ring of the "B" and "C" steam generators during RFO 13 in 2006. This inspection employed remote visual equipment with recording capabilities for a basis for comparison with the results of future inspections. The applicant added that alternative techniques to remote visual may inspect the feedwater distribution ring and related components for loss of material due to FAC depending on industry operating experience with the Westinghouse Delta 75 steam generators and development of additional inspection techniques.
The staff finds the applicant's approach acceptable because visual inspection records provide a basis for evaluation of the future one-time inspection.
The staffs evaluation of the applicants Water Chemistry Program is documented in SER Section 3.0.3.1.1, the staffs evaluation of the applicants One-Time Inspection Program in SER Section 3.0.3.2.5. Based on its evaluations of these programs, the staff finds that the applicants Water Chemistry Program mitigates and its One-Time Inspection Program detects the aging effect of loss of material due to FAC during the period of extended operation. The staff finds that these programs are consistent with GALL Report recommendations and adequate to manage the aging effect of loss of material due FAC for the steam generator feedwater impingement plate and support.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.14 criteria. For those line items that apply to LRA Section 3.1.2.2.14, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.15 Changes in Dimensions Due to Void Swelling The staff reviewed LRA Section 3.1.2.2.15 against the criteria in SRP-LR Section 3.1.2.2.15.
LRA Section 3.1.2.2.15 addresses changes in dimensions due to void swelling by stating that such changes in dimensions could occur in stainless steel and nickel alloy PWR RVI components exposed to reactor coolant. The FSAR supplement states commitments: (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months 3-220
 
before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
SRP-LR Section 3.1.2.2.15 states that changes in dimensions due to void swelling may occur in stainless steel and nickel alloy PWR internal components exposed to reactor coolant. The GALL Report recommends no further AMR if the applicant commits in the FSAR supplement (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
In reviewing GALL Report Table 1, item 33, which corresponds to SRP Section 3.1.2.2.15, the staff noted that LRA tables do not include the AMR line items for the following GALL Report, Volume 2 components that correspond to GALL Report Table 1, item 33: IV.B2-7 (core barrel, core barrel upper flange, core barrel outlet nozzles, and thermal shield), IV.B2-1 (baffle/former plates), IV.B2-4 (baffle/former bolts), IV.B2-15 (lower internal assembly fuel alignment pins, lower support plate column bolts, and clevis insert bolts), and IV.B2-11(instrumentation support structures flux thimble guide tubes) made of nickel alloy or steel with nickel alloy cladding and exposed to reactor coolant.
During the audit, the staff asked the applicant to explain why comparable line items for these components with their MEAPs are not in the LRA tables. The applicant responded that GALL Report items IV.B2-7, IV.B2-1, IV.B2-4, and IV.B2-15 apply to components within a reactor coolant environment. The HNP AMR considers these components as in a reactor coolant and high-neutron flux environment which would align to GALL Report items IV.B2-9, IV.B2-3, IV.B2-6, and IV.B2-17. The applicant explained that these GALL Report items correspond to GALL Report Table 1, line 22 which includes both loss of fracture toughness due to neutron irradiation embrittlement and changes in dimensions due to void swelling. Further, the applicant clarified that GALL Report item IV.B2-11 applies to flux thimble guide tubes outside the reactor vessel and not subject to radiation levels above the threshold for changes in dimensions due to void swelling; therefore, the applicant determined that the flux thimble tubes are not subject to such changes in dimensions and that GALL Report item IV.B2-11 does not apply.
During the audit, the staff reviewed the applicants supporting documents and determined that the applicant appropriately indicated components that align to GALL Report Table 1, item 33; therefore, the staff finds the applicants response acceptable.
In reviewing LRA Table 3.1.1, item 33, the staff noted that the FSAR supplement commits to managing change in dimensions due to void swelling; however, LRA Table 3.1.2-1 AMR line items for stainless steel and nickel alloy PWR RVI components exposed to reactor coolant corresponding to GALL Report Table 1, line 33, do not provide for the commitment in the FSAR supplement.
During the audit, the staff asked the applicant to revise LRA Table 3.1.2-1 AMR line items to include the commitment in the FSAR supplement.
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In its response dated August 20, 2007, the applicant stated that the LRA states a commitment (1) to participate in industry RVI aging programs, (2) to implement applicable results, and (3) to submit for NRC approval at least 24 months before the period of extended operation an RVI inspection plan based on industry recommendation. Review of Table 2 items corresponding to Table 1 items 3.1.1-22, 3.1.1-27, 3.1.1-30, 3.1.1-33, and 3.1.1-37 demonstrates this commitment. During the audit, the applicant pointed out that Table 1, item 3.1.1-33, states that the HNP commitment is described in the FSAR supplement with further evaluation in Section 3.1.2.2.15. Further the applicant, in its response, clarified that the commitment in Table 1, item 3.1.1-33 applies to all corresponding Table 2 AMR lines in LRA Section 3.1. The staff finds the applicants response acceptable because it confirmed that the commitment in LRA Section 3.1.2.2.15 and FSAR Section A.1.1 applies to AMPs that manage change in dimensions due to void swelling for stainless steel and nickel alloy PWR RVI components exposed to reactor coolant corresponding to GALL Report Table 1, item 33.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.15 criteria. For those line items that apply to LRA Section 3.1.2.2.15, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.16 Cracking Due to Stress Corrosion Cracking and Primary Water Stress Corrosion Cracking The staff reviewed LRA Section 3.1.2.2.16 against the criteria in SRP-LR Section 3.1.2.2.16:
(1)    LRA Section 3.1.2.2.16 addresses SCC and PWSCC in control rod drive head penetration pressure housings by stating that such cracking is managed by the Water Chemistry Program in combination with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program has been effective in managing aging effects in Class 1, 2, or 3 components and their attachments in light-water cooled power plants. Only stainless steel or stain less steel-clad components are present in this item; therefore, no commitment as to nickel alloys is necessary.
SRP-LR Section 3.1.2.2.16 states that SCC may occur on the primary coolant side of PWR steel steam generator upper and lower heads, tubesheets, and tube-to-tube sheet welds made or clad with stainless steel. Cracking due to PWSCC may occur on the primary coolant side of PWR steel steam generator upper and lower heads, tubesheets, and tube-to-tube sheet welds made or clad with nickel alloy. The GALL Report recommends ASME Code Section XI ISI and control of water chemistry to manage this aging effect and recommends no further AMR for PWSCC of nickel alloy if the applicant complies with applicable NRC orders and commits in the FSAR supplement to implement applicable (1) bulletins and generic letters, and (2) staff-accepted industry guidelines.
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The staff noted that in SRP-LR Table 3.1-1 there are two lines, items 34 (for control rod drive head penetration) and 35 (for steam generator), that refer to SRP-LR Section 3.1.2.2.16.1 and that these lines are the same as GALL Report, Volume 1, Table 1, items 34 and 35. The staff noted that all AMR results in LRA Table 3.1.2-1 referring to LRA Table 3.1.1, item 34, are for components constructed of stainless steel or alloy steel with stainless steel cladding. The staff reviewed details of the applicants AMR evaluation and found no omissions of construction materials for these components. The LRA states that for these components the aging effect of SCC or PWSCC will be managed by the Water Chemistry Program in combination with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. The staffs evaluations of these AMPs are in SER Sections 3.0.3.2.1 and 3.0.3.1.1, respectively. On the basis of the staffs evaluation of the specified AMPs and because all components in the AMR result line are made of stainless steel, the staff finds the applicants use of the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program and the Water Chemistry Program acceptable and the AMR result consistent with GALL Report recommendations.
LRA Table 3.1.1, item 35, states that steam generators are recirculating and not once-through; therefore, this aging effect is not present and no commitment is required.
The staff noted that GALL Report, Volume 1, Table 1, item 35, refers only to GALL Report item IV.D2-4, which is for nonrecirculating steam generators, and that comparable AMR results for recirculating steam generator components are in the GALL Report, Volume 1, Table 1, items 81, 82 and 84. On the basis that the SRP-LR subsection applies to once-through steam generators and HNP has recirculating steam generators, the staff agreed with the applicant that no further evaluation is required.
(2) LRA Section 3.1.2.2.16 addresses SCC and PWSCC in the pressurizer spray head by stating that SCC could occur on stainless steel pressurizer spray heads and PWSCC could affect nickel alloy pressurizer spray heads. The pressurizer spray head is fabricated from CASS. A combination of Water Chemistry Program and the One-Time Inspection Program manages SCC of the pressurizer spray head. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation. No applicant commitment as to spray head inspection is required because the pressurizer spray head is fabricated from CASS.
SRP-LR Section 3.1.2.2.16 states that SCC may occur on stainless steel pressurizer spray heads. Cracking due to PWSCC may occur on nickel-alloy pressurizer spray heads. The existing program controls water chemistry to mitigate this aging effect. The GALL Report recommends one-time inspection to confirm that cracking has not occurred. For nickel alloy welded spray heads, the GALL Report recommends no further AMR if the applicant complies with applicable NRC orders and commits in the FSAR supplement to implement applicable (1) bulletins and generic letters, and (2) staff-accepted industry guidelines.
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The staff noted that all AMR results in LRA Table 3.1.2-5 referring to LRA Table 3.1.1, item 36, are for components in which the material of construction is CASS or stainless steel and that the discussion column of LRA Table 3.1.1, item 36, states that no licensee commitment is required as the pressurizer spray head at HNP is fabricated from CASS.
The staff reviewed details of the applicants AMR results and found no omissions of construction materials for these components. LRA Section 3.1.2.2.16 states that for these components the aging effect of SCC or PWSCC will be managed by the Water Chemistry Program and by One-Time Inspection Program. The staffs evaluations of these AMPs are in SER Sections 3.0.3.1.1 and 3.0.3.1.5, respectively. On the basis of the staffs evaluation of the specified AMPS and because all components included in the AMR results line are made of stainless steel, the staff finds the applicants use of the Water Chemistry Program and by the One-Time Inspection Program acceptable and the AMR result consistent with GALL Report recommendations.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.16 criteria. For those line items that apply to LRA Section 3.1.2.2.16, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.17 Cracking Due to Stress Corrosion Cracking, Primary Water Stress Corrosion Cracking, and Irradiation-Assisted Stress Corrosion Cracking The staff reviewed LRA Section 3.1.2.2.17 against the criteria in SRP-LR Section 3.1.2.2.17.
LRA Section 3.1.2.2.17 addresses SCC, primary water stress corrosion cracking, and irradiation-assisted stress corrosion cracking. The applicant stated that SCC, PWSCC, or IASCC by stating that such cracking could occur in stainless steel and nickel alloy PWR RVI components. The Water Chemistry Program manages SCC of the PWR stainless steel and nickel alloy RVI components and monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. In addition, The FSAR Supplement states commitments: (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and approval.
SRP-LR Section 3.1.2.2.17 states that SCC, PWSCC, and IASCC may occur in PWR stainless steel and nickel alloy RVI components. The existing program controls water chemistry to mitigate these aging effects; however, the existing program should be augmented to manage these aging effects for RVI components. The GALL Report recommends no further AMR if the applicant commits in the FSAR supplement (1) to participate in the industry programs for investigating and managing aging effects on reactor internals, (2) to evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, to submit an inspection plan for reactor internals to the staff for review and 3-224
 
approval.
GALL Report Table 1, item 37 and corresponding GALL Report Volume 2, Section IV components addressed in LRA for this Table 1 line item recommend a water chemistry program and a commitment in the FSAR supplement, as stated in SRP-LR Section 3.1.2.2.17, to manage SCC, PWSCC and IASCC for stainless steel and nickel alloy RVI components exposed to reactor coolant environments. LRA Table 3.1.1, item 37, and corresponding Table 3.1.2-1 AMR line items credit water chemistry for managing cracking in these AMRs. The staffs evaluation of the applicants Water Chemistry program is documented in SER Section 3.0.3.1.1. On the basis of its review of this program, the staff finds that the applicants Water Chemistry Program is consistent with the GALL Report and adequate to mitigate SCC for stainless CASS RVI components in treated water environments.
In reviewing LRA Table 3.1.1, item 37, the staff noted that the FSAR supplement commits to managing SCC, PWSCC, and IASCC; however, LRA Table 3.1.2-1 AMR line items for stainless steel and nickel alloy RVI components exposed to reactor coolant corresponding to GALL Report Volume 1, line 37 do not provide for the commitment in the FSAR supplement.
During the audit, the staff asked the applicant to revise LRA Table 3.1.2-1 AMR line items to include the commitment in the FSAR supplement.
In its letter dated August 20, 2007, the applicant stated that the LRA states a commitment (1) to participate in industry RVI aging programs, (2) to implement applicable results, and (3) to submit for NRC approval at least 24 months before the period of extended operation an RVI inspection plan based on industry recommendation. Reviews of the Table 2 items that correspond to the following Table 1 items (3.1.1-22, 3.1.1-27, 3.1.1-30, 3.1.1-33, and 3.1.1-37) demonstrates this commitment. The applicant also pointed out that Table 1, item 3.1.1-37 states that the commitment is described in the FSAR supplement with further evaluation in Subsection 3.1.2.2.17. Further, the applicants response clarified that the commitment in the Table 1, item 3.1.1-30 applies to all corresponding Table 2 AMR lines in LRA Section 3.1.
The staff finds the applicants response acceptable because it confirmed that the commitment in LRA Section 3.1.2.2.17 and FSAR Section A.1.1 applies to AMPs that manage SCC and IASCC for stainless steel and CASS RVI components exposed to treated water corresponding to GALL Report Table 1, item 37.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.1.2.2.17 criteria. For those line items that apply to LRA Section 3.1.2.2.17, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.2.18 Quality Assurance for Aging Management of Nonsafety-Related Components SER Section 3.0.4 documents the staffs evaluation of the applicants QA program.
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3.1.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report In LRA Tables 3.1.2-1 through 3.1.2-6, the staff reviewed additional details of the AMR results for material, environment, AERM, and AMP combinations not consistent with or not addressed in the GALL Report.
In LRA Tables 3.1.2-1 through 3.1.2-6, the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. The applicant provided further information about how it will manage the aging effects. Specifically, Note F indicates that the material for the AMR line item component is not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the line item component, material, and environment combination is not applicable.
Note J indicates that neither the component nor the material and environment combination for the line item is evaluated in the GALL Report.
For component type, material, and environment combinations not evaluated in the GALL Report, the staff reviewed the applicants evaluation to determine whether the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. The staffs evaluation is documented in the following sections.
3.1.2.3.1 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Vessel and Internals - LRA Table 3.1.2-1 The staff reviewed LRA Table 3.1.2-1, which summarizes the results of AMR evaluations for the reactor vessel and internals component groups.
In reviewing LRA Table 3.1.2-1, the staff noted that the applicant lists stainless steel CRDM head penetration thermal sleeves exposed to treated water environments, using Notes J and 113 for this AMR line. Note J indicates that neither the component nor the material and environment combination is evaluated in the GALL Report and plant-specific Note 113 states that these aging effects do not affect the insulation intended function of the thermal sleeves; therefore, the LRA states None for AERM and its AMP. The staff did not agree with the applicants elimination of an aging effect because of the intended function. The staff believed that if a component has no intended function to be managed during the period of extended operation that component should be screened out and not included in the AMR tables. During the audit, the staff asked the applicant to justify elimination of aging effect for stainless steel CRDM head penetration thermal sleeves exposed to treated water in accordance with the requirements of 10 CFR Part 54.
In its response dated August 20, 2007, the applicant revised LRA Table 3.1.2-1 to use a combination of the Water Chemistry Program and the One-Time Inspection Program to manage loss of material and cracking of stainless steel CRDM head penetration thermal 3-226
 
sleeves exposed to treated water. The applicants response added that the Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate cracking and loss of material aging effects. The One-Time Inspection Program either verifies that unacceptable degradation has not occurred or triggers additional actions to maintain intended functions of affected components during the period of extended operation.
The staffs evaluation of the applicants Water Chemistry Program and One-Time Inspection Program are documented in SER Section 3.0.3.1.1 and 3.0.3.1.5, respectively.
The staff finds this response acceptable because the applicant adequately revised the AMR line items in Table 3.1.2-1 to include loss of material and cracking of stainless steel CRDM head penetration thermal sleeves exposed to treated water and appropriately added the Water Chemistry and One-Time Inspection Programs to manage this aging effect.
In reviewing LRA Table 3.1.2-1, the staff noted that it indicates no aging effects for stainless steel piping, piping components, and piping elements exposed to silicone fluid environments.
Note J for this AMR line indicates that neither the component nor the material and environment combination is evaluated in the GALL Report and plant-specific Note 116 states, The silicone fluid is the capillary fluid for the instrumentation. This fluid is controlled to preclude the introduction of contaminants. The design of the component inherently resists the intrusion of water; therefore, the environment is considered benign to stainless steel. The staff agrees that chemically silicone fluid is nearly inert and has no adverse effect on stainless steel. On this basis, the staff finds that stainless steel in a silicone fluid environment exhibits no aging effect and that the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.3.2 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Incore Instrumentation System - LRA Table 3.1.2-2 The staff reviewed LRA Table 3.1.2-2, which summarizes the results of AMR evaluations for the incore instrumentation system component groups.
In reviewing LRA Table 3.1.2-1, the staff noted that it states no aging effect and AMP for stainless steel flux thimble tubes and valves internally exposed to wetted air or gas. Note G for these line items indicates that the environment is not in the GALL Report for this component and material and Note 111 states that this internal environment is not normally likely to have condensation; however, the LRA refers to GALL Report Volume 2, item IV.E-2 for stainless steel components externally exposed to "Air - Indoor uncontrolled. The staff noted that the only GALL Report item specifically for flux thimble tubes or flux thimble isolation valves is item IV.B2-13 for flux thimble tubes in reactor coolant environments, not applicable to this LRA line item; therefore, the applicant appropriately used one of the Common Miscellaneous Material Environmental Combinations in GALL Report Table IV.E for determination of the aging 3-227
 
effect for flux thimble tube surfaces exposed to air. On this basis, the staff finds the applicants determination of no aging effect for stainless steel flux thimble tubes exposed to indoor air acceptable.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.3.3 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Coolant System - LRA Table 3.1.2-3 The staff reviewed LRA Table 3.1.2-3, which summarizes the results of AMR evaluations for the reactor coolant system component groups.
In reviewing LRA Table 3.1.2-3, the staff noted that it indicates Loss of Fracture Toughness Due to Thermal Embrittlement as an aging effect or mechanism for CASS piping, piping components, and piping elements internally exposed to treated water environments. Note I for this line item indicates that neither the component nor the material and environment combination is evaluated in the GALL Report for this component, material, and environment combination. Note 109 states that elbows in the primary loop piping are fabricated from SA351 CF8A material and Note 118 states that this component has been screened and found not susceptible to thermal aging embrittlement based on information in a letter from C.I. Grimes (USNRC) to D. Walters (NEI), License Renewal Issue No. 98-0030, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Components," May 19, 2000; therefore, the LRA states "None" for the AMP required to manage loss of fracture toughness due to thermal embrittlement. During the audit the staff asked the applicant to explain how CASS piping and piping components exposed to treated water environments with loss of fracture toughness embrittlement were screened out based on the criteria in the May 19, 2000, letter.
In its response dated August 20, 2007, the applicant stated that:
Per Table 3 of the Grimes Letter, valve bodies and pump casings do not require a susceptibility evaluation because both susceptible and non-susceptible components are examined to ASME Section XI requirements. As shown on page 3.1-62 of the LRA, CASS components of the Reactor Vessel Internals are managed by the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program (B.2.6) for Loss of Fracture Toughness due to Thermal Embrittlement. The remaining population of CASS components that require a susceptibility review included the Reactor Coolant Loop elbows and the Pressurizer Spray Head. The d-ferrite level for the Reactor Coolant Loop elbows was calculated as part of the leak-before-break evaluation performed in WCAP-14549-P, Addendum 1, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the Harris Nuclear Plant for the License Renewal Program. The reactor coolant loop elbows are low-molybdenum statically cast components. Since the 3-228
 
maximum calculated d-ferrite level is # 20 percent, the elbows are not susceptible to thermal aging. For the Pressurizer Spray Head, the Certified Material Test Report (CMTR) information was reviewed and the d-ferrite level calculated. The resultant d-ferrite level was below the screening threshold regardless of casting method; therefore, the Pressurizer Spray Head is not susceptible to thermal aging.
Since the population of components reviewed for thermal aging were shown not to be susceptible to thermal aging, the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is not required for License Renewal.
The staff reviewed specific details of the material composition and casting methods during the audit and found the applicants evaluation of CASS components for susceptibility to thermal aging acceptable. The staff also agreed with the applicant that the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is not appropriate as the CASS components are not susceptible to thermal aging.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.3.4 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Coolant Pump and Motor - LRA Table 3.1.2-4 The staff reviewed LRA Table 3.1.2-4, which summarizes the results of AMR evaluations for the reactor coolant pump and motor component groups.
In reviewing LRA Table 3.1.2-4, the staff noted that it states loss of material due to galvanic corrosion as an aging effect for RCP oil spill protection system piping fabricated from carbon or low-alloy steel internally exposed to lubricating oil or hydraulic fluid environments. Note H for this line item indicates that the aging effect is not in the GALL Report for this component, material, and environment combination. The LRA credits the Lubricating Oil Analysis Program and the One-Time Inspection Program to manage this aging effect. It also lists GALL Report item VII.G-26, for which the aging effect is loss of material due to general, pitting, and crevice corrosion.
During the audit, the staff asked the applicant to explain why the LRA refers to GALL Report item VII.G-26 for this line item and the how Lubricating Oil Analysis and One-Time Inspection Programs manage loss of material due to galvanic corrosion when aging mechanisms are not defined in LRA Sections B.2.18 and B.2.25.
In its response dated August 20, 2007, the applicant stated that the LRA refers to GALL Report, item VII.G 26 (A 83) for this item because the component has been subject to loss of material due to general, pitting, and crevice corrosion. The applicant added that this AMR line item 3-229
 
environment is lubricating oil. The oil collection piping consists of both carbon steel and stainless steel sections. Carbon steel piping is connected to stainless steel piping and, as the lubricating oil can contain moisture, "galvanic corrosion" is an aging mechanism. Consistent with the GALL Report, the Lubricating Oil Analysis Program "maintains oil systems contaminants (primarily water and particulates) within acceptable limits." Therefore, because galvanic corrosion requires an electrolyte for the mechanism to occur, the program is appropriate to manage the aging effect. No operating experience suggests loss of material for these components; therefore, the One-Time Inspection Program is adequate to verify whether the aging effect occurs. The staffs evaluation of the applicants Lubricating Oil Analysis Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively.
The staff finds the applicants response acceptable because it conservatively determined loss of material due to galvanic corrosion as an aging effect for the carbon or low-alloy steel RCP oil spill protection system piping exposed to lubricating oil and appropriately explained how this aging effect is managed by HNP AMPs.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.3.5 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Pressurizer - LRA Table 3.1.2-5 The staff reviewed LRA Table 3.1.2-5, which summarizes the results of AMR evaluations for the pressurizer component groups.
In reviewing LRA Table 3.1.2-5, the staff noted that it states Loss of Fracture Toughness Due to Thermal Embrittlement as an aging effect or mechanism for CASS pressurizer spray heads exposed to treated water environments. Note I for this line item indicates that neither the component nor the material and environment combination is evaluated in the GALL Report for this component, material, and environment combination. Note 109 states that elbows in the primary loop piping are fabricated from SA351 CF8A material and Note 118 states that this component has been screened and found not susceptible to thermal aging embrittlement based on information in a letter from C.I. Grimes (NRC) to D. Walters (NEI), License Renewal Issue No. 98-0030, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Components,"
May 19, 2000; therefore, the LRA states "None" for the AMP required to manage loss of fracture toughness due to thermal embrittlement. During the audit the staff asked the applicant to explain how CASS pressurizer spray head exposed to treated water environments with loss of fracture toughness embrittlement were screened out based on the criteria in the May 19, 2000 letter.
In its letter dated August 20, 2007, the applicant stated that:
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Per Table 3 of the Grimes Letter, valve bodies and pump casings do not require a susceptibility evaluation because both susceptible and non-susceptible components are examined to ASME Section XI requirements. As shown on page 3.1-62 of the LRA, CASS components of the Reactor Vessel Internals are managed by the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program (B.2.6) for Loss of Fracture Toughness due to Thermal Embrittlement. The remaining population of CASS components that require a susceptibility review included the Reactor Coolant Loop elbows and the Pressurizer Spray Head. The d-ferrite level for the Reactor Coolant Loop elbows was calculated as part of the leak-before-break evaluation performed in WCAP-14549-P, Addendum 1, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the Harris Nuclear Plant for the License Renewal Program. The reactor coolant loop elbows are low-molybdenum statically cast components. Since the maximum calculated d-ferrite level is # 20 percent, the elbows are not susceptible to thermal aging. For the Pressurizer Spray Head, the Certified Material Test Report (CMTR) information was reviewed and the d-ferrite level calculated. The resultant d-ferrite level was below the screening threshold regardless of casting method; therefore, the Pressurizer Spray Head is not susceptible to thermal aging.
Since the population of components reviewed for thermal aging were shown not to be susceptible to thermal aging, the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is not required for License Renewal.
The staff reviewed specific details of the material composition and casting methods during the audit and found the applicants evaluation of the CASS components for susceptibility to thermal aging acceptable. The staff also agreed with the applicant that the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is not appropriate because the CASS components are not susceptible to thermal aging.
In reviewing LRA Table 3.1.2-5, the staff noted it includes AMR entries for the pressurizer spray nozzle and surge nozzle thermal sleeves exposed to treated water. The AMR line items assuring the M-6 intended function of the thermal sleeves (i.e., a thermal insulation function) conclude that there were no AERMs. In these AMR items Footnote 113 states that loss of material and cracking are aging effects but need no management because they will not impact the ability of the thermal sleeves to perform the M-6 thermal insulation function. During the audit, the staff requested from the applicant technical basis for the conclusion that loss of material and cracking in these thermal sleeves do not reduce or eliminate their ability to insulate the pressurizer spray and surge nozzles from the impacts of thermal cycling.
In its response dated December 11, 2007, the applicant revised the LRA Table 3.1.2-5 AMR line items for the pressurizer surge and spray nozzles thermal sleeves to change the aging effects in treated water to SCC and loss of material due to crevice and pitting corrosion. For these components SCC will be managed by a combination of the Water Chemistry Program and the One-Time Inspection Program. The Water Chemistry Program will manage loss of material for stainless steel pressurizer spray and surge nozzle thermal sleeves exposed to 3-231
 
treated water. The applicants response added that the Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking and loss of material aging effects. The One-Time Inspection Program either verifies that unacceptable degradation has not occurred or triggers additional actions to maintain intended functions of affected components during the period of extended operation. The staff's evaluation of the applicant's Water Chemistry Program and One-Time Inspection Program are documented in SER Section 3.0.3.1.1 and 3.0.3.1.5, respectively.
The staff finds this response acceptable because it adequately revised the AMR line items in Table 3.1.2-1 to include loss of material and cracking of stainless steel pressurizer spray and surge nozzles thermal sleeves exposed to treated water and appropriately added the Water Chemistry and One-Time Inspection Programs for managing these aging effects.
LRA Table 3.1.2-5 proposes to use the Bolting Integrity Program for managing loss of material due to wear for pressurizer manway nuts and studs fabricated of high-strength carbon or low-alloy steel in indoor air environments. Note H for this AMR result indicates that the aging effect is not in the GALL Report for this component, material, and environment combination. For similarity, LRA Table 3.1.2-5 for this AMR line refers to GALL Report item IV.C2-8, which recommends the Bolting Integrity Program for managing loss of preload for low-alloy closure bolting in air. The staffs evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5. The Bolting Integrity Program description states the program utilizes industry recommendations and EPRI guidance that considers material properties, joint-gasket design, chemical control, service requirements, and industry and plant-specific operating experience in specifying torque and closure requirements. On the basis of its review of plant-specific and industry operating experience, the staff determined that use of the Bolting Integrity Program to manage loss of material due to wear is a conservative approach; therefore, the staff finds that the aging effect of loss of material due to wear in pressurizer manway nuts and studs is effectively managed by the Bolting Integrity Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.2.3.6 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Steam Generator - LRA Table 3.1.2-6 The staff reviewed LRA Table 3.1.2-6, which summarizes the results of AMR evaluations for the steam generator component groups.
In reviewing LRA Table 3.1.2-6, the staff noted that it includes several AMR items on loss of material due to pitting and crevice corrosion and on SCC in feedwater nozzle and auxiliary feedwater nozzle thermal sleeves exposed to treated water and credits the Water Chemistry Program and the One-time Inspection Program to manage these component aging effects. The staff determined that the scope of the One-Time Inspection Program, as stated in the LRA, does not specifically include the feedwater nozzle and auxiliary feedwater nozzle thermal 3-232
 
sleeves. During the audit, the staff asked the applicant:
: a. To clarify whether any other AMPs credited periodically examine these thermal sleeves. If there are alternate AMPs, why it is acceptable to credit the One-Time Inspection Program as the means of managing loss of material and cracking of these thermal sleeves in lieu of the alternate AMPs? Amend AMP B.1.28, One-Time Inspection Program, to include the feedwater nozzle and auxiliary feedwater nozzle thermal sleeves within the scope of the AMP.
: b. The staff opinion is that cracking or loss of material in the feedwater and auxiliary feedwater nozzle thermal sleeves may impact their ability to protect the feedwater and auxiliary feedwater nozzles from thermal cycling and thus their M-6 thermal insulation function. Provide your technical basis for concluding that loss of material or cracking would not impact the M-6 thermal insulation function for these thermal sleeves.
In its response dated August 20, 2007, the applicant stated that:
: a. Loss of material from pitting and crevice corrosion and cracking from SCC of the feedwater nozzle thermal sleeves and auxiliary feedwater nozzle thermal sleeves are managed by a combination of the Water Chemistry Program and the One-Time Inspection Program. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the subject aging effects. The One-Time Inspection Program provides an inspection that either verifies that unacceptable degradation is not occurring or triggers additional actions that assure the intended function of affected components will be maintained during the period of extended operation.
The basis document for the One-Time Inspection Program includes the feedwater nozzle thermal sleeves and auxiliary feedwater nozzle thermal sleeves in the one-time inspections to verify effectiveness of the Water Chemistry Program. This level of detail is not provided in the LRA AMP description.
: b. The LRA and the bases documents for the Water Chemistry and One-Time Inspection Program will be amended/revised to include, for the feedwater and auxiliary feedwater nozzles' M-6 Function, the Water Chemistry and One-Time Inspection Programs to manage the aging effects.
During the audit, the staff reviewed the Water Chemistry Program and One-Time Inspection Program bases documents and finds the applicants response acceptable because it committed to revise the LRA and the bases documents for the feedwater and auxiliary feedwater nozzle thermal sleeves with thermal insulation intended function (M-6 Function) to include the Water 3-233
 
Chemistry and One-Time Inspection Programs to manage the cracking and loss of material aging effects.
In reviewing LRA Table 3.1.2-6, the staff noted that it credits the One-Time Inspection Program to manage loss of material due to general, pitting, or crevice corrosion, and in some cases SCC, in the following component commodity groups:
* steam generator feedwater impingement plate and support
* feedwater distribution ring and support
* feedwater distribution ring spray nozzles
* auxiliary feedwater internal spray pipe
* moisture separator assembly
* miscellaneous nonpressure boundary steam generator internals (a)    The staff noted that the steam generator feedwater impingement plate and support, feedwater distribution ring and support, feedwater distribution ring spray nozzle, and auxiliary feedwater internal spray pipe commodity groups are within the scope of AMP B.2.18, One-Time Inspection Program. The staff asked the applicant to clarify whether any other AMPs credited in the LRA periodically examine these commodity groups and, if so, why it credits the One-Time Inspection Program for managing loss of material (and in some cases cracking) in these commodity groups in lieu of the alternate AMPs.
(b)    The staff determined that the One-Time Inspection Program does not specify that the steam generator moisture separator assembly is within its scope. The staff asked the applicant to clarify whether any other AMPs credited in the LRA periodically examine the steam generator moisture separator assembly and, if so, why it credits the One-Time Inspection Program for managing loss of material in this component in lieu of crediting the alternate AMPs. The staff asked the applicant to amend AMP B.2.18, One-Time Inspection Program, appropriately to include the steam generator moisture separator assembly within its scope if the component is not included.
(c)    The staff also asked the applicant to define the specific steam generator commodity groups the term "Miscellaneous Non-Pressure Boundary Internals," and to state why it is acceptable to credit the One-Time Inspection Program for managing loss of material and cracking in each of these steam generator nonpressure boundary internals. The staff asked the applicant to amend the One-Time Inspection Program specifically to place these nonpressure boundary internals with the scope of this AMP.
In its response dated August 20, 2007, the applicant stated that:
The One-Time Inspection Program basis document provides a description of Program Scope by tabulating for each material-environment combination: system number/system name, and component inspected/description. Each table also provides aging effects and component intended functions.
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: a. The steam generator feedwater impingement plate and support, feedwater distribution ring and support, feedwater distribution ring spray nozzles, auxiliary feedwater internal spray pipe commodity groups are managed by the Water Chemistry Program and the One-Time Inspection Program.
For those components that are carbon steel, the aging effects managed are loss of material from pitting, crevice and general corrosion. For those components that are nickel based alloys, the aging effects managed are loss of material from pitting and crevice corrosion and SCC.
The basis for why it acceptable to credit the Water Chemistry Program and the One-Time Inspection Program as the means for managing the subject aging effects is as follows:
Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the subject aging effects. The One-Time Inspection Program provides an inspection that either verifies that unacceptable degradation is not occurring or triggers additional actions that assure the intended function of affected components will be maintained during the period of extended operation.
In addition to the prevention and mitigation of the aging effects provided by the Water Chemistry Program, the One Time Inspection Program will rely on established NDE techniques, including visual, and/or volumetric techniques that are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR 50, Appendix B. The inspection and test techniques will have a demonstrated history of effectiveness in detecting the aging effect of concern. Evidence of degradation will result in evaluation by Engineering for repair/replacement in accordance with the Corrective Action Program. Acceptance criteria will be based on construction code, manufacturer's recommendations, engineering evaluation, or metallurgical examination, as appropriate.
: b. The steam generator moisture separator assembly commodity group is managed by the Water Chemistry Program and the One-Time Inspection Program. For the carbon steel steam generator moisture separator assembly, the aging effects managed are loss of material from pitting, crevice and general corrosion.
The basis for why it acceptable to credit the Water Chemistry Program and the One-Time Inspection Program as the means for managing the subject aging effects is as follows:
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Water Chemistry Program monitors and controls water chemistry using site procedures and processes for the prevention or mitigation of the subject aging effects. The One-Time Inspection Program provides an inspection that either verifies that unacceptable degradation is not occurring or triggers additional actions that assure the intended function of affected components will be maintained during the period of extended operation.
In addition to the prevention and mitigation of the aging effects provided by the Water Chemistry Program, the One Time Inspection Program will rely on established NDE techniques, including visual, and/or volumetric techniques that are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR 50, Appendix B. The inspection and test techniques will have a demonstrated history of effectiveness in detecting the aging effect of concern. Evidence of degradation will result in evaluation by Engineering for repair/replacement in accordance with the Corrective Action Program. Acceptance criteria will be based on construction code, manufacturer's recommendations, engineering evaluation, or metallurgical examination, as appropriate.
The basis document for the One-Time Inspection Program includes the subject components in the one-time inspections to verify effectiveness of the Water Chemistry Program. This level of detail is not provided in the LRA AMP description.
: c. The steam generator Miscellaneous Non-Pressure Boundary Internals commodity group is managed by the Water Chemistry Program and the One-Time Inspection Program. For those components that are carbon steel, the aging effects managed are loss of material from pitting, crevice and general corrosion. For those components that are nickel based alloys or stainless steel, the aging effects managed are loss of material from pitting and crevice corrosion and SCC.
Examples of the steam generator Miscellaneous Non-Pressure Boundary Internals include, primary separators, secondary separator vanes, various plates, stay rods and spacer pipes.
These components will be added to the basis document Evaluation Group Tables.
The basis for why it acceptable to credit the Water Chemistry Program and the One-Time Inspection Program as the means for managing the subject aging effects is as follows:
Water Chemistry Program monitors and controls water chemistry using site 3-236
 
procedures and processes for the prevention or mitigation of the subject aging effects. The One-Time Inspection Program provides an inspection that either verifies that unacceptable degradation is not occurring or triggers additional actions that assure the intended function of affected components will be maintained during the period of extended operation.
In addition to the prevention and mitigation of the aging effects provided by the Water Chemistry Program, the One Time Inspection Program will rely on established NDE techniques, including visual, and/or volumetric techniques that are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR 50, Appendix B. The inspection and test techniques will have a demonstrated history of effectiveness in detecting the aging effect of concern. Evidence of degradation will result in evaluation by Engineering for repair/replacement in accordance with the Corrective Action Program.
Acceptance criteria will be based on construction code, manufacturer's recommendations, engineering evaluation, or metallurgical examination, as appropriate.
The basis document for the One-Time Inspection Program includes the subject components in the one-time inspections to verify effectiveness of the Water Chemistry Program. This level of detail is not provided in the LRA AMP description.
The staff determined that the Water Chemistry Program and the One Time Inspection Program will be adequate to manage (a) loss of material from pitting, crevice, and general corrosion for carbon steel components and SCC and loss of material from pitting, crevice, and general corrosion for nickel-based alloy components, (b) loss of material from pitting, crevice, and general corrosion for the carbon steel steam generator moisture separator assembly, and (c) loss of material from pitting, crevice, and general corrosion for carbon steel and SCC and loss of material from pitting, crevice and general corrosion for nickel-based alloy components in the steam generator Miscellaneous Non-Pressure Boundary Internals commodity group of LRA Table 3.1.2-6.
The applicant proposed to manage the aging effect of cracking due to thermal fatigue in stainless steel instrument manifolds and valves exposed to treated water environments using a TLAA evaluated for the period of extended operation. The applicant used Note F for this AMR result, indicating that the material is not in the GALL Report for this component. The staffs review of the applicants evaluation of this TLAA is documented in SER Section 4.3. On the basis of its review of this TLAA, the staff finds the AMR result acceptable.
The applicant proposed to manage reduction of heat transfer effectiveness due to fouling of heat transfer surfaces in nickel alloy steam generator tubes exposed to treated water using the Water Chemistry Program. The applicant used Notes H and 117 for these AMR results. Note H indicates that aging effect is not in the GALL Report for this component, material, and environment combination and Note 117 states, No HNP operating experience has been identified for fouling of steam generator tubes. The absence of fouling is considered largely due to the plant water chemistry program; therefore, Reduction of Heat Transfer has been identified 3-237
 
as an aging effect that is managed by water chemistry. The staffs evaluation of the Water Chemistry Program is documented in SER Section 3.0.3.1.1. The program monitors and controls water chemistry using procedures and processes to prevent or mitigate the loss of material and cracking aging effects.
On the basis of its review of plant-specific and industry operating experience, the staff finds that the environment of these components will be monitored and controlled and the aging effect of reduction of heat transfer effectiveness due to fouling in steam generator tubes exposed to treated water effectively mitigated by the Water Chemistry Program.
The applicant proposed the Water Chemistry Program and the Steam Generator Tube Integrity Program to manage loss of material due to crevice and pitting corrosion in stainless steel steam generator tube support plates and flow distribution baffles fabricated of stainless steel in treated water. The applicant used Note F, which indicates that the material is not in the GALL Report for this component. The Water Chemistry Program monitors and controls water chemistry using procedures and processes to prevent or mitigate the loss of material and cracking aging effects. The Steam Generator Tube Integrity Program manages aging effects by a balance of prevention, inspection, evaluation, repair, and leakage monitoring. The staffs evaluation of the applicants Water Chemistry program is documented in SER Section 3.0.3.1.1, of the applicants Steam Generator Tube Integrity Program in SER Section 3.0.3.2.6.
On the basis of its review of plant-specific and industry operating experience, the staff finds that the aging effect of loss of material due to crevice and pitting corrosion in the steam generator support plates and flow distribution baffles exposed to treated water effectively managed by the Water Chemistry and Steam Generator Tube Integrity Programs.
The applicant proposed the Water Chemistry and Steam Generator Tube Integrity Programs to manage loss of material due to pitting corrosion in steam generator anti-vibration bars fabricated of stainless steel and nickel alloy in treated water. The applicant used Note H, which indicates that the aging effect is not in the GALL Report for this component, material, and environment combination. The Water Chemistry Program monitors and controls water chemistry using procedures and processes to prevent or mitigate the loss of material and cracking aging effects. The Steam Generator Tube Integrity Program manages aging effects by a balance of prevention, inspection, evaluation, repair, and leakage monitoring. The staffs evaluation of the applicants Water Chemistry program is documented in SER Section 3.0.3.1.1, of the applicants Steam Generator Tube Integrity Program in SER Section 3.0.3.2.6.
On the basis of its review of plant-specific and industry operating experience, the staff finds the aging effect of loss of material due to pitting corrosion in the steam generator anti vibration bars exposed to treated water effectively managed by the Water Chemistry and Steam Generator Tube Integrity Programs.
The applicant proposed the Water Chemistry Program to manage SCC in the steam nozzle flow limiters fabricated of nickel-base alloy and exposed to treated water. Note H for these AMR results indicates that aging effect is not in the GALL Report for this component, material, and environment combination and Note 108 states that for the purposes of alignment the steam nozzle flow limiter is an extension of the Main Steam System as described in GALL Report 3-238
 
item VIII.B1. The staffs evaluation of the Water Chemistry Program is documented in SER Section 3.0.3.1.1. The program monitors and controls water chemistry using procedures and processes to prevent or mitigate the loss of material and cracking aging effects.
On the basis of its review of plant-specific and industry operating experience, the staff finds that the environment of these components will be monitored and controlled and the aging effect of SCC in steam nozzle flow limiters exposed to treated water effectively mitigated by the Water Chemistry Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1.3 Conclusion The staff concludes that the applicant has provided sufficient information to demonstrate that the effects of aging for the reactor vessel, RVI, and reactor coolant system components within the scope of license renewal and subject to an AMR will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2 Aging Management of Engineered Safety Features System This section of the SER documents the staffs review of the applicants AMR results for the engineered safety feature system components and component groups of:
* containment spray system
* containment isolation system
* high-head safety injection system
* low-head safety injection and residual heat removal system
* passive safety injection system
* control room area ventilation system 3.2.1 Summary of Technical Information in the Application LRA Section 3.2 provides AMR results for the engineered safety feature system components and component groups. LRA Table 3.2.1, Summary of Aging Management Evaluations in Chapter V of NUREG-1801 for Engineered Safety Features, is a summary comparison of the applicants AMRs with those evaluated in the GALL Report for the engineered safety feature system components and component groups.
The applicants AMRs evaluated and incorporated applicable plant-specific and industry operating experience in the determination of AERMs. The plant-specific evaluation included 3-239
 
condition reports and discussions with appropriate site personnel to identify AERMs. The applicants review of industry operating experience included a review of the GALL Report and operating experience issues identified since the issuance of the GALL Report.
3.2.2 Staff Evaluation The staff reviewed LRA Section 3.2 to determine whether the applicant provided sufficient information to demonstrate that the effects of aging for the engineered safety feature system components within the scope of license renewal and subject to an AMR, will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
The staff conducted an onsite audit of AMRs to ensure the applicants claim that certain AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters described in the GALL Report; however, the staff did verify that the material presented in the LRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The staffs evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs audit evaluation are documented in SER Section 3.2.2.1.
In the onsite audit, the staff also selected AMRs consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicants further evaluations were consistent with the SRP-LR Section 3.2.2.2 acceptance criteria. The staffs audit evaluations are documented in SER Section 3.2.2.2.
The staff also conducted a technical review of the remaining AMRs not consistent with or not addressed in the GALL Report. The technical review evaluated whether all plausible aging effects have been identified and whether the aging effects listed were appropriate for the material-environment combinations specified. The staffs evaluations are documented in SER Section 3.2.2.3.
For SSCs which the applicant claimed were not applicable or required no aging management, the staff reviewed the AMR line items and the plants operating experience to verify the applicants claims.
Table 3.2-1 summarizes the staffs evaluation of components, aging effects or mechanisms, and AMPs listed in LRA Section 3.2 and addressed in the GALL Report.
Table 3.2-1 Staff Evaluation for Engineered Safety Features System Components in the GALL Report 3-240
 
Component Group      Aging Effect/    AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism          Report      Evaluation Supplements, Item No.)                                          in GALL        or Report    Amendments Steel and stainless  Cumulative      TLAA, evaluated in Yes        TLAA          Consistent with steel piping, piping fatigue damage  accordance with                              GALL Report, which components, and                      10 CFR 54.21(c)                              recommends further piping elements in                                                                evaluation (See emergency core                                                                    SER cooling system                                                                    Section 3.2.2.2.1)
(3.2.1-1)
Steel with stainless Loss of material A plant-specific  Yes        Not applicable Not applicable to steel cladding pump  due to cladding  aging management                            HNP (See SER casing exposed to    breach          program is to be                            Section 3.2.2.2.2) treated borated                      evaluated.
water (3.2.1-2)                            Reference NRC Information Notice 94-63, Boric Acid Corrosion of Charging Pump Casings Caused by Cladding Cracks Stainless steel      Loss of material Water Chemistry    Yes        Not applicable Not applicable containment          due to pitting  and One-Time                                (See SER isolation piping and and crevice      Inspection                                  Section 3.2.2.2.3) components internal  corrosion surfaces exposed to treated water (3.2.1-3)
Stainless steel      Loss of material A plant-specific  Yes        Not applicable Not applicable to piping, piping      due to pitting  aging management                            HNP (See SER components, and      and crevice      program is to be                            Section 3.2.2.2.3) piping elements      corrosion        evaluated.
exposed to soil (3.2.1-4)
Stainless steel and  Loss of material Water Chemistry    Yes        Not applicable Not applicable to aluminum piping,    due to pitting  and One-Time                                PWRs (See SER piping components,  and crevice      Inspection                                  Section 3.2.2.2.3.3) and piping elements  corrosion exposed to treated water (3.2.1-5)
Stainless steel and  Loss of material Lubricating Oil    Yes        Not applicable Not applicable to copper alloy piping, due to pitting  Analysis and                                HNP (See SER piping components,  and crevice      One-Time                                    Section 3.2.2.2.3) and piping elements  corrosion        Inspection exposed to lubricating oil (3.2.1-6) 3-241
 
Component Group        Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Partially encased    Loss of material  A plant-specific    Yes        One-Time        Consistent with stainless steel tanks due to pitting    aging management              Inspection      GALL Report, which with breached        and crevice      program is to be              (B.2.18)        recommends further moisture barrier      corrosion        evaluated for                                  evaluation (See exposed to raw                          pitting and crevice                            SER water                                  corrosion of tank                              Section 3.2.2.2.3)
(3.2.1-7)                              bottoms because moisture and water can egress under the tank due to cracking of the perimeter seal from weathering.
Stainless steel      Loss of material  A plant-specific    Yes        Not applicable  Not applicable to piping, piping        due to pitting    aging management                              HNP (See SER components, piping    and crevice      program is to be                              Section 3.2.2.2.3) elements, and tank    corrosion        evaluated.
internal surfaces exposed to condensation (internal)
(3.2.1-8)
Steel, stainless      Reduction of      Lubricating Oil    Yes        Lubricating Oil Not applicable to steel, and copper    heat transfer due Analysis and                  Analysis        ESFS (See SER alloy heat            to fouling        One-Time                      Program        Section 3.2.2.2.4) exchanger tubes                        Inspection                    (B.2.25) exposed to                                                            and One-Time lubricating oil                                                        Inspection (3.2.1-9)                                                              (B.2.18)
Stainless steel heat  Reduction of      Water Chemistry    Yes        Water          Consistent with exchanger tubes      heat transfer due and One-Time                  Chemistry      GALL Report, which exposed to treated    to fouling        Inspection                    (B.2.2) and    recommends further water                                                                  One-Time        evaluation (See (3.2.1-10)                                                            Inspection      SER (B.2.18)        Section 3.2.2.2.4)
Elastomer seals and  Hardening and    A plant-specific    Yes        Not applicable  Not applicable to components in        loss of strength  aging management                              PWRs (See SER standby gas          due to elastomer  program is to be                              Section 3.2.2.2.5) treatment system      degradation      evaluated.
exposed to air -
indoor uncontrolled (3.2.1-11) 3-242
 
Component Group        Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Stainless steel      Loss of material  A plant-specific    Yes        Inspection of  Not applicable to high-pressure safety due to erosion    aging management              Internal        ESFS (See SER injection (charging)                    program is to be              Surfaces in    Section 3.2.2.2.6) pump miniflow                          evaluated for                  Miscellaneous orifice exposed to                      erosion of the                Piping and treated borated                        orifice due to                Ducting water                                  extended use of                Components (3.2.1-12)                              the centrifugal                Program HPSI pump for                  (B.2.24) normal charging.
Steel drywell and    Loss of material  A plant-specific    Yes        Not applicable  Not applicable to suppression          due to general    aging management                              PWRs (See SER chamber spray        corrosion and    program is to be                              Section 3.2.2.2.7) system nozzle and    fouling          evaluated.
flow orifice internal surfaces exposed to air - indoor uncontrolled (internal)
(3.2.1-13)
Steel piping, piping  Loss of material Water Chemistry      Yes        Not applicable  Not applicable to components, and      due to general,  and One-Time                                  PWRs (See SER piping elements      pitting, and      Inspection                                    Section 3.2.2.2.8) exposed to treated    crevice corrosion water (3.2.1-14)
Steel containment    Loss of material Water Chemistry      Yes        Not applicable  Not applicable (See isolation piping,    due to general,  and One-Time                                  SER piping components,    pitting, and      Inspection                                    Section 3.2.2.2.8) and piping elements  crevice corrosion internal surfaces exposed to treated water (3.2.1-15)
Steel piping, piping  Loss of material  Lubricating Oil    Yes        Lubricating Oil Not applicable to components, and      due to general,  Analysis and                  Analysis        ESFS (See SER piping elements      pitting, and      One-Time                      Program        Section 3.2.2.2.8) exposed to            crevice corrosion Inspection                    (B.2.25) lubricating oil                                                        and One-Time (3.2.1-16)                                                            Inspection (B.2.18)
Steel (with or        Loss of material  Buried Piping and  No        Not applicable  Not applicable to without coating or    due to general,  Tanks Surveillance                            HNP (See SER wrapping) piping,    pitting, crevice,                                                Section 3.2.2.2.9) piping components,    and              or and piping elements  microbiologically buried in soil        -influenced corrosion        Buried Piping and  Yes (3.2.1-17)
Tanks Inspection 3-243
 
Component Group        Aging Effect/      AMP in GALL      Further  AMP in LRA,      Staff Evaluation (GALL Report          Mechanism            Report      Evaluation Supplements, Item No.)                                            in GALL          or Report    Amendments Stainless steel      Cracking due to  BWR Stress        No        Not applicable    Not applicable to piping, piping        stress corrosion  Corrosion Cracking                              PWRs components, and      cracking and      and Water piping elements      intergranular    Chemistry exposed to treated    stress corrosion water > 60EC          cracking
(> 140EF)
(3.2.1-18)
Steel piping, piping  Wall thinning    Flow-Accelerated  No        Not applicable    Not applicable to components, and      due to            Corrosion                                      PWRs piping elements      flow-accelerated exposed to steam or  corrosion treated water (3.2.1-19)
Cast austenitic      Loss of fracture  Thermal Aging      No        Not applicable    Not applicable to stainless steel      toughness due    Embrittlement of                                PWRs piping, piping        to thermal aging  CASS components, and      embrittlement piping elements exposed to treated water (borated or unborated) > 250EC
(> 482EF)
(3.2.1-20)
High-strength steel  Cracking due to  Bolting Integrity  No        Not applicable    Not applicable to closure bolting      cyclic loading,                                                  HNP (See SER exposed to air with  stress corrosion                                                  Section 3.2.2.1.1) steam or water        cracking leakage (3.2.1-21)
Steel closure bolting Loss of material  Bolting Integrity  No        Bolting Integrity Consistent with exposed to air with  due to general                                  Program (B.2.8) GALL Report steam or water        corrosion leakage (3.2.1-22)
Steel bolting and    Loss of material Bolting Integrity  No        Bolting Integrity Consistent with closure bolting      due to general,                                Program (B.2.8) GALL Report exposed to air -      pitting, and outdoor (external),  crevice corrosion or air - indoor uncontrolled (external)
(3.2.1-23)
Steel closure bolting Loss of preload  Bolting Integrity  No        Bolting Integrity Consistent with exposed to air -      due to thermal                                  Program (B.2.8) GALL Report indoor uncontrolled  effects, gasket (external)            creep, and (3.2.1-24)            self-loosening 3-244
 
Component Group      Aging Effect/    AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report    Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Stainless steel      Cracking due to  Closed-Cycle    No        Closed-Cycle  Consistent with piping, piping      stress corrosion  Cooling Water              Cooling Water  GALL Report components, and      cracking          System                      System piping elements                                                    Program exposed to closed                                                  (B.2.11) cycle cooling water
> 60EC (> 140EF)
(3.2.1-25)
Steel piping, piping Loss of material Closed-Cycle      No        Not applicable Not applicable to components, and      due to general,  Cooling Water                              HNP (See SER piping elements      pitting, and      System                                    Section 3.2.2.1.1) exposed to closed    crevice corrosion cycle cooling water (3.2.1-26)
Steel heat          Loss of material  Closed-Cycle    No        Closed-Cycle  Consistent with exchanger            due to general,  Cooling Water              Cooling Water  GALL Report components          pitting, crevice, System                      System exposed to closed    and galvanic                                  Program cycle cooling water  corrosion                                    (B.2.11)
(3.2.1-27)
Stainless steel      Loss of material  Closed-Cycle    No        Closed-Cycle  Consistent with piping, piping      due to pitting    Cooling Water              Cooling Water  GALL Report components, piping  and crevice      System                      System elements, and heat  corrosion                                    Program exchanger                                                          (B.2.11) components exposed to closed-cycle cooling water (3.2.1-28)
Copper alloy piping, Loss of material  Closed-Cycle    No        Not applicable Not applicable to piping components,  due to pitting,  Cooling Water                              HNP (See SER piping elements,    crevice, and      System                                    Section 3.2.2.1.1) and heat exchanger  galvanic components          corrosion exposed to closed cycle cooling water (3.2.1-29)
Stainless steel and  Reduction of      Closed-Cycle    No        Closed-Cycle  Consistent with copper alloy heat    heat transfer due Cooling Water              Cooling Water  GALL Report exchanger tubes      to fouling        System                      System exposed to closed                                                  Program cycle cooling water                                                (B.2.11)
(3.2.1-30) 3-245
 
Component Group      Aging Effect/      AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation Supplements, Item No.)                                            in GALL        or Report    Amendments External surfaces of Loss of material  External Surfaces    No        Not applicable Not applicable to steel components    due to general    Monitoring                                    HNP (See SER including ducting,  corrosion                                                        Section 3.2.2.1.1) piping, ducting closure bolting, and containment isolation piping external surfaces exposed to air -
indoor uncontrolled (external);
condensation (external) and air -
outdoor (external)
(3.2.1-31)
Steel piping and    Loss of material  Inspection of        No        Not applicable Not applicable to ducting components due to general      Internal Surfaces in                          HNP (See SER and internal        corrosion        Miscellaneous                                  Section 3.2.2.1.1) surfaces exposed to                    Piping and Ducting air - indoor                          Components uncontrolled (Internal)
(3.2.1-32)
Steel encapsulation  Loss of material  Inspection of        No        Not applicable Not applicable to components          due to general,  Internal Surfaces in                          HNP (See SER exposed to air -    pitting, and      Miscellaneous                                  Section 3.2.2.1.1) indoor uncontrolled  crevice corrosion Piping and Ducting (internal)                            Components (3.2.1-33)
Steel piping, piping Loss of material  Inspection of        No        Not applicable Not applicable to components, and      due to general,  Internal Surfaces in                          HNP (See SER piping elements      pitting, and      Miscellaneous                                  Section 3.2.2.1.1) exposed to          crevice corrosion Piping and Ducting condensation                          Components (internal)
(3.2.1-34)
Steel containment    Loss of material  Open-Cycle          No        Not applicable Not applicable to isolation piping and due to general,  Cooling Water                                  HNP (See SER components internal  pitting, crevice, System                                        Section 3.2.2.1.1) surfaces exposed to  and raw water            microbiologically (3.2.1-35)          -influenced corrosion, and fouling 3-246
 
Component Group      Aging Effect/      AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation Supplements, Item No.)                                            in GALL        or Report    Amendments Steel heat          Loss of material  Open-Cycle        No        Not applicable Not applicable to exchanger            due to general,  Cooling Water                                HNP (See SER components          pitting, crevice, System                                      Section 3.2.2.1.1) exposed to raw      galvanic, and water                microbiologically (3.2.1-36)          -influenced corrosion, and fouling Stainless steel      Loss of material  Open-Cycle        No        Not applicable Not applicable to piping, piping      due to pitting,  Cooling Water                                HNP (See SER components, and      crevice, and      System                                      Section 3.2.2.1.1) piping elements      microbiologically exposed to raw      -influenced water                corrosion (3.2.1-37)
Stainless steel      Loss of material  Open-Cycle        No        Not applicable Not applicable to containment          due to pitting,  Cooling Water                                HNP (See SER isolation piping and crevice, and      System                                      Section 3.2.2.1.1) components internal  microbiologically surfaces exposed to  -influenced raw water            corrosion, and (3.2.1-38)          fouling Stainless steel heat Loss of material  Open-Cycle        No        Not applicable Not applicable to exchanger            due to pitting,  Cooling Water                                HNP (See SER components          crevice, and      System                                      Section 3.2.2.1.1) exposed to raw      microbiologically water                -influenced (3.2.1-39)          corrosion, and fouling Steel and stainless  Reduction of      Open-Cycle        No        Not applicable Not applicable to steel heat          heat transfer due Cooling Water                                HNP (See SER exchanger tubes      to fouling        System                                      Section 3.2.2.1.1)
(serviced by open-cycle cooling water) exposed to raw water (3.2.1-40)
Copper alloy        Loss of material  Selective Leaching No        Not applicable Not applicable to
> 15% Zn piping,    due to selective  of Materials                                HNP (See SER piping components,  leaching                                                      Section 3.2.2.1.1) piping elements, and heat exchanger components exposed to closed cycle cooling water (3.2.1-41) 3-247
 
Component Group      Aging Effect/      AMP in GALL        Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Gray cast iron      Loss of material  Selective Leaching  No        Not applicable Not applicable to piping, piping      due to selective  of Materials                                  HNP (See SER components, piping  leaching                                                        Section 3.2.2.1.1) elements exposed to closed-cycle cooling water (3.2.1-42)
Gray cast iron      Loss of material  Selective Leaching  No        Not applicable Not applicable to piping, piping      due to selective  of Materials                                  HNP (See SER components, and      leaching                                                        Section 3.2.2.1.1) piping elements exposed to soil (3.2.1-43)
Gray cast iron motor Loss of material  Selective Leaching  No        Not applicable Not applicable to cooler exposed to    due to selective  of Materials                                  HNP (See SER treated water        leaching                                                        Section 3.2.2.1.1)
(3.2.1-44)
Aluminum, copper    Loss of material Boric Acid            No        Boric Acid    Consistent with alloy > 15% Zn, and  due to Boric acid Corrosion                      Corrosion      GALL Report steel external      corrosion                                        Program surfaces, bolting,                                                    (B.2.4) and piping, piping components, and piping elements exposed to air with borated water leakage (3.2.1-45)
Steel encapsulation  Loss of material  Inspection of        No        Not applicable Not applicable to components          due to general,  Internal Surfaces in                          HNP (See SER exposed to air with  pitting, crevice  Miscellaneous                                  Section 3.2.2.1.1) borated water        and boric acid    Piping and Ducting leakage (internal)  corrosion        Components (3.2.1-46)
Cast austenitic      Loss of fracture  Thermal Aging        No        Not applicable Not applicable to stainless steel      toughness due    Embrittlement of                              HNP (See SER piping, piping      to thermal aging  CASS                                          Section 3.2.2.1.1) components, and      embrittlement piping elements exposed to treated borated water
> 250EC (> 482EF)
(3.2.1-47) 3-248
 
Component Group        Aging Effect/    AMP in GALL    Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism          Report    Evaluation Supplements, Item No.)                                        in GALL        or Report    Amendments Stainless steel or    Cracking due to  Water Chemistry No        Water          Consistent with stainless-steel-clad stress corrosion                            Chemistry      GALL Report steel piping, piping  cracking                                    Program (B.2.2) components, piping elements, and tanks (including safety injection tanks/accumulators) exposed to treated borated water
> 60EC (> 140EF)
(3.2.1-48)
Stainless steel      Loss of material Water Chemistry No        Water          Consistent with piping, piping        due to pitting                              Chemistry      GALL Report components, piping    and crevice                                Program (B.2.2) elements, and tanks  corrosion exposed to treated borated water (3.2.1-49)
Aluminum piping,      None            None            No        None            Consistent with piping components,                                                                GALL Report and piping elements exposed to air -
indoor uncontrolled (internal/external)
(3.2.1-50)
Galvanized steel      None            None            No        Not applicable  Not applicable to ducting exposed to                                                                HNP (See SER air - indoor                                                                      Section 3.2.2.1.1) controlled (external)
(3.2.1-51)
Glass piping          None            None            No        Not applicable  Not applicable to elements exposed                                                                  HNP (See SER to air - indoor                                                                  Section 3.2.2.1.1) uncontrolled (external),
lubricating oil, raw water, treated water, or treated borated water (3.2.1-52) 3-249
 
Component Group      Aging Effect/  AMP in GALL    Further  AMP in LRA,    Staff Evaluation (GALL Report      Mechanism        Report    Evaluation  Supplements, Item No.)                                      in GALL        or Report    Amendments Stainless steel,    None          None            No        None          Consistent with copper alloy, and                                                            GALL Report nickel alloy piping, piping components, and piping elements exposed to air -
indoor uncontrolled (external)
(3.2.1-53)
Steel piping, piping None          None            No        Not applicable Not applicable to components, and                                                              HNP (See SER piping elements                                                              Section 3.2.2.1.1) exposed to air -
indoor controlled (external)
(3.2.1-54)
Steel and stainless  None          None            No        Not applicable Not applicable to steel piping, piping                                                          HNP (See SER components, and                                                              Section 3.2.2.1.1) piping elements in concrete (3.2.1-55)
Steel, stainless    None          None            No        None          Consistent with steel, and copper                                                            GALL Report alloy piping, piping components, and piping elements exposed to gas (3.2.1-56)
Stainless steel and  None          None            No        None          Consistent with copper alloy                                                                  GALL Report
< 15% Zn piping, piping components, and piping elements exposed to air with borated water leakage (3.2.1-57)
The staffs review of the engineered safety features system component groups followed any one of several approaches. One approach, documented in SER Section 3.2.2.1, reviewed AMR results for components that the applicant indicated are consistent with the GALL Report and require no further evaluation. Another approach, documented in SER Section 3.2.2.2, reviewed AMR results for components that the applicant indicated are consistent with the GALL Report and for which further evaluation is recommended. A third approach, documented in SER Section 3.2.2.3, reviewed AMR results for components that the applicant indicated are not consistent with, or not addressed in, the GALL Report. The staffs review of AMPs credited to manage or monitor aging effects of the engineered safety features system components is 3-250
 
documented in SER Section 3.0.3.
3.2.2.1 AMR Results Consistent with the GALL Report LRA Section 3.2.2.1 identifies the materials, environments, AERMs, and the following programs that manage aging effects for the engineered safety features system components:
* Water Chemistry Program
* Boric Acid Corrosion Program
* Bolting Integrity Program
* One-Time Inspection Program
* External Surfaces Monitoring Program
* Closed Cycle Cooling Water System Program LRA Tables 3.2.2-1 through 3.2.2-4 summarize AMRs for the engineered safety features system components and indicate AMRs claimed to be consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant claimed consistency with the report and for which it does not recommend further evaluation, the staffs audit and review determined whether the plant-specific components of these GALL Report component groups were bounded by the GALL Report evaluation.
The applicant noted for each AMR line item how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with Notes A through E indicating how the AMR is consistent with the GALL Report.
Note A indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report and validity of the AMR for the site-specific conditions.
Note B indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report and verified that the identified exceptions to the GALL Report AMPs have been reviewed and accepted. The staff also determined whether the applicants AMP was consistent with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
Note C indicates that the component for the AMR line item, although different from, is consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. This note indicates that the applicant was unable to find a listing of some system components in the GALL Report; however, the applicant identified in the GALL Report a different component with the same material, environment, aging effect, and AMP as the component under review. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the AMR line item of the 3-251
 
different component was applicable to the component under review and whether the AMR was valid for the site-specific conditions.
Note D indicates that the component for the AMR line item, although different from, is consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP takes some exceptions to the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report. The staff verified whether the AMR line item of the different component was applicable to the component under review and whether the identified exceptions to the GALL Report AMPs have been reviewed and accepted. The staff also determined whether the applicants AMP was consistent with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
Note E indicates that the AMR line item is consistent with the GALL Report for material, environment, and aging effect, but credits a different AMP. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the credited AMP would manage the aging effect consistently with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
The staff audited and reviewed the information in the LRA. The staff did not repeat its review of the matters described in the GALL Report; however, the staff did verify that the material presented in the LRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The staffs evaluation follows.
3.2.2.1.1 AMR Results Identified as Not Applicable LRA Table 3.2.1 shows items 3.2.1-02, -03, -04, -05, -06, -08, -09, -11, -12, -13, -14, -15, -16,
-17, -18, -19, -20, -21, -26, -29, -31, -32, -33, -34, -35, -36, -37, -38, -39, -40, -41, -42, -43, -44,
-46, -47, -51, -52, -54, and -55 as Not Applicable as either there is no such component, material, and environment combination for HNP engineered safety feature systems, the combination is present at BWR plants only, or the components are evaluated with their parent systems in other sections. For each of these items, the staff reviewed the LRA and supporting documents and confirmed the applicants claim that the component, material, and environment combination does not exist in HNP engineered safety feature systems. On the basis that HNP engineered safety feature systems do not have the component, material, and environment combination for these Table 1 items, the staff concurs with the applicants conclusion that these AMRs do not apply to HNP engineered safety feature systems.
The staff evaluated the applicants claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicants consideration of recent operating experience and proposals for managing aging effects. On the basis of its review, the staff concludes that the AMR results, which the applicant claimed to be consistent with the GALL Report, are indeed consistent with its AMRs; therefore, the staff concludes that the applicant has demonstrated that the effects of aging for these components will be adequately managed so that their intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3-252
 
3.2.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended In LRA Section 3.2.2.2, the applicant further evaluates aging management, as recommended by the GALL Report, for the engineered safety features system components and provides information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* loss of material due to cladding breach
* loss of material due to pitting and crevice corrosion
* reduction of heat transfer due to fouling
* hardening and loss of strength due to elastomer degradation
* loss of material due to erosion
* loss of material due to general corrosion and fouling
* loss of material due to general, pitting, and crevice corrosion
* loss of material due to general, pitting, crevice, and MIC
* QA for aging management of nonsafety-related components For component groups evaluated in the GALL Report, for which the applicant claimed consistency with the report and for which the report recommends further evaluation, the staff audited and reviewed the applicants evaluation to determine whether it adequately addressed the issues further evaluated. In addition, the staff reviewed the applicants further evaluations against the criteria contained in SRP-LR Section 3.2.2.2.The staffs review of the applicants further evaluation follows.
3.2.2.2.1 Cumulative Fatigue Damage LRA Section 3.2.2.2.1 states that fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). SER Section 4.3 documents the staffs review of the applicants evaluation of this TLAA.
3.2.2.2.2 Loss of Material Due to Cladding Breach The staff reviewed LRA Section 3.2.2.2.2 against the criteria in SRP-LR Section 3.2.2.2.2.
LRA Section 3.2.2.2.2 addresses loss of material due to cladding breach, stating that this aging effect is not present because the charging pumps are fabricated from stainless steel and not from carbon steel with stainless steel cladding.
SRP-LR Section 3.2.2.2.2 and GALL Report, Volume 1, Table 2, AMR Item 2, state that loss of material due to cladding breach may occur in PWR steel pump casings with stainless steel cladding exposed to treated borated water.
Based on the review of the LRA and the applicants supporting documents, the staff confirmed 3-253
 
that residual heat removal pumps, containment spray pumps, and safety-injection/charging pumps are fabricated from stainless steel and not from carbon steel with interior stainless steel cladding surfaces. Based on this review, the staff concludes that the AMR evaluation in SRP-LR Section 3.2.2.2.2 and GALL Report, Volume 1, Table 2, AMR Item 2, do not apply to HNP engineered safety feature systems because there are no steel pump casings with stainless steel cladding exposed to treated borated water in the engineered safety feature systems at HNP.
3.2.2.2.3 Loss of Material Due to Pitting and Crevice Corrosion The staff reviewed LRA Section 3.2.2.2.3 against the following criteria in SRP-LR Section 3.2.2.2.3:
(1)  LRA Section 3.2.2.2.3 addresses loss of material due to pitting and crevice corrosion in internal surfaces of stainless steel containment isolation components, stating that such internal surfaces exposed to treated water are evaluated with their parent system. If loss of material due to pitting and crevice corrosion occurs, an appropriate AMP is credited.
SRP-LR Section 3.2.2.2.3 and GALL Report, Volume 1, Table 2, AMR Item 3, state that loss of material due to pitting and crevice corrosion may occur on internal surfaces of stainless steel containment isolation piping, piping components, and piping elements exposed to treated water. The existing AMP monitors and controls water chemistry to mitigate degradation; however, control of water chemistry does not preclude loss of material due to pitting and crevice corrosion at locations with stagnant flow conditions; therefore, the effectiveness of water chemistry control programs should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to verify the effectiveness of water chemistry control programs. A one-time inspection of selected components at susceptible locations is an acceptable method to determine whether an aging effect is occurring or is slowly progressing such that the components intended functions will be maintained during the period of extended operation.
The discussion column of Table 3.2.1, item 3.2.1-03, applicant states that HNP manages loss of material due to pitting and crevice corrosion of stainless steel containment isolation piping and components internal surfaces exposed to treated water with a combination of the Water Chemistry Program and the One-Time Inspection Program consistent with the GALL Report.
The staff reviewed the Water Chemistry Program, which monitors chlorides, fluorides, and dissolved oxygen to limit the contaminants, minimize the occurrences of aging effects, and maintain component ability to perform intended functions. The applicant stated that the One-Time Inspection Program will verify the effectiveness of the Water Chemistry Program and confirm the absence of any aging effect. The One-Time Inspection Program inspects select stainless steel components exposed to treated water at susceptible locations like stagnant areas for loss of material due to pitting and crevice corrosion in engineered safety feature systems. The staff evaluations of the Water Chemistry Program and the One-Time Inspection Program are documented in SER 3-254
 
Sections 3.0.3.1.1 and 3.0.3.1.5, respectively. The staff finds these programs consistent with GALL Report recommendations and adequate to manage loss of material due to pitting and crevice corrosion on internal surfaces of stainless steel containment isolation piping and components exposed to treated water.
However, the applicant stated that the internal surfaces of containment isolation piping and components exposed to treated water are being evaluated with their parent system.
The staff determined that the applicant should have aligned this AMR to GALL Report, Volume 2, AMR Item V.C-2, and not to AMR Item V.A-27.
The staffs review of LRA Section 3.2.2.2.3 identified an area in which additional information was necessary to complete the review of the applicants AMR results. The applicant responded to the staffs RAI as discussed below.
In RAI 3.2-1, Part A, dated January 7, 2008, the staff asked the applicant to justify referencing GALL AMR Item V.A-27 in lieu of AMR Item V.C-4 for stainless steel containment isolation piping and component surfaces that are exposed to a treated water environment. Specifically, the staff asked the applicant to provide its basis for not coupling a one-time inspection of these components to the Water Chemistry Program to manage loss of material due crevice corrosion and pitting corrosion in the components, as is recommended in GALL Report, Volume 2, AMR Item V.C-4.
In its response dated January 17, 2008, the applicant clarified that the water inventory in the subject components is borated and that due to this environment, the AMR for these components is consistent with the AMR provided by the staff in GALL AMR Item V.A-27.
In GALL AMR Item V.A-27, the staff does not recommend that a one-time inspection be coupled with an applicants Water Chemistry Program because the treated water environment is treated with boric acid, which is an effective corrosion inhibitor. Thus the staffs recommendation in GALL AMR Item V.A-27 considers that the Water Chemistry Program would be sufficient to mitigate loss of material due to pitting or crevice corrosion in stainless steel ESF components that are exposed to a borated, treated water environment.
Based on its review, the staff finds the applicants response to RAI 3.2-1, Part A, acceptable because the applicant clarified that the environment is that for borated treated water. The staff concludes that it is valid for the applicant to use GALL AMR Item V.A-27 as the basis for the applicants AMR on loss of material due to pitting or crevice corrosion for the stainless piping, piping components, piping elements, and tanks that are exposed to a borated treated water environment. The staffs concern described in RAI 3.2-1, Part A, is resolved.
(2) LRA Section 3.2.2.2.3 addresses loss of material due to pitting and crevice corrosion in buried stainless steel components, stating that this aging effect is not present because the engineered safety feature systems have no piping components exposed to soil.
SRP-LR Section 3.2.2.2.3 and GALL Report, Volume 1, Table 2, AMR Item 4, state that 3-255
 
loss of material due to pitting and crevice corrosion may occur in stainless steel piping, piping components, and piping elements exposed to soil.
Based on the review of the LRA and the applicants supporting documents, the staff confirmed that the engineered safety feature systems have no piping components exposed to soil and concludes that the AMR evaluation in SRP-LR Section 3.2.2.3.2 and GALL Report, Volume 1, Table 2, AMR Item 4, do not apply to HNP engineered safety feature systems because there are no stainless steel piping, piping components, or piping elements in engineered safety feature systems exposed to soil.
(3) LRA Section 3.2.2.2.3 addresses loss of material due to pitting and crevice corrosion in BWR stainless steel and aluminum piping, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.2.2.2.3 and GALL Report, Volume 1, Table 2, AMR Item 5, state that loss of material due to pitting and crevice corrosion may occur in BWR stainless steel and aluminum piping, piping components, and piping elements exposed to treated water.
This further evaluation does not apply to HNP, a PWR plant.
(4) LRA Section 3.2.2.2.3 addresses loss of material due to pitting and crevice corrosion in stainless steel and copper alloy piping components in lubricating oil, stating that loss of material could occur for stainless steel and copper alloy piping, piping components, and piping elements exposed to lubricating oil. Components exposed to lubricating oil are charging and safety injection pumps.
SRP-LR Section 3.2.2.2.3 and GALL Report, Volume 1, Table 2, AMR Item 6, state that loss of material due to pitting and crevice corrosion may occur in engineered safety feature stainless steel and copper alloy piping, piping components, and piping elements exposed to lubricating oil. The existing program periodically samples and analyzes lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment that is not conducive to corrosion; however, control of lube oil contaminants may not always be fully effective in precluding corrosion; therefore, the effectiveness of lubricating oil control should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation to verify the effectiveness of the lubricating oil programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
The discussion column of LRA Table 3.2.1, AMR item 3.2.1-06, states that the AMPs credited to manage loss of material due to pitting and crevice corrosion of stainless steel and copper alloy piping, piping components, and piping elements exposed to lubricating oil are the Lubricating Oil Analysis Program and One-Time Inspection Program. The applicant clarified that LRA Section 3.3.2.1.1 further evaluates this item and that the 3-256
 
Type 2 AMR items for these engineered safety feature components are in LRA Table 3.3.2-1.
The staff verified that the AMR items for these engineered safety feature components are in LRA Table 3.3.2-1, including the charging and safety-injection pump (CSIP) gear lube oil pumps, gear oil cooler components, and the charging and safety-injection pump lube oil components. The staff also verified that the AMR items for these components credit both the Lubricating Oil Analysis Program and the One-Time Inspection Program to manage loss of material due to pitting and crevice corrosion for component surfaces exposed to lubricating oil. The staffs evaluation of the applicants Lubricating Oil Analysis Program and One-Time Inspection Program is documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. On this basis, the staff finds that the Lubricating Oil Analysis Program and One-Time Inspection Programs adequately manage loss of material due to pitting and crevice corrosion for CSIP subcomponents exposed to lubricating oil.
(5) LRA Section 3.2.2.2.3 addresses loss of material due to pitting and crevice corrosion in bottom surfaces of stainless steel tanks, stating that loss of material due to pitting, crevice, and MIC could occur for stainless steel tank bottoms exposed to raw water. The refueling water storage tank rests on a concrete pad. Although not a partially-encased tank with a moisture barrier as described in the GALL Report, the refueling water storage tank enclosure is subject to radio-chemistry controls; therefore, it is not drained automatically. Rainwater pool levels in the tank area could exceed the top of the 6-in.
tank pad, and rainwater (raw water) could seep into the gap below the tank bottom. Loss of material will be managed by the One-Time Inspection Program, which either verifies that unacceptable degradation has not occurred or triggers additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.2.2.2.3 and GALL Report, Volume 1, Table 2, AMR Item 7, state that loss of material due to pitting and crevice corrosion may occur in partially encased stainless steel tanks exposed to raw water due to cracking of the perimeter seal from weathering. The GALL Report recommends further evaluation to ensure that the aging effect is adequately managed. The GALL Report recommends that a plant-specific AMP be evaluated because moisture and water can egress under the tank if the perimeter seal is degraded.
The applicant proposed the One-Time Inspection Program to manage loss of material due to pitting and crevice corrosion for bottom surfaces of stainless steel tanks. The staff asked the applicant for the basis for crediting the One-Time Inspection Program to manage such loss of material for bottom surfaces of stainless steel refueling water storage tank exposed to raw water environments.
The applicant responded that this item represents corrosion resulting from water seepage underneath the refueling water storage tank. The tank area enclosure for the refueling water storage tank does not drain automatically; therefore, standing rainwater may accumulate to levels above the tank pad elevation.
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Chemistry procedures guide sampling of drainage water before its release from the tank area. Results of sampling for radioactive contamination are reported to operations for release of the water to storm drain system or its return for liquid radwaste system processing.
The staff noted that the One-Time Inspection Program is normally used to verify the effectiveness of other mitigative or preventative programs, such as chemistry control programs, and do not include procedures to enhance the environment so that it is not conducive to pitting and crevice corrosion.
The staffs review of LRA Section 3.2.2.2.3 identified areas in which additional information was necessary to complete the review of the applicants AMR results. The applicant responded to the staffs RAIs as discussed below.
In RAI 3.2-1, Part B, dated January 7, 2008, the staff asked the applicant to provide its basis for crediting the One-Time Inspection Program alone to manage loss of material due to pitting and crevice corrosion for items referencing LRA Item 3.2.1-7, and why the Water Chemistry Program is also not credited for these tanks, particularly when the applicant is relying on plant-specific chemistry procedures to sample and test the water inventory in these tanks.
In its response dated January 17, 2008, the applicant clarified that the AMR on loss of material due to pitting or crevice corrosion applies to the external surfaces of the bottom surface of the refueling water storage tank and that the environment for these component surface is external raw water. The applicant clarified that the AMR for the bottom external surface of the refueling water storage tank is that for rainwater. The applicant clarified that the applicant samples the rainwater dripping from the tanks only to do an assay of the entrapped rainwater to ensure that no radioactive contamination of the outside environment is occurring and that the testing is not for the presence of ionic chemical species. Thus, the applicant has clarified that its Water Chemistry Program does not rely on testing of rainwater seepage for ionic impurities.
Based on its review, the staff finds the applicants response to RAI 3.2-1, Part B, because the applicant clarified that the testing of the rainwater is only for radioactive contamination. The staff concludes that the applicant does not rely on its Water Chemistry Program to control potential corrosion in the external surfaces that are exposed to the external raw water/entrapped rainwater environment and that, as such, the applicant does not need to couple the Water Chemistry Program to the One-Time Inspection Program that the applicant has credited for the external refueling water storage tank bottom surface. The staffs concern described in RAI 3.2-1, Part B, is resolved.
From industry operating experience, the staff recognizes that stainless steel components exposed to accumulated water for limited durations should not experience significant degradation. The staff finds a one-time inspection to confirm whether significant degradation has occurred acceptable. The staffs evaluation of the applicants One-Time Inspection Program is documented in SER 3.0.3.1.5. The staff determined 3-258
 
that this programs inspections and NDE examination techniques are consistent with GALL Report recommendations and adequate to detect loss of material due to pitting and crevice corrosion for stainless steel tanks exposed to raw water. On this basis, the staff finds that the applicant has met the criteria of SRP-LR Section 3.2.2.2.3, item 5, for further evaluation.
(6) LRA Section 3.2.2.2.3 addresses loss of material due to pitting and crevice corrosion in stainless steel components exposed to internal condensation, stating that this aging effect is not present because HNP Engineered safety feature systems do not have this material and environment combination.
SRP-LR Section 3.2.2.2.3 and GALL Report, Volume 1, Table 2, AMR Item 8, state that loss of material due to pitting and crevice corrosion may occur in stainless steel piping, piping components, piping elements, and tanks exposed to internal condensation.
In RAI 3.2-2 dated January 7, 2008, the staff asked the applicant to provide its basis for concluding that the ESF systems do not include stainless steel components or component areas that are exposed to or subject to internal condensation.
In its response dated January 17, 2008, the applicant clarified that the AMRs refer to the internal gas/water interfaces for the following stainless steel components:
* in the containment spray system: the refueling water storage tank and the containment spray additive tank
* in the passive safety injection system: the cold leg accumulators The applicant clarified that the atmospheric environment for two of these component types, (i.e., for the containment spray additive tank and the cold leg accumulators) is that for dry nitrogen and that this gas does not create an environment which is conducive for condensation. Dry nitrogen gas is an inert dry gaseous environment. This environment does not create opportunities for water condensation on the internal surfaces of the components exposed to the nitrogen environment and does not create an atmospheric environment that is conducive to the initiation of corrosion (i.e. the dry nitrogen gas creates an inerted condition for stainless steel surfaces that are in contact with it). This is consistent with the basis for gas environments as discussed in GALL Report, Revision 1, Volume 2, Table IX.D.
Based on this assessment, the staff finds the applicant's response to RAI 3.2-2 acceptable because the internal surfaces of the cold leg accumulators and containment spray additive tank that are exposed to dry nitrogen gas would not be subject to condensation or corrosion resulting from condensation. The staffs concern described in RAI 3.2-2 is resolved with respect to assessing whether condensation is an applicable environment for the internal cold leg accumulator and contains spray additive tank surfaces that are inerted with dry nitrogen gas.
For the refueling water storage tank, the applicant also clarified that the refueling water 3-259
 
storage tank is a covered tank and that the internal uncontrolled air atmosphere for the refueling water storage tank is periodically vented to the outside atmosphere. The applicant also clarified that, other than during refueling outages, the refueling water storage tank is not normally subjected to large volume changes of its borated water inventory or to concomitant exchanges of internal air environment. The applicants venting of the internal air atmosphere in the refueling water storage tank will mitigate the probability that condensation will occur on the internal surfaces that are exposed to the air environment. In addition, stainless steel components are designed to resist corrosion under exposure to uncontrolled air or air with condensation environments.
Based on this assessment, the staff finds the applicants response to RAI 3.2-2 acceptable because the internal condensation is not expected for the internal surfaces of the refueling water storage tank that are exposed to the air environment because the applicant vents the system frequently enough to prevent a stagnant uncontrolled air atmosphere, that if otherwise present, could potentially induce condensation on the internal refueling water storage tank surfaces in contact with the air. The staffs concern described in RAI 3.2-2 is resolved with respect to assessing whether condensation is an applicable environment for the internal refueling water storage tank surfaces that are exposed to an uncontrolled air environment.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.2.2.2.3 criteria. For those line items that apply to LRA Section 3.2.2.2.3, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.2.4 Reduction of Heat Transfer Due to Fouling The staff reviewed LRA Section 3.2.2.2.4 against the following criteria in SRP-LR Section 3.2.2.2.4:
(1)  LRA Section 3.2.2.2.4 addresses reduction of heat transfer due to fouling of heat exchanger tubes exposed to lubricating oil, stating that reduction of heat transfer due to fouling could occur for steel, stainless steel, and copper alloy heat exchanger tubes exposed to lubricating oil. The charging and volume control system charging and safety injection pump gear oil cooler tubes have been aligned to this item based on material, environment, aging effect, and program. The applicant manages heat exchanger tubes exposed to lubricating oil with the Lubricating Oil Analysis Program in combination with the One-Time Inspection Program. The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to reduction of heat transfer due to fouling.
One-Time Inspection Program inspections either verify that no unacceptable degradation has occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.2.2.2.4 and GALL Report, Volume 1, Table 2, AMR Item 9, state that 3-260
 
reduction of heat transfer due to fouling may occur in steel, stainless steel, and copper alloy heat exchanger tubes exposed to lubricating oil. The existing AMP monitors and controls lube oil chemistry to mitigate reduction of heat transfer due to fouling; however, control of lube oil chemistry may not always be fully effective in precluding fouling; therefore, the effectiveness of lube oil chemistry control should be verified to ensure that fouling does not occur. The GALL Report recommends further evaluation of programs to verify the effectiveness of lube oil chemistry control. A one-time inspection of selected components at susceptible locations is an acceptable method to determine whether an aging effect is occurring or is slowly progressing such that the components intended functions will be maintained during the period of extended operation.
The discussion column of Table 3.2.1, item 3.2.1-09, states that the AMPs credited to manage reduction of heat transfer due to fouling of steel, stainless steel, and copper alloy heat exchanger tubes exposed to lubricating oil are the Lubricating Oil Analysis Program and the One-Time Inspection Program. The staff verified that engineered safety feature systems have no stainless steel heat exchanger tubes exposed to lubricating oil within the scope of license renewal, that the engineered safety feature components that align to AMR item 3.2.1-09 are the charging and safety-injection pump gear oil cooler tubes made of copper alloy containing less 15-percent alloying zinc, and that the AMR item to manage reduction of heat transfer of these tubes exposed to the lubricating oil environments is in LRA Table 3.3.2-1. The staff determined that, in this AMR item, the applicant credits both the Lubricating Oil Analysis Program and the One-Time Inspection Program to manage this aging effect consistent the recommendations of SRP-LR Section 3.2.2.2.4 and GALL Report, Volume 1, Table 2, AMR Item 9. The staffs evaluations of the applicants Lubricating Oil analysis Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. On these bases, the staff finds the Lubricating Oil Analysis Program and One-Time Inspection Programs adequate to manage reduction of heat transfer due to fouling for CVCS CSIP gear oil cooler tubes.
Based on this review, the staff concludes that the AMR to manage reduction of heat transfer due to fouling of the CSIP gear oil cooler tubes is consistent with the staffs recommended position in SRP-LR Section 3.2.2.2.4 and GALL Report, Volume 1, Table 2, AMR Item 9, and acceptable.
(2) LRA Section 3.2.2.2.4 addresses reduction of heat transfer due to fouling of heat exchanger tubes exposed to treated water, stating that the Water Chemistry Program together with the One-Time Inspection Program manage reduction of heat transfer due to fouling for the residual heat removal heat exchanger and seal water cooler tubes. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to mitigate or reduce heat transfer due to fouling. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.2.2.2.4 and GALL Report, Volume 1, Table 2, Item 10, state that reduction of heat transfer due to fouling may occur in stainless steel heat exchanger 3-261
 
tubes exposed to treated water. The existing program controls water chemistry to manage reduction of heat transfer due to fouling; however, control of water chemistry may be inadequate; therefore, the GALL Report recommends that the effectiveness of water chemistry control programs should be verified to ensure that reduction of heat transfer due to fouling does not occur. A one-time inspection is an acceptable method to ensure that reduction of heat transfer does not occur and that component intended functions will be maintained during the period of extended operation.
The discussion column of Table 3.2.1, item 3.2.1-10, states that HNP manages reduction of heat transfer due to fouling with a combination of the Water Chemistry Program and the One-Time Inspection Program consistent with the GALL Report.
The staff reviewed the Water Chemistry Program, which monitors chlorides, fluorides, and dissolved oxygen to limit the contaminants, minimize occurrences of aging effects, and maintain component ability to perform intended functions. The staff also reviewed the One-Time Inspection Program and verified that the programs one-time inspection of stainless steel heat exchanger tube components exposed to treated water manages reduction of heat transfer due to fouling of the surfaces of the tubes exposed to treated water. The staffs evaluations of the Water Chemistry Program and the One-Time Inspection Program are documented in SER Sections 3.0.3.1.1 and 3.0.3.1.5, respectively. The staff finds these programs consistent with GALL Report recommendations and adequate to manage loss of material due to pitting and crevice corrosion on internal surfaces of stainless steel low-head safety-injection and residual heat removal system heat exchanger tubes exposed to treated water.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.2.2.2.4 criteria. For those line items that apply to LRA Section 3.2.2.2.4, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.2.5 Hardening and Loss of Strength Due to Elastomer Degradation The staff reviewed LRA Section 3.2.2.2.5 against the criteria in SRP-LR Section 3.2.2.2.5.
LRA Section 3.2.2.2.5 addresses hardening and loss of strength due to elastomer degradation in a BWR standby gas treatment system, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.2.2.2.5 and GALL Report, Volume 1, Table 2, AMR Item 11, state that hardening and loss of strength due to elastomer degradation may occur in elastomer seals and components of the BWR standby gas treatment system ductwork and filters exposed to air - indoor uncontrolled.
This further evaluation item does not apply to HNP, a PWR plant.
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3.2.2.2.6 Loss of Material Due to Erosion The staff reviewed LRA Section 3.2.2.2.6 against the criteria in SRP-LR Section 3.2.2.2.6.
LRA Section 3.2.2.2.6 addresses loss of material due to erosion, stating that such loss of material could occur in the stainless steel high-pressure safety injection (HPSI) pump mini-flow recirculation orifices exposed to treated borated water. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages loss of material due to erosion of the stainless steel HPSI pump miniflow recirculation orifices by visual inspections for environmental conditions causing material degradation that could result in loss of component intended functions.
SRP-LR Section 3.2.2.2.6 and GALL Report, Volume 1, Table 2, Item 12, state that loss of material due to erosion may occur in the stainless steel HPSI pump miniflow recirculation orifice exposed to treated borated water. The GALL Report recommends that plant-specific AMPs be evaluated for erosion of the orifice due to extended use of the centrifugal HPSI pump for normal charging. The GALL Report references Licensee Event Report 50-275/94-023 as operating experience with erosion events in HPSI pump mini-flow recirculation orifices. Further evaluation is recommended to ensure that the aging effect is adequately managed.
The discussion column of Table 3.2.1, item 3.2.1-12, credits a plant-specific AMP to manage loss of material due to erosion of stainless steel HPSI (charging) pump miniflow orifices exposed to treated borated water. Specifically, the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages these CVCS components.
The staffs evaluation of the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The staff verified that the applicant included the AMR line item for loss of material due to erosion of the stainless steel HPSI (charging) pump miniflow orifices in LRA Section 3.3.2.1.1 and LRA Table 3.3.2-1.
The staff also verified that the AMR in LRA Table 3.3.2-1 credits the Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage this aging effect.
Based on the programs credited to manage this aging effect, the staff concludes that the applicant has credited an appropriate AMP to manage reduction of heat transfer capability in HPSI pump mini-flow recirculation orifices and that the applicants AMR is consistent with the recommended staff position in SRP-LR Section 3.2.2.2.6 and in GALL Report, Volume 1, Table 2, Item 12.
On these bases for this AMR item, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.2.7 Loss of Material Due to General Corrosion and Fouling The staff reviewed LRA Section 3.2.2.2.7 against the criteria in SRP-LR Section 3.2.2.2.7.
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LRA Section 3.2.2.2.7 addresses loss of material due to general corrosion and fouling, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.2.2.2.7 and GALL Report, Volume 1, Table 2, Item 13, state that loss of material due to general corrosion and fouling may occur in BWR steel drywell and suppression chamber spray system nozzle and flow orifice internal surfaces exposed to air - indoor uncontrolled and may cause plugging of the spray nozzles and flow orifices.
This further evaluation item does not apply to HNP, a PWR plant.
3.2.2.2.8 Loss of Material Due to General, Pitting, and Crevice Corrosion The staff reviewed LRA Section 3.2.2.2.8 against the following criteria in SRP-LR Section 3.2.2.2.8:
(1)  LRA Section 3.2.2.2.8 addresses loss of material due to general, pitting, and crevice corrosion in BWR piping exposed to treated water, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.2.2.2.8 and GALL Report, Volume 1, Table 2, Item 14, states that loss of material due to general, pitting, and crevice corrosion may occur in BWR steel piping, piping components, and piping elements exposed to treated water.
This further evaluation item does not apply to HNP, a PWR plant.
(2)  LRA Section 3.2.2.2.8 addresses loss of material due to general, pitting, and crevice corrosion in internal surfaces of containment isolation components, stating that such loss of material is possible for internal surfaces of containment isolation piping, piping components, and piping elements exposed to treated water. The applicant evaluates these internal surfaces with their parent systems and credits an appropriate AMP if loss of material due to pitting and crevice corrosion occurs.
SRP-LR Section 3.2.2.2.8 and GALL Report, Volume 1, Table 2, Item 15, states that loss of material due to general, pitting, and crevice corrosion may occur on the internal surfaces of steel containment isolation piping, piping components, and piping elements exposed to treated water. The existing AMP monitors and controls water chemistry to mitigate degradation; however, control of water chemistry does not preclude loss of material due to general, pitting, and crevice corrosion at locations with stagnant flow conditions; therefore, the effectiveness of water chemistry control programs should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to verify the effectiveness of water chemistry control programs.
A one-time inspection of selected components at susceptible locations is an acceptable method to determine whether an aging effect is occurring or is slowly progressing such that the components intended functions will be maintained during the period of extended operation.
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The discussion column of LRA Table 3.2.1, item 3.2.1-15, states that loss of material due to general, pitting, and crevice corrosion in steel containment isolation piping, piping component, and piping element internal surfaces exposed to treated water is an AERM.
The staff informed the applicant that the steel containment isolation piping and piping components discussed in LRA Table 3.2.1, AMR Item 3.2.1-15, should have been directly aligned to GALL Report, Volume 1, Table 2, AMR Item 15, and to GALL Report, Volume 2, Table V.C, AMR Item V.C-6.
The staffs review of LRA Section 3.2.2.2.8 identified an area in which additional information was necessary to complete the review of the applicants AMR results. The applicant responded to the staffs RAI as discussed below.
In RAI 3.2-1, Part C, dated January 7, 2008, the staff asked the applicant to provide its basis for why the Type 2 Table AMRs for those steel containment isolation piping, piping components, and piping elements evaluated in LRA AMR Item 3.2.1-15 have not been aligned to GALL AMR Item V.C-6. Specifically, the staff asked the applicant to provide its basis for why the further evaluation basis for these AMRs, as given in LRA AMR Item 3.2.1-15 and in LRA Section 3.2.2.2.8.2, have not credited both the One-Time Inspection Program and the Water Chemistry Program to manage loss of material due to general, pitting, and crevice corrosion in the surfaces of the containment isolation piping, piping components, and piping elements that are exposed to a treated water environment.
In its response dated January 17, 2008, the applicant clarified that there are not any AMR line items in the LRA that align to GALL AMR Item V.C-6 because there are not any containment isolation piping, piping components, or piping element that are made from carbon steel, other than the carbon steel nitrogen supply piping (including its containment isolation portions). For this piping line, the applicant clarified that the internal environment is that for dry nitrogen gas, which is different from the treated water environment that, if present, could induced the aging effects discussed in GALL AMR Item V.C-6. Dry nitrogen gas is an inert dry gaseous environment. This environment does not create opportunities for water condensation on the internal surfaces of the components exposed to the nitrogen environment and does not create an atmospheric environment that is conducive to the initiation of corrosion (i.e. the dry nitrogen gas creates an inerted condition for carbon steel surfaces that are in contact with it).
Thus, based on the applicants response, the staff concludes that SRP-LR Section 3.2.2.2.8, Item 20 and GALL AMR Item V.C-6, dealing with managing loss of material in carbon steel containment isolation piping, piping components, or piping elements under internal exposure to treated water, are not applicable to the design of the HNP containment isolation piping, piping components, and piping elements because:
(a)  there are not any containment isolation piping, piping components, or piping elements that are made from carbon steel, other than the carbon steel nitrogen supply piping (including its containment isolation portions) and those 3-265
 
containment isolation components that are exposed to a treated water environment are fabricated from austenitic stainless steel (b)    the environment for the internal surfaces of the carbon steel nitrogen supply piping (including its containment isolation portions) is that of dry nitrogen gas, which creates an inert environment for carbon steel materials Based on its review, the staff finds the applicants response to RAI 3.2-, Part C, acceptable because the applicant demonstrated a valid basis for using the Water Chemistry Program as the basis for managing loss of material due to pitting and crevice corrosion in the stainless steel containment isolation components that are exposed to treated water and for stating that there are no AERMs for the carbon steel nitrogen supply containment isolation component that are exposed internally to a dry nitrogen gas environment. The staffs concern described in RAI 3.2-1, Part C, is resolved with respect to aging management of these contain isolation components.
The staff reviewed the applicants Water Chemistry Program and its evaluation is documented in SER Section 3.0.3.1.1. The staff finds that this program includes activities that are consistent with recommendations in the GALL Report, and are adequate to manage loss of material in the components.
(3) LRA Section 3.2.2.2.8 addresses loss of material due to general, pitting, and crevice corrosion in steel piping components exposed to lubricating oil, stating that such loss of material could occur for steel piping, piping components, and piping elements exposed to lubricating oil. Although the engineered safety feature systems have no steel piping components exposed to lubricating oil, a combination of the Lubricating Oil Analysis and One-Time Inspection Programs manages loss of material for the reactor coolant pump oil cooler/heat exchanger components exposed to lubricating oil. The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to loss of material, cracking, or reduction of heat transfer. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.2.2.2.8 and GALL Report, Volume 1, Table 2, Item 16, state that loss of material due to general, pitting, and crevice corrosion may occur in steel piping, piping components, and piping elements exposed to lubricating oil. The existing program periodically samples and analyzes lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment not conducive to corrosion; however, control of lube oil contaminants may not always be fully effective in precluding corrosion; therefore, the effectiveness of lubricating oil control should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation to verify the effectiveness of lubricating oil programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
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The discussion column of Table 3.2.1, item 3.2.1-16, states that the AMPs credited to manage loss of material due to general, pitting, and crevice corrosion of steel containment isolation piping, piping components, and piping elements exposed to lubricating oil are the Lubricating Oil Analysis Program and the One-Time Inspection Program. The staffs evaluations of the applicants Lubricating Oil analysis Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The staff finds these programs consistent with GALL Report recommendations and adequate to manage loss of material due to general, pitting, and crevice corrosion; however, the applicant stated that although the engineered safety feature systems have no steel piping components exposed to lubricating oil, HNP manages RCP oil cooler/heat exchanger components with a combination of the Lubricating Oil Analysis Program and the One-Time Inspection Program. The staff verified that engineered safety feature systems have no steel piping components exposed to lubricating oil; therefore, the staff agrees that this item does not apply to HNP engineered safety feature systems.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.2.2.2.8 criteria. For those line items that apply to LRA Section 3.2.2.2.8, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.2.9 Loss of Material Due to General, Pitting, Crevice, and Microbiologically-Influenced Corrosion The staff reviewed LRA Section 3.2.2.2.9 against the criteria in SRP-LR Section 3.2.2.2.9.
LRA Section 3.2.2.2.9 addresses loss of material due to general, pitting, crevice, and MIC, stating that this aging effect is not present because the engineered safety feature systems have no piping components exposed to soil.
SRP-LR Section 3.2.2.2.9 and GALL Report, Volume 1, Table 2, Item 17, state that loss of material due to general, pitting, crevice, and MIC may occur in steel (with or without coating or wrapping) piping, piping components, and piping elements buried in soil.
The discussion column of Table 3.2.1, item 3.2.1-17, states that this item does not apply because the engineered safety feature systems have no steel piping, piping components, or piping elements exposed to soil.
Based on the review of the LRA and the applicants supporting documents, the staff verified that the engineered safety feature systems have no piping components exposed to soil within the scope of license renewal; therefore, the staff agrees that this item does not apply to HNP engineered safety feature systems.
3.2.2.2.10 Quality Assurance for Aging Management of Nonsafety-Related Components 3-267
 
SER Section 3.0.4 documents the staffs evaluation of the applicants QA program.
3.2.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report In LRA Tables 3.2.2-1 through 3.2.2-4, the staff reviewed additional details of the AMR results for material, environment, AERM, and AMP combinations not consistent with or not addressed in the GALL Report.
In LRA Tables 3.2.2-1 through 3.2.2-4, the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. The applicant provided further information about how it will manage the aging effects. Specifically, Note F indicates that the material for the AMR line item component is not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the line item component, material, and environment combination is not applicable.
Note J indicates that neither the component nor the material and environment combination for the line item is evaluated in the GALL Report.
For component type, material, and environment combinations not evaluated in the GALL Report, the staff reviewed the applicants evaluation to determine whether the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. The staffs evaluation is documented in the following sections.
3.2.2.3.1 Engineered Safety Features - Summary of Aging Management Evaluation -
Containment Spray System - LRA Table 3.2.2-1 The staff reviewed LRA Table 3.2.2-1, which summarizes the results of AMR evaluations for the containment spray system component groups.
LRA Table 3.2.2-1 includes plant-specific AMRs (as designated with annotated Note F) for stainless steel closure bolting in the containment spray system exposed to air-indoor and air-outdoor environments. In these AMRs, the applicant credited the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the bolting.
The staff reviewed the GALL Report and verified that it includes no AMR for these material, component, environment, and aging effect combinations. The staff also verified that the applicants Bolting Integrity Program is consistent with the program elements of GALL AMP XI.M.18, Bolting Integrity Program, and that program inspections monitor loss of preload, bolt loosening, and good bolting practices, which include guidelines for proper disassembly, inspection, and reassembly of connections with threaded fasteners. On the basis of this review, the staff concludes that it is valid to credit the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the containment spray 3-268
 
system for stainless steel closure bolting exposed to the air-indoor and air-outdoor environments. The staffs evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
LRA Table 3.2.2-1 includes plant-specific AMRs (as designated with annotated Note G) for stainless steel piping, piping components, and piping elements and for stainless steel refueling water storage tanks in the containment spray system exposed to air-outdoor environments. The applicant did not credit any AMPs for these component, material, and environment combinations because it concluded that there are no AERMs for stainless steel piping components and or other stainless steel components exposed to uncontrolled air-outdoor environments.
The staff verified that, although the GALL report does not include AMR items on aging of stainless steel components exposed to an air-outdoor environments, the GALL Report does include AMR Item V.F-12 with an AMR for stainless steel piping components exposed to external air-indoor environments and the position that there are no AERMs for stainless steel components exposed to such environments. The staff verified that no operating experience imply that stainless steel component surfaces exposed to uncontrolled, air-outdoor environments have AERMs; thus, the staff finds it valid to conclude that there are no AERMs for surfaces of stainless steel piping, piping components, piping elements, and refueling water storage tanks exposed to air - outdoor environments; therefore, based on this finding, the staff concludes that the applicant need not credit any AMPs for these component, environment, material, and aging effect combinations.
LRA Table 3.2.2-1 includes a plant-specific AMR (as designated with annotated Note H) on loss of material due to general, pitting, or crevice corrosion in steel (i.e., carbon or low-alloy steel) piping, piping components, and piping elements of the containment spray system exposed to air or gas (wetted inside) environments. In this AMR, the applicant credited the One-Time Inspection Program to manage loss of component material.
The staff verified that, although the GALL report does not include any AMR items on aging of steel piping, piping components, or piping elements exposed to air or gas (wetted inside) environments, the GALL Report does include AMR Item V.A-19 with an AMR for steel piping components exposed to air-indoor uncontrolled environments recommending GALL AMP XI.M38, Inspection of Internals Surfaces in Miscellaneous Piping and Ducting Components, to manage loss of material due to general, pitting, or crevice corrosion in steel piping components exposed to air-indoor uncontrolled environments. The staff asked the applicant to for a technical basis for crediting the One-Time Inspection Program to manage this aging effect.
In its response dated August 20, 2007, the applicant clarified that the gaseous atmosphere for these steel piping, piping components, and piping elements is inerted with nitrogen gas, and that in this environment corrosion is unlikely. In addition, the applicant stated that its Water Chemistry Program both monitors and controls water chemistry using site procedures and processes, including the process to monitor and sample the containment atmosphere to ensure its inertion with an acceptable level of nitrogen gas during normal plant operations, to prevent or mitigate the loss of material aging effect.
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A containment atmosphere maintained with nitrogen gas during normal plant operations creates an inert environment that precludes the initiation of corrosive aging mechanisms in the external piping surfaces; thus, the staff concludes that loss of material due to general, pitting, or crevice corrosion is not likely to occur in components exposed to nitrogen environments and that the applicants One-Time Inspection Program is proper to credit for confirmation that loss of material has not occurred in the piping components. In addition, it is valid to couple the One-Time Inspection Program with the applicants Water Chemistry Program because that program will ensure maintenance of an appropriate level of nitrogen in the containment during normal plant operations. Based on this review, the staff concludes that it is valid to credit the Water Chemistry Program and the One-Time Inspection Program to manage loss of material due to general, pitting, and crevice corrosion in these steel piping components exposed to the air or gas (wetted inside) environments. The staffs evaluations of the applicants Water Chemistry Program and One-Time Inspection Program are documented in SER Sections 3.0.3.1.1 and 3.0.3.1.5, respectively.
LRA Table 3.2.2-1 includes a plant-specific AMR (as annotated by Note J) for piping insulation in the containment spray system exposed to air-indoor environments. This AMR concludes that there are no AERMs for piping insulation for the containment spray system exposed to air-indoor environments.
The staff reviewed the GALL Report and verified that it includes no AMR item for this component, material, and environment combination. The staff also verified that there is no plant-specific or industry operating experience that would invalidate the applicants conclusion that the piping insulation is not subject to any AERM. On the basis of this review, the staff concludes that the piping insulation in the containment spray system is not subject to any AERM and that the applicant need not credit any AMP to manage the piping insulation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.3.2 Engineered Safety Features - Summary of Aging Management Evaluation - High Head Safety Injection System - LRA Table 3.2.2-2 The staff reviewed LRA Table 3.2.2-2, which summarizes the results of AMR evaluations for the high-head safety-injection system component groups.
LRA Table 3.2.2-2 includes a plant-specific AMR (as designated with annotated Note F) for stainless steel closure bolting in the high-head safety-injection system exposed to air-indoor environments. In this AMR, the applicant credited the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the bolting.
The staff reviewed the GALL Report and verified that it includes no AMR for this material, component, environment and aging effect combination. The staff also verified that the 3-270
 
applicants Bolting Integrity Program is consistent with the program elements of GALL AMP XI.M.18, Bolting Integrity Program, and that program inspections monitor loss of preload, bolt loosening, and good bolting practices, which include guidelines for proper disassembly, inspection, and reassembly of connections with threaded fasteners. On the basis of this review, the staff concludes that it is valid to credit the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the high-head safety-injection system stainless steel closure bolting exposed to air-indoor environments. The staffs evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
LRA Table 3.2.2-2 shows a plant-specific AMR (as annotated by Note J) for piping insulation in the high-head safety-injection system exposed to air-indoor environments. In this AMR, the applicant concluded that there are no AERMs for the high-head safety-injection system piping insulation exposed to air-indoor environments.
The staff reviewed the GALL Report and verified that it includes no AMR item for this component, material, and environment combination. The staff also verified that there is no plant-specific or industry operating experience that would invalidate the applicants conclusion that the piping insulation is not subject to applicable AERMs. On the basis of this review, the staff concludes that the piping insulation in the high-head safety-injection system is not subject to any applicable AERMs and that the applicant need not credit any AMPs to manage the piping insulation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.3.3 Engineered Safety Features - Summary of Aging Management Evaluation - Low Head Safety Injection System and Residual Heat Removal System - LRA Table 3.2.2-3 The staff reviewed LRA Table 3.2.2-3, which summarizes the results of AMR evaluations for the low head safety injection system and residual heat removal system component groups.
LRA Table 3.2.2-3 includes a plant-specific AMR (as designated with annotated Note F) for stainless steel closure bolting in the low head safety injection and residual heat removal system under exposure to the air-indoor (outside) environment. In this AMR, the applicant credited the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the bolting.
The staff reviewed the GALL Report and verified that it includes no AMR for this material, component, environment and aging effect combination. The staff also verified that the applicants Bolting Integrity Program is a program is consistent with the program elements of GALL AMP XI.M.18, Bolting Integrity Program, and that program inspections monitor loss of preload and bolt loosening and good bolting practices, which include for proper disassembly, inspection, and reassembly of connections with threaded fasteners. On the basis of this review, 3-271
 
the staff concludes that it is valid to credit the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the low head safety injection and residual heat removal system stainless steel closure bolting exposed to the air-indoor (outside) external environments. The staff evaluation of the Bolting Integrity Program is documented in Section 3.0.3.2.5.
LRA Table 3.2.2-3, the applicant provided a plant-specific AMR (as annotated by Note J) for piping insulation in the low head safety injection and residual heat removal system exposed to an air-indoor (outside) environments. In this AMR, the applicant concluded that there are no AERMs for the low head safety injection and residual heat removal system piping insulation exposed to an air-indoor (outside) environments.
The staff reviewed the GALL Report and verified that it includes no AMR item for this component, material, and environment combination. The staff also verified that there is no plant-specific or industry operating experience that would invalidate the applicants conclusion that the piping insulation is not subject to any AERM. On the basis of this review, the staff concludes that the piping insulation in the low-head safety-injection and residual heat removal systems is not subject to any AERM and that the applicant need not credit any AMP to manage it.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.2.3.4 Engineered Safety Features - Summary of Aging Management Evaluation - Passive Safety Injection System - LRA Table 3.2.2-4 The staff reviewed LRA Table 3.2.2-4, which summarizes the results of AMR evaluations for the passive safety injection system component groups.
LRA Table 3.2.2-3 includes a plant-specific AMR (as designated with annotated Note F) for stainless steel closure bolting in the passive safety-injection system exposed to air-indoor environments. In this AMR, the applicant credited the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the bolting.
The staff reviewed the GALL Report and verified that it includes no AMR for this material, component, environment, and aging effect combination. The staff also verified that the applicants Bolting Integrity Program is consistent with the program elements of GALL AMP XI.M.18, Bolting Integrity Program, and that program inspections monitor loss of preload, bolt loosening, and good bolting practices, which include guidelines for proper disassembly, inspection, and reassembly of connections with threaded fasteners. On the basis of this review, the staff concludes that it is valid to credit the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening in the passive safety-injection system stainless steel closure bolting exposed to air-indoor environments. The staffs 3-272
 
evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.2.3 Conclusion The staff concludes that the applicant has provided sufficient information to demonstrate that the effects of aging for the engineered safety features system components within the scope of license renewal and subject to an AMR will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3 Aging Management of Auxiliary Systems This section of the SER documents the staffs review of the applicants AMR results for the auxiliary systems components and component groups of:
* chemical and volume control system (CVCS)
* boron thermal regeneration system
* primary makeup system
* primary sampling system
* post-accident sampling system
* circulating water system
* cooling tower system
* cooling tower make-up system
* screen wash system
* main reservoir auxiliary equipment
* auxiliary reservoir auxiliary equipment
* normal service water system
* emergency service water system
* component cooling water system
* waste processing building cooling water system
* essential services chilled water system
* non-essential services chilled water system
* emergency screen wash system
* generator gas system
* hydrogen seal oil system
* emergency diesel generator system
* diesel generator fuel oil storage and transfer system 3-273
* diesel generator lubrication system
* diesel generator cooling water system
* diesel generator air starting system
* security power system
* instrument air system
* service air system
* bulk nitrogen storage system
* hydrogen gas system
* fire protection system
* storm drains system
* oily drains system
* radioactive floor drains system
* radioactive equipment drains system
* secondary waste system
* laundry and hot shower system
* upflow filter system
* potable and sanitary water system
* demineralized water system
* filter backwash system
* radiation monitoring system
* oily waste collection and separation system
* liquid waste processing system
* secondary waste treatment system
* boron recycle system
* gaseous waste processing system
* radwaste sampling system
* refueling system
* new fuel handling system
* spent fuel system
* spent fuel pool cooling system
* spent fuel pool cleanup system
* spent fuel cask decontamination and spray system
* spent resin storage and transfer system
* containment auxiliary equipment
* containment liner penetration auxiliary equipment
* security building heating, ventilating, and air conditioning (HVAC) system
* containment vacuum relief system
* bridge crane equipment
* containment pressurization system
* penetration pressurization system
* containment cooling system
* airborne radioactivity removal system 3-274
* containment atmosphere purge exhaust system
* control rod drive mechanism ventilation system
* primary shield and reactor supports cooling system
* fuel cask handling crane system
* reactor auxiliary building ventilation system
* emergency service water intake structure ventilation system
* turbine building area ventilation system
* waste processing building HVAC system
* diesel generator building ventilation system
* fuel oil transfer pump house ventilation system
* fuel handling building auxiliary equipment
* fuel handling building HVAC system
* turbine building health physics room auxiliary equipment
* polar crane auxiliary equipment
* elevator system
* technical support center HVAC system
* mechanical components in electrical systems
* monorail hoists equipment
* post-accident hydrogen system 3.3.1 Summary of Technical Information in the Application LRA Section 3.3 provides AMR results for the auxiliary systems components and component groups. LRA Table 3.3.1, Summary of Aging Management Evaluations in Chapter VII of NUREG-1801 for Auxiliary Systems, is a summary comparison of the applicants AMRs with those evaluated in the GALL Report for the auxiliary systems components and component groups.
The applicants AMRs evaluated and incorporated applicable plant-specific and industry operating experience in the determination of AERMs. The plant-specific evaluation included condition reports and discussions with appropriate site personnel to identify AERMs. The applicants review of industry operating experience included a review of the GALL Report and operating experience issues identified since the issuance of the GALL Report.
3.3.2 Staff Evaluation The staff reviewed LRA Section 3.3 to determine whether the applicant provided sufficient information to demonstrate that the effects of aging for the auxiliary systems components within the scope of license renewal and subject to an AMR, will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
The staff conducted an onsite audit of AMRs to ensure the applicants claim that certain AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters 3-275
 
described in the GALL Report; however, the staff did verify that the material presented in the LRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The staffs evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staffs audit evaluation are documented in SER Section 3.3.2.1.
In the onsite audit, the staff also selected AMRs consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicants further evaluations were consistent with the SRP-LR Section 3.3.2.2 acceptance criteria. The staffs audit evaluations are documented in SER Section 3.3.2.2.
The staff also conducted a technical review of the remaining AMRs not consistent with or not addressed in the GALL Report. The technical review evaluated whether all plausible aging effects have been identified and whether the aging effects listed were appropriate for the material-environment combinations specified. The staffs evaluations are documented in SER Section 3.3.2.3.
For SSCs which the applicant claimed were not applicable or required no aging management, the staff reviewed the AMR line items and the plants operating experience to verify the applicants claims.
Table 3.3-1 summarizes the staffs evaluation of components, aging effects or mechanisms, and AMPs listed in LRA Section 3.3 and addressed in the GALL Report.
Table 3.3-1 Staff Evaluation for Auxiliary System Components in the GALL Report Not used Not used (See SER Section 3.3.2.1.1)
Component Group      Aging Effect/    AMP in GALL          Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism          Report          Evaluation  Supplements, Item No.)                                            in GALL        or Report    Amendments Steel cranes -      Cumulative      TLAA to be            Yes        TLAA          Fatigue is a TLAA structural girders  fatigue damage  evaluated for                                  (See SER exposed to air -                    structural girders of                          Section 3.3.2.2.1) indoor uncontrolled                  cranes. See (external)                          SRP-LR (3.3.1-1)                            Section 4.7 for generic guidance for meeting the requirements of 10 CFR 54.21(c)(1)
                                      .
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Component Group      Aging Effect/      AMP in GALL      Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Steel and stainless  Cumulative        TLAA, evaluated in Yes        TLAA          Fatigue is a TLAA steel piping, piping fatigue damage    accordance with                              (See SER components, piping                    10 CFR 54.21(c)                              Section 3.3.2.2.1) elements, and heat exchanger components exposed to air -
indoor uncontrolled, treated borated water or treated water (3.3.1-2)
Stainless steel heat Reduction of      Water Chemistry    Yes        Not applicable Not applicable to exchanger tubes      heat transfer due and One-Time                                PWRs (See SER exposed to treated  to fouling        Inspection                                  Section 3.3.2.2.2) water (3.3.1-3)
Stainless steel      Cracking due to  Water Chemistry    Yes        Not applicable Not applicable to piping, piping      stress corrosion  and One-Time                                PWRs (See SER components, and      cracking          Inspection                                  Section 3.3.2.2.3) piping elements exposed to sodium pentaborate solution
> 60EC (> 140EF)
(3.3.1-4)
Stainless steel and  Cracking due to  A plant-specific  Yes        Not applicable Not applicable to stainless clad steel stress corrosion  aging management                            PWRs (See SER heat exchanger      cracking          program is to be                            Section 3.3.2.2.3) components                            evaluated.
exposed to treated water > 60EC
(> 140EF)
(3.3.1-5)
Stainless steel      Cracking due to  A plant-specific  Yes        Inspection of  Consistent with diesel engine        stress corrosion  aging management              Internal      GALL Report, which exhaust piping,      cracking          program is to be              Surfaces in    recommends further piping components,                    evaluated.                    Miscellaneous  evaluation (See and piping elements                                                  Piping and    SER exposed to diesel                                                    Ducting        Section 3.3.2.2.3) exhaust                                                              Components (3.3.1-6)                                                            Program (B.2.24) 3-277
 
Component Group    Aging Effect/      AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report      Mechanism            Report        Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Stainless steel    Cracking due to  Water Chemistry      Yes        Water        Consistent with non-regenerative  stress corrosion and a plant-specific            Chemistry    GALL Report, which heat exchanger    cracking and    verification                    Program      recommends further components        cyclic loading  program. An                    (B.2.2);      evaluation (See exposed to treated                  acceptable                      One-Time      SER borated water                      verification                    Inspection    Section 3.3.2.2.4)
> 60EC (> 140EF)                    program is to                  Program (3.3.1-7)                          include                        (B.2.18) temperature and radioactivity monitoring of the shell side water, and eddy current testing of tubes.
Stainless steel    Cracking due to  Water Chemistry      Yes        Water        Consistent with regenerative heat  stress corrosion and a plant-specific            Chemistry    GALL Report, which exchanger          cracking and    verification                    Program      recommends further components        cyclic loading  program. The AMP                (B.2.2);      evaluation (See exposed to treated                  is to be augmented              One-Time      SER borated water                      by verifying the                Inspection    Section 3.3.2.2.4)
> 60EC (> 140EF)                    absence of                      Program (3.3.1-8)                          cracking due to                (B.2.18) stress corrosion cracking and cyclic loading. A plant-specific aging management program is to be evaluated.
Stainless steel    Cracking due to  Water Chemistry      Yes        Water        Consistent with high-pressure pump stress corrosion and a plant-specific            Chemistry    GALL Report, which casing in PWR      cracking and    verification                    Program      recommends further chemical and      cyclic loading  program. The AMP                (B.2.2);      evaluation (See volume control                      is to be augmented              One-Time      SER system                              by verifying the                Inspection    Section 3.3.2.2.4)
(3.3.1-9)                          absence of                      Program cracking due to                (B.2.18) stress corrosion cracking and cyclic loading. A plant-specific aging management program is to be evaluated.
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Component Group      Aging Effect/      AMP in GALL          Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report          Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments High-strength steel  Cracking due to  Bolting Integrity. Yes        Not applicable  Not applicable (See closure bolting      stress corrosion  The AMP is to be                                SER exposed to air with  cracking, cyclic  augmented by                                    Section 3.3.2.2.4) steam or water      loading          appropriate leakage.                              inspection to detect (3.3.1-10)                            cracking if the bolts are not otherwise replaced during maintenance.
Elastomer seals and  Hardening and    A plant-specific      Yes        Inspection of  Consistent with components          loss of strength  aging management                Internal        GALL Report, which exposed to air -    due to elastomer  program is to be                Surfaces in    recommends further indoor uncontrolled  degradation      evaluated.                      Miscellaneous  evaluation (See (internal/external)                                                    Piping and      SER (3.3.1-11)                                                              Ducting        Section 3.3.2.2.5)
Components Program (B.2.24);
External Surfaces Monitoring Program (B.2.22)
Elastomer lining    Hardening and    A plant-specific      Yes        Not applicable  Not applicable (See exposed to treated  loss of strength  aging management                                SER water or treated    due to elastomer  program is to be                                Section 3.3.2.2.5) borated water        degradation      evaluated.
(3.3.1-12)
Boral, boron steel  Reduction of      A plant-specific      Yes        Water          Consistent with spent fuel storage  neutron-absorbin  aging management                Chemistry      GALL Report, which racks                g capacity and    program is to be                Program        recommends further neutron-absorbing    loss of material  evaluated.                      (B.2.2)        evaluation (See sheets exposed to    due to general                                                    SER treated water or    corrosion                                                          Section 3.3.2.2.6) treated borated water (3.3.1-13)
Steel piping, piping Loss of material  Lubricating Oil      Yes        Lubricating Oil Consistent with component, and      due to general,  Analysis and                    Analysis        GALL Report, which piping elements      pitting, and      One-Time                        Program        recommends further exposed to          crevice corrosion Inspection                      (B.2.25);      evaluation (See lubricating oil                                                        One-Time        SER (3.3.1-14)                                                              Inspection      Section 3.3.2.2.7)
Program (B.2.18) 3-279
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Steel reactor        Loss of material  Lubricating Oil      Yes        Lubricating Oil Consistent with coolant pump oil    due to general,  Analysis and                    Analysis        GALL Report, which collection system    pitting, and      One-Time                        Program        recommends further piping, tubing, and  crevice corrosion Inspection                      (B.2.25);      evaluation (See valve bodies                                                          One-Time        SER exposed to                                                            Inspection      Section 3.3.2.2.7) lubricating oil                                                        Program (3.3.1-15)                                                            (B.2.18)
Steel reactor        Loss of material  Lubricating Oil      Yes        Lubricating Oil Consistent with coolant pump oil    due to general,  Analysis and                    Analysis        GALL Report, which collection system    pitting, and      One-Time                        Program        recommends further tank exposed to      crevice corrosion Inspection to                  (B.2.25);      evaluation (See lubricating oil                        evaluate the                    One-Time        SER (3.3.1-16)                            thickness of the                Inspection      Section 3.3.2.2.7) lower portion of the            Program tank                            (B.2.18)
Steel piping, piping Loss of material Water Chemistry      Yes        Not applicable  Not applicable (See components, and      due to general,  and One-Time                                    SER piping elements      pitting, and      Inspection                                      Section 3.3.2.2.7) exposed to treated  crevice corrosion water (3.3.1-17)
Stainless steel and  Loss of          A plant-specific    Yes        Inspection of  Consistent with steel diesel engine  material/general  aging management                Internal        GALL Report, which exhaust piping,      (steel only),    program is to be                Surfaces in    recommends further piping components,  pitting and      evaluated.                      Miscellaneous  evaluation (See and piping elements  crevice corrosion                                Piping and      SER exposed to diesel                                                      Ducting        Section 3.3.2.2.7) exhaust                                                                Components (3.3.1-18)                                                            Program (B.2.24)
Steel (with or      Loss of material  Buried Piping and    No        Buried Piping  Consistent with without coating or  due to general,  Tanks Surveillance              and Tanks      GALL Report, which wrapping) piping,    pitting, crevice,                                Inspection      recommends further piping components,  and              or                              Program        evaluation (See and piping elements  microbiologically                                (B.2.20)        SER exposed to soil      influenced                                                        Section 3.3.2.2.8) corrosion        Buried Piping and    Yes (3.3.1-19)
Tanks Inspection Steel piping, piping Loss of material  Fuel Oil Chemistry  Yes        Fuel Oil        Consistent with components, piping  due to general,  and One-Time                    Chemistry      GALL Report, which elements, and tanks  pitting, crevice, Inspection                      Program        recommends further exposed to fuel oil  and                                              (B.2.16);      evaluation (See (3.3.1-20)          microbiologically                                One-Time        SER influenced                                        Inspection      Section 3.3.2.2.9) corrosion, and                                    Program fouling                                          (B.2.18) 3-280
 
Component Group        Aging Effect/    AMP in GALL      Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Steel heat          Loss of material  Lubricating Oil  Yes        Lubricating Oil Consistent with exchanger            due to general,  Analysis and                Analysis        GALL Report, which components          pitting, crevice, One-Time                    Program        recommends further exposed to          and              Inspection                  (B.2.25);      evaluation (See lubricating oil      microbiologically                              One-Time        SER (3.3.1-21)          influenced                                    Inspection      Section 3.3.2.2.9) corrosion, and                                Program fouling                                        (B.2.18)
Steel with elastomer Loss of material  Water Chemistry  Yes        Not applicable  Not applicable (See lining or stainless  due to pitting    and One-Time                                SER steel cladding      and crevice      Inspection                                  Section 3.3.2.2.10) piping, piping      corrosion (only components, and      for steel after piping elements      lining/cladding exposed to treated  degradation) water and treated borated water (3.3.1-22)
Stainless steel and  Loss of material  Water Chemistry  Yes        Not applicable  Not applicable to steel with stainless due to pitting    and One-Time                                PWRs steel cladding heat  and crevice      Inspection exchanger            corrosion components exposed to treated water (3.3.1-23)
Stainless steel and  Loss of material  Water Chemistry  Yes        Not applicable  Not applicable (See aluminum piping,    due to pitting    and One-Time                                SER piping components,  and crevice      Inspection                                  Section 3.3.2.2.10) and piping elements  corrosion exposed to treated water (3.3.1-24)
Copper alloy HVAC    Loss of material  A plant-specific  Yes        Not applicable  Not applicable (See piping, piping      due to pitting    aging management                            SER components, piping  and crevice      program is to be                            Section 3.3.2.2.10) elements exposed    corrosion        evaluated.
to condensation (external)
(3.3.1-25)
Copper alloy piping, Loss of material  Lubricating Oil  Yes        Lubricating Oil Consistent with piping components,  due to pitting    Analysis and                Analysis        GALL Report, which and piping elements  and crevice      One-Time                    Program        recommends further exposed to          corrosion        Inspection                  (B.2.25);      evaluation (See lubricating oil                                                    One-Time        SER (3.3.1-26)                                                          Inspection      Section 3.3.2.2.10)
Program (B.2.18) 3-281
 
Component Group      Aging Effect/    AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report      Mechanism            Report      Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Stainless steel      Loss of material A plant-specific  Yes        External      Consistent with HVAC ducting and    due to pitting  aging management            Surfaces      GALL Report, which aluminum HVAC        and crevice      program is to be            Monitoring    recommends further piping, piping      corrosion        evaluated.                  Program        evaluation (See components and                                                    (B.2.22)      SER piping elements                                                                  Section 3.3.2.2.10) exposed to condensation (3.3.1-27)
Copper alloy fire    Loss of material A plant-specific  Yes        Fire Water    Consistent with protection piping,  due to pitting  aging management            System        GALL Report, which piping components,  and crevice      program is to be            Program        recommends further and piping elements  corrosion        evaluated.                  (B.2.15);      evaluation (See exposed to                                                        Selective      SER condensation                                                      Leaching of    Section 3.3.2.2.10)
(internal)                                                        Materials (3.3.1-28)                                                        Program (B.2.19)
Stainless steel      Loss of material A plant-specific  Yes        Not applicable Not applicable (See piping, piping      due to pitting  aging management                            SER components, and      and crevice      program is to be                            Section 3.3.2.2.10) piping elements      corrosion        evaluated.
exposed to soil (3.3.1-29)
Stainless steel      Loss of material Water Chemistry  Yes        Not applicable Not applicable to piping, piping      due to pitting  and One-Time                                PWRs (See SER components, and      and crevice      Inspection                                  Section 3.3.2.2.10) piping elements      corrosion exposed to sodium pentaborate solution (3.3.1-30)
Copper alloy piping, Loss of material Water Chemistry  Yes        Not applicable Not applicable to piping components,  due to pitting,  and One-Time                                PWRs (See SER and piping elements  crevice, and    Inspection                                  Section 3.3.2.2.11) exposed to treated  galvanic water                corrosion (3.3.1-31) 3-282
 
Component Group        Aging Effect/      AMP in GALL      Further    AMP in LRA,    Staff Evaluation (GALL Report          Mechanism            Report      Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Stainless steel,      Loss of material  Fuel Oil Chemistry Yes        Fuel Oil        Consistent with aluminum and          due to pitting,  and One-Time                  Chemistry      GALL Report, which copper alloy piping,  crevice, and      Inspection                    Program        recommends further piping components,    microbiologically                              (B.2.16);      evaluation (See and piping elements    influenced                                      One-Time        SER exposed to fuel oil    corrosion                                      Inspection      Section 3.3.2.2.12)
(3.3.1-32)                                                            Program (B.2.18);
Fire Protection Program (B2.14)*
(*with Fuel Oil Chemistry Program applicable to diesel-driven fire pump fuel oil supply line only)
Stainless steel        Loss of material  Lubricating Oil    Yes        Lubricating Oil Consistent with piping, piping        due to pitting,  Analysis and                  Analysis        GALL Report, which components, and        crevice, and      One-Time                      Program        recommends further piping elements        microbiologically Inspection                    (B.2.25);      evaluation (See exposed to            influenced                                      One-Time        SER lubricating oil        corrosion                                      Inspection      Section 3.3.2.2.12)
(3.3.1-33)                                                            Program (B.2.18)
Elastomer seals and Loss of material    A plant-specific  Yes        Inspection of  Consistent with components            due to wear      aging management              Internal        GALL Report, which exposed to air -                        program is to be              Surfaces in    recommends further indoor uncontrolled                      evaluated.                    Miscellaneous  evaluation (See (internal or external)                                                Piping and      SER (3.3.1-34)                                                            Ducting        Section 3.3.2.2.13)
Components Program (B.2.24);
External Surfaces Monitoring Program (B.2.22) 3-283
 
Component Group        Aging Effect/      AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report          Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Steel with stainless  Loss of material  A plant-specific    Yes        Not applicable Not applicable (See steel cladding pump  due to cladding  aging management                              SER casing exposed to    breach            program is to be                              Section 3.3.2.2.14) treated borated                        evaluated.
water (3.3.1-35)                              Reference NRC IN 94-63, Boric Acid Corrosion of Charging Pump Casings Caused by Cladding Cracks.
Boraflex spent fuel  Reduction of      Boraflex Monitoring No        Boraflex      Consistent with storage racks        neutron-absorbin                                Monitoring    GALL Report (See neutron-absorbing    g capacity due to                                Program        SER sheets exposed to    boraflex                                        (B.2.12)      Section 3.3.2.1) treated water        degradation (3.3.1-36)
Stainless steel      Cracking due to  BWR Reactor        No        Not applicable Not applicable to piping, piping        stress corrosion  Water Cleanup                                PWRs components, and      cracking,        System piping elements      intergranular exposed to treated    stress corrosion water > 60EC          cracking
(> 140EF)
(3.3.1-37)
Stainless steel      Cracking due to  BWR Stress          No        Not applicable Not applicable to piping, piping        stress corrosion  Corrosion Cracking                            PWRs components, and      cracking          and Water piping elements                        Chemistry exposed to treated water > 60EC
(> 140EF)
(3.3.1-38)
Stainless steel BWR Cracking due to    Water Chemistry    No        Not applicable Not applicable (See spent fuel storage    stress corrosion                                                SER racks exposed to      cracking                                                        Section 3.3.2.1.1) treated water
> 60EC (> 140EF)
(3.3.1-39)
Steel tanks in diesel Loss of material Aboveground Steel No            Inspection of  Consistent with fuel oil system      due to general,  Tanks                          Internal      GALL Report (See exposed to air -      pitting, and                                    Surfaces in    SER outdoor (external)    crevice corrosion                                Miscellaneous  Section 3.3.2.1.11)
(3.3.1-40)                                                            Piping and Ducting Components Program (B.2.24) 3-284
 
Component Group        Aging Effect/    AMP in GALL        Further  AMP in LRA,      Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments High-strength steel  Cracking due to  Bolting Integrity  No        Not applicable    Not applicable (See closure bolting      cyclic loading,                                                  SER exposed to air with  stress corrosion                                                  Section 3.3.2.1.1) steam or water        cracking leakage (3.3.1-41)
Steel closure bolting Loss of material  Bolting Integrity  No        Not used          Not used (See SER exposed to air with  due to general                                                    Section 3.3.2.1.1) steam or water        corrosion leakage (3.3.1-42)
Steel bolting and    Loss of material Bolting Integrity  No        Bolting Integrity Consistent with closure bolting      due to general,                                Program (B.2.8) GALL Report (See exposed to air -      pitting, and                                                      SER indoor uncontrolled  crevice corrosion                                                Section 3.3.2.1)
(external) or air -
outdoor (external)
(3.3.1-43)
Steel compressed      Loss of material Bolting Integrity  No        Not used          Not used (See SER air system closure    due to general,                                                  Section 3.3.2.1.1) bolting exposed to    pitting, and condensation          crevice corrosion (3.3.1-44)
Steel closure bolting Loss of preload  Bolting Integrity  No        Bolting Integrity Consistent with exposed to air -      due to thermal                                  Program (B.2.8) GALL Report (See indoor uncontrolled  effects, gasket                                                  SER (external)            creep, and                                                        Section 3.3.2.1)
(3.3.1-45)            self-loosening Stainless steel and  Cracking due to  Closed-Cycle      No        Closed-Cycle      Consistent with stainless clad steel  stress corrosion  Cooling Water                Cooling Water    GALL Report (See piping, piping        cracking          System                        System            SER components, piping                                                    Program          Section 3.3.2.1) elements, and heat                                                    (B.2.11) exchanger components exposed to closed cycle cooling water > 60EC
(> 140EF)
(3.3.1-46)
Steel piping, piping  Loss of material Closed-Cycle        No        Closed-Cycle      Consistent with components, piping    due to general,  Cooling Water                Cooling Water    GALL Report (See elements, tanks,      pitting, and      System                        System            SER and heat exchanger    crevice corrosion                              Program          Section 3.3.2.1) components                                                            (B.2.11) exposed to closed cycle cooling water (3.3.1-47) 3-285
 
Component Group        Aging Effect/    AMP in GALL      Further    AMP in LRA,  Staff Evaluation (GALL Report          Mechanism            Report    Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Steel piping, piping  Loss of material  Closed-Cycle    No        Closed-Cycle  Consistent with components, piping    due to general,  Cooling Water              Cooling Water  GALL Report (See elements, tanks,      pitting, crevice, System                      System        SER and heat exchanger    and galvanic                                  Program        Section 3.3.2.1.12) components            corrosion                                    (B.2.11);
exposed to closed                                                    Inspection of cycle cooling water                                                  Internal (3.3.1-48)                                                          Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24)
Stainless steel; steel Loss of material  Closed-Cycle    No        Not applicable Not applicable to with stainless steel  due to            Cooling Water                              PWRs cladding heat          microbiologically System exchanger              influenced components            corrosion exposed to closed cycle cooling water (3.3.1-49)
Stainless steel        Loss of material  Closed-Cycle    No        Closed-Cycle  Consistent with piping, piping        due to pitting    Cooling Water              Cooling Water  GALL Report (See components, and        and crevice      System                      System        SER piping elements        corrosion                                    Program        Section 3.3.2.1.13) exposed to closed                                                    (B.2.11);
cycle cooling water                                                  Inspection of (3.3.1-50)                                                          Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24)
Copper alloy piping,  Loss of material  Closed-Cycle    No        Closed-Cycle  Consistent with piping components,    due to pitting,  Cooling Water              Cooling Water  GALL Report (See piping elements,      crevice, and      System                      System        SER and heat exchanger    galvanic                                      Program        Section 3.3.2.1) components            corrosion                                    (B.2.11) exposed to closed cycle cooling water (3.3.1-51) 3-286
 
Component Group      Aging Effect/    AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report      Mechanism            Report      Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Steel, stainless    Reduction of      Closed-Cycle      No        Closed-Cycle  Consistent with steel, and copper  heat transfer due Cooling Water                Cooling Water  GALL Report (See alloy heat          to fouling        System                      System        SER exchanger tubes                                                    Program        Section 3.3.2.1) exposed to closed                                                  (B.2.11) cycle cooling water (3.3.1-52)
Steel compressed    Loss of material  Compressed Air    No        Not applicable Not applicable (See air system piping,  due to general    Monitoring                                  SER piping components,  and pitting                                                  Section 3.3.2.1.1) and piping elements corrosion exposed to condensation (internal)
(3.3.1-53)
Stainless steel    Loss of material  Compressed Air    No        Not used      Not used (See SER compressed air      due to pitting    Monitoring                                  Section 3.3.2.1.1) system piping,      and crevice piping components,  corrosion and piping elements exposed to internal condensation (3.3.1-54)
Steel ducting      Loss of material  External Surfaces No        Not used      Not used (See SER closure bolting    due to general    Monitoring                                  Section 3.3.2.1.1) exposed to air -    corrosion indoor uncontrolled (external)
(3.3.1-55)
Steel HVAC ducting  Loss of material  External Surfaces No        Not used      Not used (See SER and components      due to general    Monitoring                                  Section 3.3.2.1.1) external surfaces  corrosion exposed to air -
indoor uncontrolled (external)
(3.3.1-56)
Steel piping and    Loss of material  External Surfaces No        Not used      Not used (See SER components          due to general    Monitoring                                  Section 3.3.2.1.1) external surfaces  corrosion exposed to air -
indoor uncontrolled (External)
(3.3.1-57) 3-287
 
Component Group      Aging Effect/      AMP in GALL      Further  AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Steel external      Loss of material  External Surfaces  No        Not used        Not used (See SER surfaces exposed to  due to general    Monitoring                                    Section 3.3.2.1.1) air - indoor        corrosion uncontrolled (external), air -
outdoor (external),
and condensation (external)
(3.3.1-58)
Steel heat          Loss of material External Surfaces  No        External        Consistent with exchanger            due to general,  Monitoring                    Surfaces        GALL Report (See components          pitting, and                                    Monitoring      SER exposed to air -    crevice corrosion                              Program        Section 3.3.2.1) indoor uncontrolled                                                  (B.2.22)
(external) or air-outdoor (external)
(3.3.1-59)
Steel piping, piping Loss of material External Surfaces  No        External        Consistent with components, and      due to general,  Monitoring                    Surfaces        GALL Report (See piping elements      pitting, and                                    Monitoring      SER exposed to air -    crevice corrosion                              Program        Section 3.3.2.1) outdoor (external)                                                  (B.2.22)
(3.3.1-60)
Elastomer fire      Increased        Fire Protection    No        Fire Protection Consistent with barrier penetration  hardness,                                      Program        GALL Report (See seals exposed to    shrinkage and                                  (B2.14)        SER air - outdoor or    loss of strength                                                Section 3.3.2.1.14) air - indoor        due to uncontrolled        weathering (3.3.1-61)
Aluminum piping,    Loss of material  Fire Protection    No        Fire Water      Consistent with piping components,  due to pitting                                  System          GALL Report (See and piping elements  and crevice                                    Program        SER exposed to raw      corrosion                                      (B2.15)        Section 3.3.2.1.15) water (3.3.1-62)
Steel fire rated    Loss of material  Fire Protection    No        Fire Protection Consistent with doors exposed to air due to wear                                    Program        GALL Report (See
- outdoor or                                                        (B2.14);        SER air - indoor                                                        Structures      Section 3.3.2.1.16) uncontrolled                                                        Monitoring (3.3.1-63)                                                          Program (B.2.31) 3-288
 
Component Group      Aging Effect/      AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Steel piping, piping Loss of material Fire Protection and  No        Fire Protection Consistent with components, and      due to general,  Fuel Oil Chemistry            Program        GALL Report (See piping elements      pitting, and                                    (B.2.14);      SER exposed to fuel oil  crevice corrosion                                Fuel Oil      Section 3.3.2.1)
(3.3.1-64)                                                            Chemistry Program (B.2.16)
Reinforced concrete  Concrete          Fire Protection and No        Fire Protection Consistent with structural fire      cracking and      Structures                    Program        GALL Report (See barriers - walls,    spalling due to  Monitoring                    (B2.14);        SER ceilings and floors  aggressive        Program                        Structures      Section 3.3.2.1.17) exposed to air -    chemical attack,                                Monitoring indoor uncontrolled  and reaction with                                Program (3.3.1-65)          aggregates                                      (B.2.31);
ASME Section XI, Subsection IWL Program (B.2.27)
Reinforced concrete  Concrete          Fire Protection and No        Fire Protection Consistent with structural fire      cracking and      Structures                    Program        GALL Report (See barriers - walls,    spalling due to  Monitoring                    (B2.14);        SER ceilings and floors  freeze thaw,      Program                        Structures      Section 3.3.2.1.18) exposed to air -    aggressive                                      Monitoring outdoor              chemical attack,                                Program (3.3.1-66)          and reaction with                                (B.2.31);
aggregates                                      ASME Section XI, Subsection IWL Program (B.2.27)
Reinforced concrete  Loss of material  Fire Protection and No        Fire Protection Consistent with structural fire      due to corrosion  Structures                    Program        GALL Report (See barriers - walls,    of embedded      Monitoring                    (B2.14);        SER ceilings and floors  steel            Program                        Structures      Section 3.3.2.1.19) exposed to air -                                                      Monitoring outdoor or air -                                                      Program indoor uncontrolled                                                  (B.2.31);
(3.3.1-67)                                                            ASME Section XI, Subsection IWL Program (B.2.27) 3-289
 
Component Group      Aging Effect/      AMP in GALL      Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report      Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Steel piping, piping Loss of material  Fire Water System No        Fire Water    Consistent with components, and      due to general,                                System        GALL Report (See piping elements      pitting, crevice,                              Program      SER exposed to raw      and                                            (B2.15);      Section 3.3.2.1.20) water                microbiologically                              Inspection of (3.3.1-68)          influenced                                    Internal corrosion, and                                Surfaces in fouling                                        Miscellaneous Piping and Ducting Components Program (B.2.24)
Stainless steel      Loss of material  Fire Water System No        Fire Water    Consistent with piping, piping      due to pitting                                System        GALL Report (See components, and      and crevice                                    Program      SER piping elements      corrosion, and                                (B2.15);      Section 3.3.2.1.21) exposed to raw      fouling                                        Inspection of water                                                              Internal (3.3.1-69)                                                          Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24)
Copper alloy piping, Loss of material  Fire Water System No        Fire Water    Consistent with piping components,  due to pitting,                                System        GALL Report (See and piping elements  crevice, and                                  Program      SER exposed to raw      microbiologically                              (B2.15);      Section 3.3.2.1.22) water                influenced                                    Inspection of (3.3.1-70)          corrosion, and                                Internal fouling                                        Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24) 3-290
 
Component Group        Aging Effect/    AMP in GALL        Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                              in GALL          or Report    Amendments Steel piping, piping  Loss of material  Inspection of        No        Fuel Oil      Consistent with components, and      due to general,  Internal Surfaces in            Chemistry      GALL Report (See piping elements      pitting, and      Miscellaneous                  Program        SER exposed to moist air  crevice corrosion Piping and Ducting              (B.2.16);      Section 3.3.2.1.23) or condensation                        Components                      One-Time (internal)                                                              Inspection (3.3.1-71)                                                              Program (B.2.18);
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24)
Steel HVAC ducting    Loss of material  Inspection of        No        Fuel Oil      Consistent with and components        due to general,  Internal Surfaces in            Chemistry      GALL Report (See internal surfaces    pitting, crevice, Miscellaneous                  Program        SER exposed to            and (for drip    Piping and Ducting              (B.2.16);      Section 3.3.2.1.24) condensation          pans and drain    Components                      One-Time (internal)            lines)                                            Inspection (3.3.1-72)            microbiologically                                Program influenced                                        (B.2.18);
corrosion                                        Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24)
Steel crane          Loss of material  Inspection of        No        Inspection of  Consistent with structural girders in due to general    Overhead Heavy                  Overhead      GALL Report (See load handling        corrosion        Load and Light                  Heavy Load    SER system exposed to                      Load (Related to                and Light Load Section 3.3.2.1) air - indoor                            Refueling)                      Handling uncontrolled                            Handling Systems                Systems (external)                                                              Program (3.3.1-73)                                                              (B.2.13)
Steel cranes - rails  Loss of material  Inspection of        No        Inspection of  Consistent with exposed to air -      due to Wear      Overhead Heavy                  Overhead      GALL Report (See indoor uncontrolled                    Load and Light                  Heavy Load    SER (external)                              Load (Related to                and Light Load Section 3.3.2.1)
(3.3.1-74)                              Refueling)                      Handling Handling Systems                Systems Program (B.2.13) 3-291
 
Component Group        Aging Effect/    AMP in GALL      Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report    Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Elastomer seals and  Hardening and    Open-Cycle      No        Not applicable Not applicable (See components          loss of strength  Cooling Water                              SER exposed to raw      due to elastomer System                                      Section 3.3.2.1.1) water                degradation; loss (3.3.1-75)          of material due to erosion Steel piping, piping Loss of material  Open-Cycle      No        Open-Cycle    Consistent with components, and      due to general,  Cooling Water              Cooling Water  GALL Report (See piping elements      pitting, crevice, System                      System        SER (without lining/    and                                          Program        Section 3.3.2.1.25) coating or with      microbiologically                            (B.2.10);
degraded            influenced                                    One-Time lining/coating)      corrosion,                                    Inspection exposed to raw      fouling, and                                  Program water                lining/coating                                (B.2.18);
(3.3.1-76)          degradation                                  Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.24);
External Surfaces Monitoring Program (B.2.22)
Steel heat          Loss of material  Open-Cycle      No        Open-Cycle    Consistent with exchanger            due to general,  Cooling Water              Cooling Water  GALL Report (See components          pitting, crevice, System                      System        SER exposed to raw      galvanic, and                                Program        Section 3.3.2.1.26) water                microbiologically                            (B.2.10);
(3.3.1-77)          influenced                                    Inspection of corrosion, and                                Internal fouling                                      Surfaces in Miscellaneous Piping and Ducting Components (B.2.24)
Stainless steel,    Loss of material  Open-Cycle      No        Not used      Not used (See SER nickel alloy, and    due to pitting    Cooling Water                              Section 3.3.2.1.1) copper alloy piping, and crevice      System piping components,  corrosion and piping elements exposed to raw water (3.3.1-78) 3-292
 
Component Group      Aging Effect/    AMP in GALL      Further    AMP in LRA,  Staff Evaluation (GALL Report        Mechanism            Report    Evaluation  Supplements, Item No.)                                          in GALL          or Report    Amendments Stainless steel      Loss of material  Open-Cycle      No        Open-Cycle    Consistent with piping, piping      due to pitting    Cooling Water              Cooling Water GALL Report (See components, and      and crevice      System                      System        SER piping elements      corrosion, and                                Program      Section 3.3.2.1.27) exposed to raw      fouling                                      (B.2.10);
water                                                              Inspection of (3.3.1-79)                                                        Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.24)
Stainless steel and  Loss of material  Open-Cycle      No        Open-Cycle    Consistent with copper alloy piping, due to pitting,  Cooling Water              Cooling Water GALL Report (See piping components,  crevice, and      System                      System        SER and piping elements  microbiologically                            Program      Section 3.3.2.1.28) exposed to raw      influenced                                    (B.2.10);
water                corrosion                                    Inspection of (3.3.1-80)                                                        Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.24)
Copper alloy piping, Loss of material  Open-Cycle      No        Open-Cycle    Consistent with piping components,  due to pitting,  Cooling Water              Cooling Water GALL Report (See and piping          crevice, and      System                      System        SER elements, exposed    microbiologically                            Program      Section 3.3.2.1.29) to raw water        influenced                                    (B.2.10);
(3.3.1-81)          corrosion, and                                Inspection of fouling                                      Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.24) 3-293
 
Component Group        Aging Effect/      AMP in GALL      Further    AMP in LRA,  Staff Evaluation (GALL Report          Mechanism            Report      Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Copper alloy heat    Loss of material  Open-Cycle        No        Open-Cycle    Consistent with exchanger            due to pitting,  Cooling Water                Cooling Water  GALL Report (See components            crevice,          System                        System        SER exposed to raw        galvanic, and                                  Program        Section 3.3.2.1.30) water                microbiologically                              (B.2.10);
(3.3.1-82)            influenced                                      Inspection of corrosion, and                                  Internal fouling                                        Surfaces in Miscellaneous Piping and Ducting Components (B.2.24)
Stainless steel and  Reduction of      Open-Cycle        No        Open-Cycle    Consistent with copper alloy heat    heat transfer due Cooling Water                Cooling Water  GALL Report (See exchanger tubes      to fouling        System                        System        SER exposed to raw                                                        Program        Section 3.3.2.1) water                                                                (B.2.10)
(3.3.1-83)
Copper alloy          Loss of material  Selective Leaching No        Selective      Consistent with
> 15% Zn piping,      due to selective  of Materials                  Leaching of    GALL Report (See piping components, leaching                                          Materials      SER piping elements,                                                      Program        Section 3.3.2.1) and heat exchanger                                                    (B.2.19) components exposed to raw water, treated water, or closed cycle cooling water (3.3.1-84)
Gray cast iron        Loss of material  Selective Leaching No        Selective      Consistent with piping, piping        due to selective  of Materials                  Leaching of    GALL Report (See components, and      leaching                                        Materials      SER piping elements                                                      Program        Section 3.3.2.1) exposed to soil, raw                                                  (B.2.19) water, treated water, or closed-cycle cooling water (3.3.1-85)
Structural steel (new Loss of material Structures          No        Not applicable Not applicable (See fuel storage rack    due to general,  Monitoring                                  SER assembly) exposed    pitting, and      Program                                      Section 3.3.2.1.1) to air - indoor      crevice corrosion uncontrolled (external)
(3.3.1-86) 3-294
 
Component Group      Aging Effect/    AMP in GALL        Further    AMP in LRA,    Staff Evaluation (GALL Report        Mechanism            Report        Evaluation  Supplements, Item No.)                                            in GALL          or Report    Amendments Boraflex spent fuel  Reduction of      Boraflex Monitoring No        Boraflex        Consistent with storage racks        neutron-absorbin                                Monitoring      GALL Report (See neutron-absorbing    g capacity due to                                Program        SER sheets exposed to    boraflex                                        (B.2.12)        Section 3.3.2.1) treated borated      degradation water (3.3.1-87)
Aluminum and        Loss of material  Boric Acid          No        Boric Acid      Consistent with copper alloy        due to boric acid Corrosion                      Corrosion      GALL Report (See
> 15% Zn piping,    corrosion                                        Program (B.2.4) SER piping components,                                                                    Section 3.3.2.1) and piping elements exposed to air with borated water leakage (3.3.1-88)
Steel bolting and    Loss of material  Boric Acid          No        Boric Acid      Consistent with external surfaces    due to boric acid Corrosion                      Corrosion      GALL Report (See exposed to air with  corrosion                                        Program (B.2.4) SER borated water                                                                        Section 3.3.2.1.31) leakage (3.3.1-89)
Stainless steel and  Cracking due to  Water Chemistry    No        Water          Consistent with steel with stainless stress corrosion                                Chemistry      GALL Report (See steel cladding      cracking                                        Program        SER piping, piping                                                        (B.2.2);        Section 3.3.2.1.32) components, piping                                                    Inspection of elements, tanks,                                                      Internal and fuel storage                                                      Surfaces in racks exposed to                                                      Miscellaneous treated borated                                                      Piping and water > 60EC                                                          Ducting
(> 140EF)                                                            Components (3.3.1-90)                                                            (B.2.24)
Stainless steel and  Loss of material  Water Chemistry    No        Water          Consistent with steel with stainless due to pitting                                  Chemistry      GALL Report (See steel cladding      and crevice                                      Program        SER piping, piping      corrosion                                        (B.2.2);        Section 3.3.2.1.33) components, and                                                      Inspection of piping elements                                                      Internal exposed to treated                                                    Surfaces in borated water                                                        Miscellaneous (3.3.1-91)                                                            Piping and Ducting Components (B.2.24) 3-295
 
Component Group      Aging Effect/  AMP in GALL    Further  AMP in LRA,  Staff Evaluation (GALL Report        Mechanism        Report    Evaluation Supplements, Item No.)                                      in GALL        or Report    Amendments Galvanized steel      None          None            No        None        Consistent with piping, piping                                                              GALL Report (See components, and                                                              SER piping elements                                                              Section 3.3.2.1) exposed to air -
indoor uncontrolled (3.3.1-92)
Glass piping          None          None            No        None        Consistent with elements exposed                                                            GALL Report (See to air, air - indoor                                                        SER uncontrolled                                                                Section 3.3.2.1)
(external), fuel oil, lubricating oil, raw water, treated water, and treated borated water (3.3.1-93)
Stainless steel and  None          None            No        None        Consistent with nickel alloy piping,                                                        GALL Report (See piping components,                                                          SER and piping elements                                                          Section 3.3.2.1) exposed to air -
indoor uncontrolled (external)
(3.3.1-94)
Steel and aluminum    None          None            No        None        Consistent with piping, piping                                                              GALL Report (See components, and                                                              SER piping elements                                                              Section 3.3.2.1) exposed to air -
indoor controlled (external)
(3.3.1-95)
Steel and stainless  None          None            No        None        Consistent with steel piping, piping                                                        GALL Report (See components, and                                                              SER piping elements in                                                          Section 3.3.2.1) concrete (3.3.1-96)
Steel, stainless      None          None            No        None        Consistent with steel, aluminum,                                                            GALL Report (See and copper alloy                                                            SER piping, piping                                                              Section 3.3.2.1) components, and piping elements exposed to gas (3.3.1-97) 3-296
 
Component Group      Aging Effect/  AMP in GALL    Further  AMP in LRA,  Staff Evaluation (GALL Report        Mechanism        Report    Evaluation Supplements, Item No.)                                      in GALL        or Report    Amendments Steel, stainless    None            None            No        None          Consistent with steel, and copper                                                            GALL Report (See alloy piping, piping                                                          SER components, and                                                              Section 3.3.2.1) piping elements exposed to dried air (3.3.1-98)
Stainless steel and  None            None            No        None          Consistent with copper alloy                                                                  GALL Report (See
< 15% Zn piping,                                                              SER piping components,                                                            Section 3.3.2.1) and piping elements exposed to air with borated water leakage (3.3.1-99)
The staffs review of the auxiliary systems component groups followed any one of several approaches. One approach, documented in SER Section 3.3.2.1, reviewed AMR results for components that the applicant indicated are consistent with the GALL Report and require no further evaluation. Another approach, documented in SER Section 3.3.2.2, reviewed AMR results for components that the applicant indicated are consistent with the GALL Report and for which further evaluation is recommended. A third approach, documented in SER Section 3.3.2.3, reviewed AMR results for components that the applicant indicated are not consistent with, or not addressed in, the GALL Report. The staffs review of AMPs credited to manage or monitor aging effects of the auxiliary systems components is documented in SER Section 3.0.3.
3.3.2.1 AMR Results Consistent with the GALL Report LRA Section 3.3.2.1 identifies the materials, environments, AERMs, and the following programs that manage aging effects for the auxiliary systems components:
* Water Chemistry Program
* Boric Acid Corrosion Program
* Flow-Accelerated Corrosion Program
* Bolting Integrity Program
* Open-Cycle Cooling Water System Program
* Closed-Cycle Cooling Water System Program
* Fire Protection Program
* Fire Water System Program
* Fuel Oil Chemistry Program
* One-Time Inspection Program 3-297
* Selective Leaching of Materials Program
* Buried Piping and Tanks Inspection Program
* External Surfaces Monitoring Program
* Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program
* Lubricating Oil Analysis Program LRA Tables 3.3.2-1 through 3.3.2-71 summarize AMRs for the auxiliary systems components and indicate AMRs claimed to be consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant claimed consistency with the report and for which it does not recommend further evaluation, the staffs audit and review determined whether the plant-specific components of these GALL Report component groups were bounded by the GALL Report evaluation.
The applicant noted for each AMR line item how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with Notes A through E indicating how the AMR is consistent with the GALL Report.
Note A indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report and validity of the AMR for the site-specific conditions.
Note B indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report and verified that the identified exceptions to the GALL Report AMPs have been reviewed and accepted. The staff also determined whether the applicants AMP was consistent with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
Note C indicates that the component for the AMR line item, although different from, is consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. This note indicates that the applicant was unable to find a listing of some system components in the GALL Report; however, the applicant identified in the GALL Report a different component with the same material, environment, aging effect, and AMP as the component under review. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the AMR line item of the different component was applicable to the component under review and whether the AMR was valid for the site-specific conditions.
Note D indicates that the component for the AMR line item, although different from, is consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP takes some exceptions to the GALL Report AMP. The staff audited these line items to verify consistency with the GALL Report. The staff verified whether the AMR line item of the different component was applicable to the component under review and whether the identified 3-298
 
exceptions to the GALL Report AMPs have been reviewed and accepted. The staff also determined whether the applicants AMP was consistent with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
Note E indicates that the AMR line item is consistent with the GALL Report for material, environment, and aging effect, but credits a different AMP. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the credited AMP would manage the aging effect consistently with the GALL Report AMP and whether the AMR was valid for the site-specific conditions.
The staff audited and reviewed the information in the LRA. The staff did not repeat its review of the matters described in the GALL Report; however, the staff did verify that the material presented in the LRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The staffs evaluation follows.
3.3.2.1.1 AMR Results Identified as Not Applicable LRA Table 3.3.1 shows items 39, 41, 53, and 75 as Not Applicable as the component, material, and environment combination is not present. For each of these line items, the staff reviewed the LRA and the applicants supporting license renewal basis calculations and confirmed the applicants claim that the component, material, and environment combination is not present at HNP. On the basis that HNP has no component, material, and environment combination for these Table 1 line items, the staff finds that these AMRs do not apply.
LRA Table 3.3.1 shows items 42, 44, 54, 55, 56, 57, 58, and 78 as not used as the component, material, and environment combination is addressed by another Table 1 line item.
For each of these line items, the staff reviewed the LRA and license renewal basis calculations and confirmed that the line item is not used in the LRA. In addition, the staff confirmed that the aging effects addressed by these line items are addressed by other appropriate Table 1 AMR line items. On this basis, the staff finds the applicants treatment of these Table 1 AMR line items as not used acceptable.
3.3.2.1.2 Cracking Due to Stress Corrosion Cracking LRA Table 3.3.1, item 3.3.1-06, states that SCC of the stainless steel expansion joint exposed to diesel exhaust is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. During the audit and review, the staff noted that the AMR result item referring to LRA Table 3.3.1, item 3.3.1-06, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends a plant-specific AMP, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. The staffs evaluation of that program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program periodically inspects internal surfaces of piping, piping elements, ducting, and components visually for 3-299
 
timely detection of component degradation. On the basis of periodic visual inspections, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
On the bases of its review of the AMR result item and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.3 Cracking Due to Stress Corrosion Cracking and Cyclic Loading LRA Table 3.3.1, item 3.3.1-07, states that cracking of CVCS heat exchanger components exposed to treated water is managed by a combination of the Water Chemistry and the One-Time Inspection Programs. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-07, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report, which recommends a combination of GALL AMP XI.M2, Water Chemistry, and a plant-specific verification program. The applicant proposed the Water Chemistry Program, which is consistent with GALL AMP XI.M2, with One-Time Inspection Program for verification. The staffs evaluations of the Water Chemistry and One-Time Inspection Programs are documented in SER Sections 3.0.3.1.1 and 3.0.3.1.5, respectively.
The One-Time Inspection Program verifies the effectiveness of the Water Chemistry Program.
The staff confirmed CVCS inclusion within the scope of the One-Time Inspection Program for verification of the effectiveness of the Water Chemistry Program to manage cracking. On the basis of one-time visual inspections in the CVCS, the staff finds the applicants One-Time Inspection Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.4 Cracking Due to Stress Corrosion Cracking and Cyclic Loading LRA Table 3.3.1, item 3.3.1-08, states that cracking of stainless steel regenerative heat exchanger components in the CVCS and the boron thermal regeneration system exposed to treated water is managed by a combination of the Water Chemistry and the One-Time Inspection Programs. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-08, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report, which recommends a combination of GALL AMP XI.M2, Water Chemistry, and a plant-specific verification program. The applicant proposed the Water Chemistry Program, which is consistent with GALL AMP XI.M2, with the One-Time Inspection Program for verification. The staffs evaluations of the Water Chemistry and One-Time 3-300
 
Inspection Programs are documented in SER Sections 3.0.3.1.1 and 3.0.3.1.5, respectively.
The One-Time Inspection Program verifies the effectiveness of the Water Chemistry Program.
The staff confirmed that the CVCS and the boron thermal regeneration system are within the scope of the One-Time Inspection Program for verification of the effectiveness of the Water Chemistry Program to manage cracking. On the basis of one-time visual inspections of these systems, the staff finds the applicants One-Time Inspection Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.5 Cracking Due to Stress Corrosion Cracking and Cyclic Loading LRA Table 3.3.1, item 3.3.1-09, states that cracking of stainless steel CSIP casings in the CVCS exposed to treated water is managed by a combination of the Water Chemistry and the One-Time Inspection Programs. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-09, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report, which recommends a combination of GALL AMP XI.M2, Water Chemistry, and a plant-specific verification program. The applicant proposed the Water Chemistry Program, which is consistent with GALL AMP XI.M2, with the One-Time Inspection Program for verification. The staffs evaluations of the Water Chemistry and One-Time Inspection Programs are documented in SER Sections 3.0.3.1.1 and 3.0.3.1.5, respectively.
The One-Time Inspection Program verifies the effectiveness of the Water Chemistry Program.
The staff confirmed CVCS inclusion within the scope of the One-Time Inspection Program for verification of the effectiveness of the Water Chemistry Program to manage cracking. On the basis of one-time visual inspections of the CVCS, the staff finds the applicants One-Time Inspection Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.6 Hardening and Loss of Strength Due to Elastomer Degradation LRA Table 3.3.1, item 3.3.1-11, states that hardening and loss of strength of elastomer seals and components in the auxiliary systems exposed to air-indoor is managed by either the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program or the External Surfaces Monitoring Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-11, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report. The GALL Report recommends a plant-specific program. The applicant 3-301
 
proposed either the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program or the External Surfaces Monitoring Program to manage the aging effects. The External Surfaces Monitoring Program is component types exposed to external air-indoor environments whereas the component types exposed to internal air-indoor environments are managed by the Internal Surfaces in Miscellaneous Piping and Ducting Program.
The staffs evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of the periodic visual inspections of external surfaces, the staff finds the applicants External Surfaces Monitoring Program acceptable.
The staffs evaluation of Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. The program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of the periodic inspections of components internal surfaces, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.7 Loss of Material/General (Steel Only), Pitting and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-18, states that loss of material of the stainless steel and steel diesel exhaust piping, piping components, and piping elements and diesel exhaust silencers exposed to diesel exhaust is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-18, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends a plant-specific AMP, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. The program periodically visually inspects the internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of periodic visual inspections, the staff finds the applicant's Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed 3-302
 
the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.8 Loss of Material Due to Pitting and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-27, states that loss of material on containment purge system bird screens exposed to air-outdoor is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that two AMR result items referring to LRA Table 3.3.1, item 3.3.1-37 refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends evaluation of any plant-specific AMP, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The applicant stated that Note E was because the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is not plant-specific.
During the onsite audit, the staff confirmed that the bird screens were actually inside the containment purge system ducting; therefore, the bird screen external environment was similar to that described in the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The staff finds that this program would detect this aging effect or mechanism during periodic visual inspections of internal surfaces of component types within its scope. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. On this basis, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable for aging management of these HVAC components.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.9 Loss of Material Due to Pitting, Crevice, and Microbiologically Influenced Corrosion LRA Table 3.3.1, item 3.3.1-32, states that loss of material of stainless steel, aluminum, and copper alloy piping, piping components, and piping elements exposed to fuel oil (except for the diesel driven fire pump fuel oil supply line) is managed by the Fuel Oil Chemistry and One-Time Inspection Programs. During the audit and review, the staff noted that one AMR result item referring to LRA Table 3.3.1, item 3.3.1-32, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends the Fuel Oil Chemistry and One-Time Inspection Programs, the applicant proposed the Fire Protection and Fuel Oil Chemistry Programs; therefore, the applicant applied Note E for the diesel-driven fire pump fuel oil supply line. The staffs evaluations of the Fire Protection and Fuel Oil Chemistry Programs are documented in SER Sections 3.0.3.1.4 and 3.0.3.1.7, respectively. The Fuel Oil Chemistry Program is consistent with the GALL Report recommendation. The Fire Protection Program manages aging of the diesel-driven fire pump fuel oil supply line and credited fire barrier 3-303
 
assemblies including fire doors, penetration seals, fire wrap, barrier walls, barrier ceilings and floors, and seismic joint filler through periodic inspections. The effective Fire Protection Program will adequately manage cracking and loss of material. On this basis, the staff finds Fire Protection Program an adequate alternative to the One-Time Inspection Program for adequate management of aging effects for copper tubing exposed to fuel oil.
On the bases of its review of the AMR result item and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.10 Loss of Material Due to Wear LRA Table 3.3.1, item 3.3.1-34, states that loss of material due to wear of elastomer seals and components exposed to external air-indoor environments is managed by the External Surfaces Monitoring Program or by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program if component types are exposed to internal air/gas (wetted) environments. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-40, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends a plant-specific program, the applicant proposed either the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program or the External Surfaces Monitoring Program to manage the aging effects. The External Surfaces Monitoring Program is for component types exposed to external air-indoor environments whereas component types exposed to internal air-indoor environments are managed by the Internal Surfaces in Miscellaneous Piping and Ducting Program.
The staffs evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of the periodic visual inspections of the external surfaces, the staff finds the applicants External Surfaces Monitoring Program acceptable.
The staffs evaluation of Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of the periodic inspections of component internal surfaces, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant addressed 3-304
 
the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.11 Loss of Material Due to General, Pitting, and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-40, states that loss of material of steel tank component (diesel-driven fire pump fuel oil storage tank flame arresters) external surfaces exposed to outdoor air environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that one AMR result item referring to LRA Table 3.3.1, item 3.3.1-40, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M29, Above Ground Steel Tanks Program, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages the external surfaces of this component.
In its response dated August 20, 2007, the applicant explained that external surfaces of the component flame arresters are adequately managed by the Inspection of Internal Surfaces in Miscellaneous and Ducting Components Program. Additionally, the applicant stated that maintenance on relatively small components like a flame arrester can observe the condition of external as well as internal surfaces adequately. The staff recognizes that, although the flame arresters are installed internally in the tank vents, the environment is outdoor air.
On the basis that flame arresters are subject to periodic maintenance and have been evaluated as exposed to outdoor air, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous and Ducting Components Program acceptable because the Above Ground Steel Tanks Program does not address these components but the Inspection of Internal Surfaces in Miscellaneous and Ducting Components Program addresses them.
On the bases of its review of the AMR result item and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant appropriately addressed the aging effect or mechanism as recommended by the GALL Report.
3.3.2.1.12 Loss of Material Due to Crevice, General, and Pitting Corrosion LRA Table 3.3.1, item 3.3.1-48, states that loss of material of carbon or low-alloy steel and gray cast-iron components exposed to treated water either internally or externally is managed by the Inspection of Internal Surfaces in Miscellaneous and Ducting Components Program. During the audit and review, the staff noted that four AMR result items referring to LRA Table 3.3.1, item 3.3.1-48, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Closed-Cycle 3-305
 
Cooling Water System, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the onsite audit, the staff confirmed that the components included within the radioactive equipment drains system are exposed various environments conservatively described as treated water. The treated water affecting these system components can be reactor-grade water from equipment leaks, drains, and tank overflows in various buildings. The treated water external environment affects components like floor drains that can be exposed to equipment drainage. The staff also confirmed that the external surfaces of component types managed by this Table 3.3.1 item are located within sumps and include pump casings, strainers, and discharge piping not accessible by external walkdowns. So management of external surfaces will be at the same time as for internal surfaces by periodic visual inspections under the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
On the basis that carbon or low-alloy steel and gray cast-iron components in the radioactive equipment drains system exposed to treated water would be subject to periodic inspection and evaluation, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous and Ducting Components Program acceptable because aging effects for these components would be detected and prompt corrective action taken where required.
On the bases of its review of AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant appropriately addressed the aging effect or mechanism as recommended by the GALL Report.
3.3.2.1.13 Loss of Material Due to Pitting and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-50, states that loss of material of stainless steel system strainer screens/elements exposed to environments of treated water is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that one AMR result item referring to Table 3.3.1, item 3.3.1-50, refer to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M21, Closed-Cycle Cooling Water System, the applicant proposed Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The LRA states that Note E is to manage the aging effects of the system strainer screens/elements because these components are internal to the pump suction piping and the external environment of the screens is treated water. Further, the applicant explained that the Closed-Cycle Cooling Water System Program does not include stainless steel strainer screen/elements of this type and that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is more suitable for managing loss of material due to crevice and pitting corrosion.
On the basis that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program would detect and manage stainless steel system strainer screens/elements externally exposed to treated water and because these components are not within the Closed-Cycle Cooling Water System Program, the staff finds the Internal Surfaces 3-306
 
Inspection of Miscellaneous Piping and Ducting Components Program acceptable.
On the bases of its review of the AMR result item and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant appropriately addressed the aging effect or mechanism as recommended by the GALL Report.
3.3.2.1.14 Increased Hardness, Shrinkage and Loss of Strength Due to Weathering LRA Table 3.5.2-28 for elastomer seismic joint filler component types exposed to air-indoor environments refers to LRA Table 3.3.1, item 3.3.1-61, and GALL Report, items VII.G-1 and VII.G-2; however, only GALL Report, item VII.G-1, and not VII.G-2, is for air-indoor environments.
During the audit and review, the staff asked the applicant to explain why it referred to GALL Report item VII.G-2 for the environment for this result item.
In its response dated August 20, 2007, the applicant stated that it would amend the LRA to remove GALL Report item VII.G-2 from LRA Table 3.5.2-28 for elastomer seismic joint filler component types exposed to air-indoor environments. In the same August 20, 2007 letter, the applicant proposed the amendment to the AMR line item to remove GALL Report item VII.G-2.
With this change, the staff finds the response consistent with the GALL Report and acceptable.
3.3.2.1.15 Loss of Material Due to Pitting and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-62, states that loss of material of aluminum or aluminum alloy heat exchanger components and aluminum or aluminum alloy piping, piping components, and piping elements exposed to internal environments of raw water is managed by the Fire Water System Program. During the audit and review, the staff noted that two AMR result items referring to LRA Table 3.3.1, item 3.3.1-62, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the material, environment, and aging effects are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M26, Fire Protection, the applicant proposed the Fire Water System Program. The applicant explained the use of Note E for aluminum or aluminum alloy heat exchanger components and piping, piping components, and piping elements. For the aluminum or aluminum alloy heat exchanger components, the applicant stated that these are for the diesel-driven fire pump and that although the GALL Report recommends the Fire Protection Program, the Fire Water System Program is more effective because routine testing and inspection specified in the Fire Water System Program would adequately detect and manage aging effects for this component. For the aluminum or aluminum alloy piping, piping components, and piping elements, the applicant described them as for operation of the automatic sprinkler valves. Additionally, the applicant explained that the GALL Report recommends the Fire Protection Program but does not describe these components but the Fire Water System Program describes how loss of material for aluminum or aluminum alloy piping, piping components, and piping elements exposed to internal environments of raw water will be managed.
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The staffs evaluation of the Fire Water System Program is documented in SER Section 3.0.3.2.11.
On the basis of its review of the Fire Water System Program, the staff finds that the applicant adequately explained the reasons for Note E to the two AMR result items and that for aluminum or aluminum alloy heat exchanger components and piping, piping components, and piping elements the Fire Water System Program would adequately detect and manage the aging effects of these components in raw water; therefore, the staff finds the Fire Water System Program for aluminum and aluminum heat exchanger components and piping, piping components, and piping elements acceptable.
On the bases of its review of AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant appropriately addressed the aging effect or mechanism as recommended by the GALL Report.
3.3.2.1.16 Loss of Material Due to Wear LRA Table 3.3.1, item 3.3.1-63, states that loss of material of carbon steel fire-rated doors exposed to air-indoor and air-outdoor environments is managed by the Fire Protection and Structures Monitoring Programs. During the audit and review, the staff noted that 14 AMR result items referring to LRA Table 3.3.1, item 3.3.1-63, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the material, environment, and aging effects are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M26, Fire Protection and GALL AMP XI.S6, Structures Monitoring, the applicant proposed the Fire Protection Program and the Structures Monitoring Program.
The applicant explained the use of Note E for carbon steel fire rated doors. The applicant explained that, although the GALL Report recommends the Fire Protection Program alone for management of the carbon steel fire-rated doors, the Structures Monitoring Program also ensures adequate management of the aging effects because the program has some of the program elements recommended by the GALL Report.
The staff's evaluations of the Fire Protection and Structures Monitoring Programs are documented in SER Sections 3.0.3.2.10 and 3.0.3.2.24, respectively.
On the basis of its review of the Fire Protection Program and the Structures Monitoring Program, the staff finds that the applicant adequately explained the reasons for Note E to the 12 AMR result items and that for carbon steel fire-rated doors the Fire Protection Program and the Structures Monitoring Program would adequately detect and manage aging effects for these components in indoor and outdoor air; therefore, the staff finds the Fire Protection Program and Structures Monitoring Program for carbon steel fire-rated doors acceptable.
On the bases of its review of AMR result items and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant appropriately 3-308
 
addressed the aging effect or mechanism as recommended by the GALL Report.
3.3.2.1.17 Concrete Cracking and Spalling Due to Aggressive Chemical Attack, and Reaction with Aggregates LRA Table 3.3.1, item 3.3.1-65, states that concrete cracking and spalling due to aggressive environments and reaction with aggregates of reinforced concrete exposed to air-indoor environments in the containment building is managed by the Fire Protection and ASME Section XI, Subsection IWL Programs. During the audit and review, the staff noted that one AMR result item referring to LRA Table 3.3.1, item 3.3.1-65, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the material, environment, and aging effects are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M26, Fire Protection and GALL AMP XI.S6, Structures Monitoring, the applicant proposed the Fire Protection Program and the ASME Section XI, Subsection IWL Program. The applicant explained the use of Note E for reinforced concrete fire barriers. Although the GALL Report recommends the Fire Protection Program and the Structures Monitoring Program for management of reinforced concrete in the containment building, the applicant uses the ASME Section XI, Subsection IWL Program in lieu of the Structures Monitoring Program because it is appropriate for reinforced concrete in containment to manage aging effects adequately because the ASME Section XI, Subsection IWL Program has some of the program elements recommended by the GALL Report.
The staff's evaluations of the Fire Protection and ASME Section XI, Subsection IWL Programs are documented in SER Sections 3.0.3.2.10 and 3.0.3.2.20, respectively.
On the basis of its review of the Fire Protection Program and the ASME Section XI, Subsection IWL Program, the staff finds that the applicant adequately explained the reasons for Note E to the AMR result item and that, for containment building reinforced concrete, the Fire Protection Program and the ASME Section XI, Subsection IWL Program would adequately detect and manage aging effects these components in indoor air; therefore, the staff finds the Fire Protection Program and ASME Section XI, Subsection IWL Program for containment reinforced concrete fire barriers acceptable.
On the bases of its review of the AMR result item and its comparison of the applicants results to corresponding GALL Report recommendations, the staff finds that the applicant appropriately addressed the aging effect or mechanism as recommended by the GALL Report.
3.3.2.1.18 Concrete Cracking and Spalling Due to Freeze Thaw, Aggressive Chemical Attack, and Reaction with Aggregates LRA Table 3.3.1, item 3.3.1-66, states that cracking of the reinforced concrete structural fire barriers (walls, ceilings and floors) exposed to air-outdoor environments is managed by a combination of the Fire Protection and ASME Section XI, Subsection IWL Programs for the containment cylinder wall. During the audit and review, the staff noted that the AMR result item 3-309
 
referring to LRA Table 3.3.1, item 3.3.1-66, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends a combination of the Fire Protection and Structures Monitoring Programs, the applicant proposed a combination of the Fire Protection and ASME Section XI, Subsection IWL Programs. The applicants existing Fire Protection Program will be consistent with GALL AMP XI.M26 following enhancement. The staff's evaluation of the Fire Protection Program is documented in SER Section 3.0.3.2.10. The ASME Section XI, Subsection IWL Program periodically visually inspects reinforced concrete containment structures. The staff's evaluation of the ASME Section XI, Subsection IWL Program is documented in SER Section 3.0.3.2.20. On the basis of periodic visual inspections, the staff finds the applicant's ASME Section XI, Subsection IWL Program acceptable.
On the bases of its review of the AMR result item and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.19 Loss of Material Due to Corrosion of Embedded Steel LRA Table 3.3.1, item 3.3.1-67, states that the loss of material of the reinforced concrete structural fire barriers (walls, ceilings and floors) exposed to air-outdoor or uncontrolled air-indoor environments is managed by a combination of the Fire Protection and ASME Section XI, Subsection IWL Programs for the containment cylinder wall. During the audit and review, the staff noted that the two AMR result items referring to LRA Table 3.3.1, item 3.3.1-67, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends a combination of GALL AMP XI.M26, Fire Protection, and GALL AMP XI.S6, Structures Monitoring Program, the applicant proposed a combination of the Fire Protection and ASME Section XI, Subsection IWL Programs. The applicants existing Fire Protection Program will be consistent with GALL AMP XI.M26 following enhancement. The staff's evaluation of the Fire Protection Program is documented in SER Section 3.0.3.2.10. The ASME Section XI, Subsection IWL Program periodically visually inspects reinforced concrete containment structures. The staff's evaluation of the ASME Section XI, Subsection IWL Program is documented in SER Section 3.0.3.2.20.
On the basis of periodic visual inspections, the staff finds the applicant's ASME Section XI, Subsection IWL Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.20 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion, and Fouling 3-310
 
LRA Table 3.3.1, item 3.3.1-68, states that loss of material and fouling of steel piping, piping components, piping elements, and tanks and fuel handling building decontamination transfer pump casings exposed to raw water is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program for various drain and waste collection systems.
During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-68, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends the Fire Water System Program, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program to manage the aging effect for various drain and collection systems. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program periodically visually inspects internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. During the audit and review, the staff confirmed that LRA Table 3.3.1, item 3.3.1-68, was for steel component types exposed to raw water in drain and collection auxiliary systems. On the basis of periodic visual inspections, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.21 Loss of Material Due to Pitting and Crevice Corrosion and Fouling LRA Table 3.3.1, item 3.3.1-69, states that loss of material and fouling of stainless steel component types in various drain, waste collection, and sampling auxiliary systems exposed to raw water is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-69, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends the Fire Water System Program, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program to manage the aging effect for various drain, waste collection, and sampling auxiliary systems. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. This program periodically visually inspects internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. During the audit and review, the staff confirmed that LRA Table 3.3.1, item 3.3.1-69, was for stainless steel component types exposed to raw water in drain, waste collection, and sampling auxiliary systems. On the basis of periodic visual inspections, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
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On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.22 Loss of Material Due to Pitting, Crevice, and Microbiologically Influenced Corrosion, and Fouling LRA Table 3.3.1, item 3.3.1-70, states that loss of material and fouling of copper alloy piping, piping components and piping elements, and system strainers in the oily drains system exposed to raw water is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-70, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends the Fire Water System Program, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program to manage the aging effect for various drain, waste collection, and sampling auxiliary systems. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is documented in SER Section 3.0.3.1.7. This program periodically visually inspects the internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. During the audit and review, the staff confirmed that LRA Table 3.3.1, item 3.3.1-70, was for copper alloy component types exposed to raw water in the oily drains system. On the basis of periodic visual inspections, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.23 Loss of Material Due to General, Pitting, and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-71, states that loss of material of steel component types in the diesel generator fuel oil storage and transfer, security power, and fire protection systems with air spaces above the fuel oil (air/gas (wetted) environment) is managed by a combination of the Fuel Oil Chemistry and One-Time Inspection Programs. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-71, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, the applicant proposed a combination of the Fuel Oil Chemistry and One-Time Inspection Programs to manage the aging effect for the steel surfaces above the fuel oil within various component types. The staff's evaluations of the Fuel Oil Chemistry and One-Time Inspection Programs are documented in 3-312
 
SER Sections 3.0.3.2.12 and 3.0.3.1.5, respectively.
The Fuel Oil Chemistry Program maintains fuel oil quality by monitoring and controlling fuel oil contamination and by periodic testing to detect biological growth. The program minimizes exposure to fuel oil contaminants (e.g., water and microbiological organisms) by verifying the quality of new oil, adding stabilizers before its introduction into the storage tanks, and periodically sampling for whether the tanks are free of water, particulates, and biological growth. The effectiveness of the program is verified by periodic tank inspections for whether significant degradation has occurred. The One-Time Inspection Program verifies the effectiveness of the Fuel Oil Chemistry Program. The staff confirmed that the diesel generator fuel oil storage and transfer, security power, and fire protection systems are within the scope of the One-Time Inspection Program to verify effectiveness of the Fuel Oil Chemistry Program to manage loss of material. On this basis, the staff finds the applicant's Fuel Oil Chemistry and One-Time Inspection Programs acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.24 Loss of Material Due to General, Pitting, Crevice, and (For Drip Pans and Drain Lines) Microbiologically Influenced Corrosion LRA Table 3.3.1, item 3.3.1-72 states that loss of material of steel surfaces in the diesel fuel oil storage tank building tank liners and fuel oil day tanks in the diesel fuel oil storage and transfer system with air spaces above the fuel oil (air/gas (wetted) environment) is managed by a combination of the Fuel Oil Chemistry and One-Time Inspection Programs. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-72 refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, the applicant proposed a combination of the Fuel Oil Chemistry and One-Time Inspection Programs to manage the aging effect for the steel surfaces above the fuel oil within various component types. The staff's evaluations of the Fuel Oil Chemistry and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.12 and 3.0.3.1.5, respectively.
The Fuel Oil Chemistry Program maintains fuel oil quality by monitoring and controlling fuel oil contamination and by periodic testing to detect biological growth. The program minimizes exposure to fuel oil contaminants (e.g., water and microbiological organisms) by verifying the quality of new oil, adding stabilizers before its introduction into the storage tanks, and periodically sampling for whether the tanks are free of water, particulates, and biological growth. The effectiveness of the program is verified by periodic tank inspections for whether significant degradation has occurred. The One-Time Inspection Program verifies the effectiveness of the Fuel Oil Chemistry Program. The staff confirmed that the diesel fuel oil storage and transfer system is within the scope of the One-Time Inspection Program to verify 3-313
 
the effectiveness of the Fuel Oil Chemistry Program to manage loss of material. On this basis, the staff finds the applicant's Fuel Oil Chemistry and One-Time Inspection Programs acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.25 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion, Fouling, and Lining/Coating LRA Table 3.3.1, item 3.3.1-76, states that loss of material for (1) carbon or low-alloy steel buried and above-ground piping, piping components, piping elements, fire service screen wash pumps, system strainers, normal service water pumps, normal service water seal and bearing water booster pumps in the circulating water, cooling tower make-up, screen wash, normal service water, and upflow filter systems and (2) gray cast-iron piping, piping components, piping elements, fire service screen wash pumps, and normal service water pumps in the cooling tower, screen wash, and normal service water systems with either a raw water internal or external environment is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program and the External Surfaces Monitoring Program (for gray cast iron in external raw water environments in the cooling tower system only). Further, LRA Table 3.3.1, item 3.3.1-76, states that loss of material for carbon steel piping, piping components, and piping elements in the steam generator wet lay-up system in raw water environments is managed by the One-Time Inspection Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-76, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components and External Surfaces Monitoring Programs to manage the aging effects for various carbon or low-alloy steel and gray cast-iron component types. Furthermore, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the One-Time Inspection Program to manage aging effects for various carbon or low-alloy steel piping, piping components, and piping elements in the steam generator wet lay-up system. The staff's evaluations of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, External Surfaces Monitoring, and One-Time Inspection Programs are documented in SER Sections 3.0.3.1.7, 3.0.3.1.5, and 3.0.3.2.16, respectively. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Open-Cycle Cooling Water System Program.
In its response dated August 20, 2007, the applicant explained that the Open-Cycle Cooling Water System Program is based on GL 89-13, which addresses only safety-related emergency service water and emergency screen wash systems and excludes nonsafety-related systems 3-314
 
except the normal service water system containment isolation valves, and that although these nonsafety-related components are outside the scope of GL 89-13 and the Open-Cycle Cooling Water System Program, they are subjected to the same preventive measures as those of the program. The applicant showed how the Open-Cycle Cooling Water System Programs preventive measures were present in the nonsafety-related systems even though GL 89-13 does not address them. Examples included the use of appropriate materials or linings and coatings to protect underlying material from aggressive cooling water environments and periodic flushing of stagnant system portions. The applicant further explained that some of the nonsafety-related systems utilize raw water from the cooling tower basin and that, because the cooling tower basin is the normal source of biocide chemical treatment for those systems addressed by GL 89-13, the nonsafety-related systems using the cooling tower basin are also treated with biocide equivalent to the requirements of the Open-Cycle Cooling Water System Program. The applicant listed nonsafety-related systems (e.g., circulating water system, cooling tower system, normal service water system, and the waste processing building cooling water system) using the cooling tower basin as a source.
The applicant noted that, although the cooling tower make-up system, screen wash system, and the upflow filter system use water directly from the lake, their intended functions do not support safety-related functions. The applicant concluded that these systems therefore require no biocide as preventive measures because fouling would not prevent successful performance of their intended functions. The applicant stated that flushing of the nonsafety-related systems is for intended functions that require flow; however, flushing on those systems would not necessarily be within the scope of license renewal for spatial interactions. The applicant addressed silt build-up in Bays 1 and 8, from which the screen wash system takes suction, collocated with Bay 6. Additionally, the applicant explained that the safety-related emergency service water system (within the scope of GL 89-13) takes suction from Bays 6 and 8, which undergo periodic silting inspections with results documented and trended.
On the bases that the nonsafety-related carbon or low-alloy steel or gray cast-iron components in various auxiliary systems exposed to raw water are subject to periodic inspection and that its preventive actions are equivalent (as required) to those of the Open-Cycle Cooling Water System Program, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable because its program elements would adequately manage the effects of aging.
On the bases that the nonsafety-related gray cast-iron components in the cooling water system exposed to raw water are subject to periodic inspection and that its preventive actions are equivalent (as required) to those of the Open-Cycle Cooling Water System Program, the staff finds the applicants External Surfaces Monitoring Program acceptable because its program elements would adequately manage the effects of aging.
On the bases that the nonsafety-related carbon or low-alloy steel components in the steam generator wet lay-up system exposed to raw water are within the scope of license renewal solely for spatial interaction and that the component in this AMR result item is a sample cooler that, although cooled by raw water, is no longer in service, the staff finds the applicants One-Time Inspection Program acceptable. The acceptability is based on the One-Time Inspection Program detection element for aging effects likely to progress slowly due to the 3-315
 
systems retirement in place.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.26 Loss of Material Due to General, Pitting, Crevice, Galvanic, and Microbiologically Influenced Corrosion, and Fouling LRA Table 3.3.1, item 3.3.1-77, states that loss of material for carbon or low-alloy steel piping, piping components, and piping elements in the boron thermal regeneration system with raw water internal environments is managed by the One-Time Inspection Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-77, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the One-Time Inspection Program to manage the aging effects for various carbon or low-alloy steel component types. During the audit and review, the staff asked the applicant to clarify how this program is more suitable than the Open-Cycle Cooling Water System Program to manage this aging effect.
In its response dated August 20, 2007, the applicant explained that the assignment of the One-Time Inspection Program is not appropriate and that it would amend the LRA to reassign this result item (on LRA page 3.3-134) from the One-Time Inspection Program to the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program, delete the plant-specific Note 369 from this line item, and change the discussion column for LRA Table 3.3.1, item 3.3.1-77, to replace One-Time Inspection Program with the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Programs is documented in SER Section 3.0.3.1.7. In the same August 20, 2007 letter, the applicant amended the LRA as described.
On the basis of periodic visual inspections of nonsafety-related carbon or low-alloy steel components in the boron thermal regeneration system exposed to raw water, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.27 Loss of Material Due to Pitting and Crevice Corrosion, and Fouling LRA Table 3.3.1, item 3.3.1-79, states that loss of material for stainless steel piping, piping 3-316
 
components, piping elements, system strainer screens/elements, and system strainers in the cooling tower, screen wash, normal service water, and upflow filter systems in either raw water internal or environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-79, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the aging effects for various stainless steel component types. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Open-Cycle Cooling Water System Program.
The applicants response and the staffs evaluation are in SER Section 3.3.2.1.25.
On the bases that the nonsafety-related stainless steel components in various auxiliary systems exposed to raw water are subject to periodic inspection and that their preventive actions are equivalent (as required) to those of the Open-Cycle Cooling Water System Program, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable because its program elements would adequately manage the effects of aging.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.28 Loss of Material Due to Pitting, Crevice, and Microbiologically Influenced Corrosion LRA Table 3.3.1, item 3.3.1-80, states that loss of material for stainless steel piping, piping components, piping elements, system strainer screens/elements, and system strainers in the cooling tower, screen wash, normal service water, upflow filter, and reactor auxiliary building ventilation systems in either raw water internal or external air/gas (wetted outside) environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-80, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the aging effects for 3-317
 
various stainless steel component types. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Sections 3.0.3.1.7. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Open-Cycle Cooling Water System Program.
The applicants response and the staffs evaluation are in SER Section 3.3.2.1.25.
On the bases that the nonsafety-related stainless steel components in various auxiliary systems exposed to raw water or air/gas (wetted outside) are subject to periodic inspection and that their preventive actions are equivalent (as required) to those of the Open-Cycle Cooling Water System Program, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable because its program elements would adequately manage the effects of aging.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.29 Loss of Material Due to Pitting, Crevice, Microbiologically-Influenced Corrosion, and Fouling LRA Table 3.3.1, item 3.3.1-81, states that loss of material for copper alloy piping, piping components, piping elements, and system strainer screens/elements in the screen wash, waste processing building cooling water, and upflow filter systems with raw water internal environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-81, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the aging effects for various copper alloy component types. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Open-Cycle Cooling Water System Program.
The applicants response and the staffs evaluation are in SER Section 3.3.2.1.25.
On the bases that nonsafety-related copper alloy components in various auxiliary systems exposed to raw water are subject to periodic inspection and that their preventive actions are 3-318
 
equivalent (as required) to those of the Open-Cycle Cooling Water System Program, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable because its program elements would adequately manage the effects of aging.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.30 Loss of Material Due to Pitting, Crevice, Galvanic, and Microbiologically Influenced Corrosion, and Fouling LRA Table 3.3.1, item 3.3.1-82, states that loss of material from copper alloy piping, piping components, and piping elements in the waste processing building cooling water system with raw water internal environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that the AMR result item referring to LRA Table 3.3.1, item 3.3.1-82, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M20, Open-Cycle Cooling Water System, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the aging effects for copper alloy piping, piping components, and piping elements. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Open-Cycle Cooling Water System Program.
The applicants response and the staffs evaluation are in SER Section 3.3.2.1.25.
On the bases that the nonsafety-related copper alloy components in the waste processing building cooling water system exposed to raw water are subject to periodic inspection and that their preventive actions are equivalent (as required) to those of the Open-Cycle Cooling Water System Program, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable because its program elements would adequately manage the effects of aging.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.31 Loss of Material Due to Boric Acid Corrosion LRA Table 3.3.2-14 shows Table 3.3.1, item 3.3.1-89, managing loss of material due to boric 3-319
 
acid corrosion for carbon or low-alloy steel piping, piping components, piping elements, and tanks exposed to treated water (inside). During the audit and review, the staff asked the applicant to justify the use of this Table 1 item to manage this aging effect for component types exposed to this environment.
In its response dated August 20, 2007, the applicant stated that there was a mistake in LRA Table 3.3.2-14 on page 3.3-201. Under carbon or low-alloy steel piping, piping components, piping elements, and tanks, the environment for results items which refer to Table 3.3.1, items 3.3.1-59 and 3.3.1-89 should read air - indoor (outside). In the same August 20, 2007 letter, the applicant amended LRA Table 3.3.2-14 for these components to make this correction. With this change, the staff finds the response consistent with the GALL Report and acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.32 Cracking Due to Stress Corrosion Cracking LRA Table 3.3.1, item 3.3.1-90, states that cracking for stainless steel piping, piping components, and piping elements in the spent resin storage and transfer system in treated water internal environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that the AMR result item referring to LRA Table 3.3.1, item 3.3.1-90, refers to Note E.
The staff reviewed the AMR result item referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M2, Water Chemistry, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the aging effects for stainless steel piping, piping components, and piping elements. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The staff asked how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Water Chemistry Program.
In its response dated August 20, 2007, the applicant explained that the LRA was incorrect in applying the AMR result item because the fluid temperature is not likely to exceed that required for this mechanism. The applicant further stated that it would amend the LRA to delete this AMR line. In the same letter, the applicant amended LRA Table 3.3.2-49 to delete this AMR line.
On the basis that the normal fluid temperature does not exceed the threshold for SCC in stainless steel piping, piping components, and piping elements the staff finds the applicants deletion of this AMR result item acceptable.
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On the bases of its review of the AMR result item and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
3.3.2.1.33 Loss of Material Due to Pitting and Crevice Corrosion LRA Table 3.3.1, item 3.3.1-91, states that loss of material of stainless steel component types in the radioactive equipment drains and spent resin storage and transfer systems in treated water internal environments is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During the audit and review, the staff noted that the AMR result items referring to LRA Table 3.3.1, item 3.3.1-91, refer to Note E.
The staff reviewed the AMR result items referring to Note E and determined that the component type, material, environment, and aging effect are consistent with those of the corresponding line of the GALL Report; however, where the GALL Report recommends GALL AMP XI.M2, Water Chemistry, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the aging effects for stainless steel piping, piping components, and piping elements. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. During the audit and review, the staff asked the applicant to clarify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program adequately manages aging effects for these components without the benefit of preventive measures by the Open-Cycle Cooling Water System Program.
In its letter response August 20, 2007, the applicant explained that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program was in lieu of the Water Chemistry Program because neither system is safety-related. The applicant stated that the periodic inspections proceed during routine maintenance when the surfaces are accessible for visual inspection. Additionally, the program visually inspects for whether existing environmental conditions cause material degradation that could result in a loss of component intended functions. The applicant concluded that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components manages the equipment appropriately.
On the bases that the applicant clarified that these nonsafety-related components are routinely inspected through normal maintenance and that they are normally accessible, the staff finds the applicants Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program acceptable.
On the bases of its review of the AMR result items and its comparison of the applicant's results to corresponding GALL Report recommendations, the staff finds that the applicant addressed the aging effect or mechanism appropriately as recommended by the GALL Report.
The staff evaluated the applicants claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicants consideration of recent operating experience and proposals for managing aging effects. On the basis of its review, the staff concludes that the AMR results, which the applicant claimed to be consistent with the GALL Report, are indeed 3-321
 
consistent with its AMRs; therefore, the staff concludes that the applicant has demonstrated that the effects of aging for these components will be adequately managed so that their intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2 AMR Results Consistent with the GALL Report for Which Further Evaluation is Recommended In LRA Section 3.3.2.2, the applicant further evaluates aging management, as recommended by the GALL Report, for the auxiliary systems components and provides information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* reduction of heat transfer due to fouling
* SCC
* SCC and cracking due to cyclic loading
* hardening and loss of strength due to elastomer degradation
* reduction of neutron-absorbing capacity and loss of material due to general corrosion
* loss of material due to general, pitting, and crevice corrosion
* loss of material due to general, pitting, crevice, and MIC
* loss of material due to general, pitting, crevice, MIC and fouling
* loss of material due to pitting and crevice corrosion
* loss of material due to pitting, crevice, and galvanic corrosion
* loss of material due to pitting, crevice, and MIC
* loss of material due to wear
* loss of material due to cladding breach
* QA for aging management of nonsafety-related components For component groups evaluated in the GALL Report, for which the applicant claimed consistency with the report and for which the report recommends further evaluation, the staff audited and reviewed the applicants evaluation to determine whether it adequately addressed the issues further evaluated. In addition, the staff reviewed the applicants further evaluations against the criteria contained in SRP-LR Section 3.3.2.2.The staffs review of the applicants further evaluation follows.
3.3.2.2.1 Cumulative Fatigue Damage LRA Section 3.3.2.2.1 states that fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). SER Section 4.3 documents the staffs review of the applicants evaluation of this TLAA.
3.3.2.2.2 Reduction of Heat Transfer Due to Fouling The staff reviewed LRA Section 3.3.2.2.2 against the criteria in SRP-LR Section 3.3.2.2.2.
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LRA Section 3.3.2.2.2 addresses reduction of heat transfer due to fouling, stating that such reduction of heat transfer could occur for stainless steel heat exchanger tubes exposed to treated water. The SRP-LR and the GALL Report apply this aging mechanism or effect to both BWR and PWR nuclear power plants; however, unique items VII.A4-4 (AP-62) and VII.E3-6 (AP-62) apply to BWR plants only.
SRP-LR Section 3.3.2.2.2 states that reduction of heat transfer due to fouling may occur in stainless steel heat exchanger tubes exposed to treated water. The existing program controls water chemistry to manage reduction of heat transfer due to fouling; however, control of water chemistry may be inadequate; therefore, the GALL Report recommends that the effectiveness of water chemistry control programs should be verified to ensure that reduction of heat transfer due to fouling does not occur. A one-time inspection is an acceptable method to ensure that reduction of heat transfer does not occur and that component intended functions will be maintained during the period of extended operation.
On the basis that unique items VII.A4-4 (AP-62) and VII.E3-6 (AP-62) apply to BWR plants only because the stainless steel heat exchanger tubes subject to reduction of heat transfer due to fouling refer to BWR spent fuel pool cooling and cleanup and reactor water cleanup systems, the staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
On the basis that HNP has no components from this group, the staff finds that this aging effect is not present.
3.3.2.2.3 Cracking Due to Stress Corrosion Cracking The staff reviewed LRA Section 3.3.2.2.3 against the following criteria in SRP-LR Section 3.3.2.2.3:
(1)  LRA Section 3.3.2.2.3 addresses SCC in BWR standby liquid control system components, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.3.2.2.3 states that SCC could occur in the stainless steel piping, piping components, and piping elements of the BWR standby liquid control system exposed to sodium pentaborate solution greater than 60 EC (140 EF).
The staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
(2)  LRA Section 3.3.2.2.3 addresses SCC in heat exchanger components, stating that the SRP-LR and the GALL Report apply this aging mechanism or effect to both PWR and BWR nuclear power plants; however, Unique Items VII.E3-3 (A-71) and VII.E3-19 (A-85) apply to BWR systems only (i.e., the reactor water cleanup system).
SRP-LR Section 3.3.2.2.3 states that SCC may occur in stainless steel and stainless clad steel heat exchanger components exposed to treated water greater than 60 EC (140 3-323
 
EF). The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately managed.
The staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
(3)  LRA Section 3.3.2.2.3 addresses SCC in stainless steel diesel exhaust piping, stating that such cracking could occur in piping, piping components, and piping elements exposed to diesel exhaust. The carbon steel emergency diesel generator system diesel engine exhaust piping has a stainless steel expansion joint for which SCC is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The program assures by visual inspections that environmental conditions cause no material degradation that could result in a loss of component intended functions.
SRP-LR Section 3.3.2.2.3 states that SCC may occur in stainless steel diesel engine exhaust piping, piping components, and piping elements exposed to diesel exhaust. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately managed.
The staff reviewed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program and determined that by visual techniques for inspecting the stainless steel diesel exhaust components the aging effect of cracking will be adequately managed.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.3 criteria. For those line items that apply to LRA Section 3.3.2.2.3, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.4 Cracking Due to Stress Corrosion Cracking and Cyclic Loading The staff reviewed LRA Section 3.3.2.2.4 against the following criteria in SRP-LR Section 3.3.2.2.4:
(1)  LRA Section 3.3.2.2.4 addresses SCC and cyclic loading in cracking of PWR nonregenerative heat exchanger components, stating that such cracking could occur in stainless steel nonregenerative heat exchanger components exposed to treated water greater than 140 EF in the chemical and volume control system. A combination of the Water Chemistry Program and the One-Time Inspection Program manages cracking of chemical and volume control system heat exchanger components. The Water Chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking and loss of material aging effects. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or 3-324
 
trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation. The applicant has selected the One-Time Inspection Program in lieu of radioactivity monitoring of the shell side water and eddy-current testing of tubes.
SRP-LR Section 3.3.2.2.4 states that SCC and cyclic loading could occur in stainless steel PWR nonregenerative heat exchanger components exposed to treated borated water greater than 60 EC (140 EF) in the chemical and volume control system. The existing AMP monitors and controls primary water chemistry in PWRs to manage the aging effects of SCC; however, control of water chemistry does not preclude SCC and cracking due to cyclic loading; therefore, the effectiveness of water chemistry control programs should be verified to ensure that cracking does not occur. The GALL Report recommends that a plant-specific AMP be evaluated to verify the absence of SCC and cracking due to cyclic loading to ensure that these aging effects are adequately managed. An acceptable verification program is to include temperature and radioactivity monitoring of the shell side water and eddy current testing of tubes.
The staff reviewed LRA Section 3.3.2.2.4, which credits the Water Chemistry and the One-Time Inspection Programs in combination for managing SCC and cracking due to cyclic loading of stainless steel nonregenerative heat exchanger components. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Water Chemistry Program to manage cracking for stainless steel nonregenerative heat exchanger components in the CVCS. On the basis of its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.4 by verifying the effectiveness of the Water Chemistry Program by one-time inspections.
(2) LRA Section 3.3.2.2.4 addresses SCC and cyclic loading in cracking of PWR regenerative heat exchanger components, stating that such cracking could occur in stainless steel regenerative heat exchanger components exposed to treated water greater than 140 EF. A combination of the Water Chemistry Program and the One-Time Inspection Program manages cracking of CVCS heat exchanger components.
SRP-LR Section 3.3.2.2.4 states that SCC and cracking due to cyclic loading may occur in stainless steel PWR regenerative heat exchanger components exposed to treated borated water greater than 60 EC (140 EF). The existing AMP monitors and controls primary water chemistry in PWRs to manage the aging effects of SCC; however, control of water chemistry does not preclude SCC and cracking due to cyclic loading; therefore, the effectiveness of water chemistry control programs should be verified to ensure that cracking does not occur. The GALL Report recommends that a plant-specific AMP be evaluated to verify the absence of SCC and cracking due to cyclic loading to ensure that these aging effects are adequately managed.
The staff reviewed LRA Section 3.3.2.2.4, which credits the Water Chemistry and the One-Time Inspection Programs in combination for managing SCC and cracking due to cyclic loading of stainless steel regenerative heat exchanger components. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Water Chemistry Program in managing cracking for such components. On the basis of 3-325
 
its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.4 by verifying the effectiveness of the Water Chemistry Program by one-time inspections.
(3)  LRA Section 3.3.2.2.4 addresses SCC and cyclic loading in cracking of PWR pumps in the CVCS, stating that a combination of the Water Chemistry Program and the One-Time Inspection Program manages cracking of CVCS stainless steel pump casings. The Water chemistry Program monitors and controls water chemistry using site procedures and processes to prevent or mitigate the cracking aging effect. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.3.2.2.4 states that SCC and cracking due to cyclic loading may occur in the stainless steel pump casing for the PWR high-pressure pumps in the chemical and volume control system. The existing AMP monitors and controls primary water chemistry in PWRs to manage the aging effects of SCC; however, control of water chemistry does not preclude SCC and cracking due to cyclic loading; therefore, the effectiveness of water chemistry control programs should be verified to ensure that cracking does not occur. The GALL Report recommends that a plant-specific AMP be evaluated to verify the absence of SCC and cracking due to cyclic loading to ensure that these aging effects are adequately managed.
The staff reviewed LRA Section 3.3.2.2.4, which credits the Water Chemistry and the One-Time Inspection Programs in combination for managing SCC and cracking due to cyclic loading of stainless steel pump casings. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Water Chemistry Program in managing cracking for CVCS stainless steel pump casings. On the basis of its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.4 by verifying the effectiveness of the Water Chemistry Program by one-time inspections.
(4)  LRA Section 3.3.2.2.4 addresses SCC and cyclic loading in high-strength bolting exposed to steam or water leakage, stating that this aging effect is not present because HNP selects proper bolting material and lubricants and, through control of bolt torque, has eliminated bolting SCC effectively. Industry data and plant-specific operating experience support this conclusion.
During the onsite audit, the staff confirmed that there is no high-strength steel closure bolting in the auxiliary systems. On the basis that there are no components of this type exposed to steam or water leakage in the auxiliary systems, the staff finds acceptable the application's evaluation that this aging effect is not present.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.4 criteria. For those line items that apply to LRA Section 3.3.2.2.4, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, 3-326
 
as required by 10 CFR 54.21(a)(3).
3.3.2.2.5 Hardening and Loss of Strength Due to Elastomer Degradation The staff reviewed LRA Section 3.3.2.2.5 against the following criteria in SRP-LR Section 3.3.2.2.5:
(1)  LRA Section 3.3.2.2.5 addresses hardening and loss of strength due to elastomer degradation in HVAC system elastomer seals and components, stating that such hardening and loss of strength could occur in seals and components exposed to indoor air on internal or external surfaces. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages the internal surfaces of the HVAC system components and also manages similar aging effects of the diaphragm in the CVCS boric acid tank by internal inspections during periodic system and component surveillances or during maintenance activities when the surfaces are accessible. The visual inspections assure that environmental conditions cause no material degradation that could result in loss of component intended functions. The External Surfaces Monitoring Program manages the external surfaces of HVAC system components by system inspections and walk-downs with periodic visual inspections of steel components (i.e., piping, piping components, ducting) and other components within the scope of license renewal and subject to AMR.
SRP-LR Section 3.3.2.2.5 states that hardening and loss of strength due to elastomer degradation may occur in elastomer seals and components of heating and ventilation systems exposed to air - indoor uncontrolled (internal/external). The GALL Report recommends further evaluation of a plant-specific AMP to ensure that these aging effects are adequately managed.
The staff reviewed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components and External Surfaces Monitoring Programs, which together periodically inspect internal and external surfaces of HVAC components and the boric acid tank diaphragm during periodic system walk-downs and inspections when the surfaces are accessible. On the basis of periodic inspections, including opportunistic inspections of component internal surfaces, the staff determines that the Internal Surfaces in Miscellaneous Piping and Ducting Components and the External Surfaces Monitoring Programs will adequately manage the aging effects through the period of extended operation.
(2)  LRA Section 3.3.2.2.5 addresses hardening and loss of strength and components in HVAC systems in degradation of elastomer linings of components in spent fuel pool cooling and cleanup system components, stating that this aging effect is not present because HNP spent fuel pool cooling and cleanup components have no elastomer lining.
SRP-LR Section 3.3.2.2.5 states that hardening and loss of strength due to elastomer degradation may occur in elastomer linings of the filters, valves, and ion exchangers in 3-327
 
spent fuel pool cooling and cleanup systems (BWR and PWR) exposed to treated water or treated borated water.
On the basis that the spent fuel pool cooling and cleanup systems do not use elastomer linings, the staff finds acceptable the application's evaluation that this aging effect is not present.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.5 criteria. For those line items that apply to LRA Section 3.3.2.2.5, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.6 Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General Corrosion The staff reviewed LRA Section 3.3.2.2.6 against the criteria in SRP-LR Section 3.3.2.2.6.
LRA Section 3.3.2.2.6 addresses reduction of neutron-absorbing capacity and loss of material due to general corrosion, stating that such reduction of neutron-absorbing capacity and loss of material could occur in the neutron-absorbing materials of spent fuel storage racks exposed to treated water or treated borated water. The AMR evaluation reviewed current monitoring results for Boral testing and determined that the record of adverse plant-specific operating experience is negligible. Additionally, the staff has evaluated both the Virgil C. Summer and Brunswick Steam Electric nuclear plants for the aging effect of reduction of neutron-absorbing capacity.
The SERs for license renewal (NUREG-1787 for Summer, NUREG-1856 for Brunswick) determined the aging effect to be insignificant; therefore, the conclusion is that reduction of neutron-absorbing capacity for Boral requires no aging management. The Water Chemistry Program, however, will continue to manage the aging effect of loss of material.
SRP-LR Section 3.3.2.2.6 states that reduction of neutron-absorbing capacity and loss of material due to general corrosion may occur in the neutron-absorbing sheets of BWR and PWR spent fuel storage racks exposed to treated water or treated borated water. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that these aging effects are adequately managed.
During the onsite audit, the staff asked how the Water Chemistry Program will detect the loss of material.
In its response dated August 20, 2007, the applicant stated that recent plant-specific Boral testing results found negligible loss of material. Additionally, the applicant evaluated industry operating experience that also confirms that loss of material is a negligible aging effect for Boral spent fuel pool components. The applicant indicated that it would amend the LRA to indicate that Boral has no AERMs. The LRA plant-specific note for the Boral line item will be revised to clarify that Boral material has no AERMs. In the same August 20, 2007 letter, the applicant 3-328
 
amended LRA Table 3.5.2-17, Table 3.3.2, item 3.3.1-13, Subsection 3.3.2.2.6, and Note 570 to state that Boral material has no aging effects. Based on plant-specific and industry operating experience indicating that Boral material has no aging effects, the staff finds this response acceptable.
Based on the information provided above, the staff concludes that LRA Table 3.3.1, item 3.3.1-13 no longer applies to the amended LRA.
On the basis that HNP has no components from this group, the staff finds that this aging effect is not present.
3.3.2.2.7 Loss of Material Due to General, Pitting, and Crevice Corrosion The staff reviewed LRA Section 3.3.2.2.7 against the following criteria in SRP-LR Section 3.3.2.2.7:
(1)  LRA Section 3.3.2.2.7 addresses loss of material due to general, pitting, and crevice corrosion in steel components exposed to lubricating oil, stating that such loss of material could occur in steel components, including the reactor coolant pump lube oil leakage collection system, exposed to lubricating oil. Piping, tubing, valves, and tanks may be affected. A combination of the Lubricating Oil Analysis Program and the One-Time Inspection Program manages piping components exposed to lubricating oil.
The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to loss of material, cracking, or reduction of heat transfer. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain intended functions of affected components during the period of extended operation. The One-Time Inspection Program determines the thickness of the lower portion of the reactor coolant pump oil collection tank.
SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, and crevice corrosion may occur in steel piping, piping components, and piping elements, including the tubing, valves, and tanks in the reactor coolant pump oil collection system, exposed to lubricating oil (as part of the fire protection system). The existing AMP periodically samples and analyzes lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment not conducive to corrosion; however, control of lube oil contaminants may not always be fully effective in precluding corrosion; therefore, the effectiveness of lubricating oil control should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to manage corrosion to verify the effectiveness of the lubricating oil program. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation. In addition, corrosion may occur at locations in the reactor coolant pump oil collection tank where water from wash-downs may accumulate; therefore, the effectiveness of the program should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to manage loss of material due to general, pitting, and crevice corrosion, including 3-329
 
determination of the thickness of the lower portion of the tank. A one-time inspection is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
The staff reviewed the Lubricating Oil Analysis Program and the One-Time Inspection Program and determined that these programs will manage the aging effects of loss of material due to general, pitting, and crevice corrosion in steel components exposed to lubricating oil effectively. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program in managing loss of material due to general, pitting, and crevice corrosion for steel components exposed to lubricating oil. In addition, the One-Time Inspection Program, as stated in LRA Section 3.3.2.2.7, determines the thickness of the lower portion of the RCP oil collection tank. On the basis of its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.7 by verifying the effectiveness of the Lubricating Oil Analysis Program by one-time inspections.
(2) LRA Section 3.3.2.2.7 addresses loss of material due to general, pitting, and crevice corrosion in BWR reactor water cleanup and shutdown cooling systems, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, and crevice corrosion may occur in steel piping, piping components, and piping elements in the BWR reactor water cleanup and shutdown cooling systems exposed to treated water.
The staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
(3) LRA Section 3.3.2.2.7 addresses loss of material due to general (steel only), pitting, and crevice corrosion in diesel engine exhaust system piping, stating that loss of material could occur in steel and stainless steel piping, piping components, and piping elements exposed to diesel exhaust. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages the internal surfaces of piping components exposed to diesel exhaust by internal inspections during the periodic system and component surveillance or during maintenance activities when the surfaces are made accessible to assure that environmental conditions cause no material degradation that could result in a loss of component intended functions.
SRP-LR Section 3.3.2.2.7 states that loss of material due to general (steel only), pitting, and crevice corrosion may occur in steel and stainless steel diesel exhaust piping, piping components, and piping elements exposed to diesel exhaust. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately managed.
The staff reviewed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program that the applicant proposed in lieu of a plant-specific program and determined that by visual techniques for inspecting the steel and stainless 3-330
 
steel diesel exhaust components, the aging effects will be adequately managed for the period of extended operation.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.7 criteria. For those line items that apply to LRA Section 3.3.2.2.7, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.8 Loss of Material Due to General, Pitting, Crevice, and Microbiologically-Influenced Corrosion The staff reviewed LRA Section 3.3.2.2.8 against the criteria in SRP-LR Section 3.3.2.2.8.
LRA Section 3.3.2.2.8 addresses loss of material due to general, pitting, and crevice corrosion and MIC, stating that such loss of material could occur for steel piping, piping components, and piping elements buried in soil regardless of pipe coatings or wrappings. The Buried Piping and Tanks Inspection Program manages the external surfaces of piping components exposed to soil by preventive measures (e.g., coatings and wrappings required by design) to mitigate degradation and by visual inspections of external surfaces of buried piping components, when excavated, for evidence of coating damage and degradation.
SRP-LR Section 3.3.2.2.8 states that loss of material due to general, pitting, and crevice corrosion, and MIC may occur in steel (with or without coating or wrapping) piping, piping components, and piping elements buried in soil. Buried piping and tanks inspection programs rely on industry practice, frequency of pipe excavation, and operating experience to manage the effects of loss of material from general, pitting, and crevice corrosion and MIC. The effectiveness of the buried piping and tanks inspection program should be verified to evaluate an applicants inspection frequency and operating experience with buried components, ensuring that loss of material does not occur.
The staff reviewed the Buried Piping and Tanks Inspection Program that the applicant proposes for managing aging effects for buried components. The Buried Piping and Tanks Inspection Program requires documentation of as-found conditions of piping and coatings during any excavation, focused inspections at least every 10 years, one detailed inspection within the 10-year period prior to the period of extended operation, and inspection requirements and their results documented and retained. Finally, inspections will be by qualified inspectors with a coatings engineer to assess the effectiveness of coatings to protect buried components within the scope of the program. On the basis of the requirements of the Buried Piping and Tanks Inspection Program, the staff determines that the program will adequately manage the aging effects through the period of extended operation.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.8 criteria. For those line items that apply to LRA Section 3.3.2.2.8, the staff determines that the LRA is consistent with the GALL Report and that the applicant has 3-331
 
demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.9 Loss of Material Due to General, Pitting, Crevice, Microbiologically-Influenced Corrosion and Fouling The staff reviewed LRA Section 3.3.2.2.9 against the following criteria in SRP-LR Section 3.3.2.2.9:
(1)  LRA Section 3.3.2.2.9 addresses loss of material due to general, pitting, and crevice corrosion, MIC, and fouling in steel components exposed to fuel oil, stating that such loss of material could occur for steel piping, piping components, piping elements, and tanks exposed to fuel oil. A combination of the Fuel Oil Chemistry Program and the One-Time Inspection Program manages piping components and tanks exposed to fuel oil. The Fuel Oil Chemistry Program maintains fuel oil quality by monitoring and controlling fuel oil contamination in accordance with plant technical specifications and American Society for Testing and Materials guidelines. Exposure to fuel oil contaminants (e.g., water and microbiological organisms) is minimized by periodic draining or cleaning of tanks and by verifying new oil quality before its introduction into the storage tanks.
One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain intended functions of affected components during the period of extended operation.
SRP-LR Section 3.3.2.2.9 states that loss of material due to general, pitting, and crevice corrosion, MIC, and fouling may occur in steel piping, piping components, piping elements, and tanks exposed to fuel oil. The existing AMP relies on fuel oil chemistry programs to monitor and control fuel oil contamination to manage loss of material due to corrosion or fouling. Corrosion or fouling may occur at locations where contaminants accumulate. The effectiveness of fuel oil chemistry programs should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to manage loss of material due to general, pitting, and crevice corrosion, MIC, and fouling to verify the effectiveness of fuel oil chemistry programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
The staff reviewed the Fuel Oil Chemistry Program and the One-Time Inspection Program that the applicant proposes for managing aging effects of steel piping and tanks in fuel oil environments. The Fuel Oil Chemistry Program verifies fuel oil quality before introducing it to the system tanks and periodically checks for water accumulation, biological growth, and sediments. The Fuel Oil Chemistry Program requires corrective actions when fuel oil condition is out of tolerance. The One-Time Inspection Program verifies Fuel Oil Chemistry Program effectiveness. On the basis of the requirements of the Fuel Oil Chemistry Program and One-Time Inspection Program, the staff determines that they will adequately manage the aging effects through the period of extended operation.
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(2)  LRA Section 3.3.2.2.9 addresses loss of material due to general, pitting, and crevice corrosion, MIC, and fouling in steel heat exchanger components exposed to lubricating oil, stating that such loss of material could occur for steel heat exchanger components exposed to lubricating oil. A combination of the Lubricating Oil Analysis Program and the One-Time Inspection Program manages piping components exposed to lubricating oil.
The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to loss of material, cracking, or reduction of heat transfer. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.3.2.2.9 states that loss of material due to general, pitting, and crevice corrosion, MIC, and fouling may occur in steel heat exchanger components exposed to lubricating oil. The existing AMP periodically samples and analyzes lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment not conducive to corrosion; however, control of lube oil contaminants may not always be fully effective in precluding corrosion; therefore, the effectiveness of lubricating oil control should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to manage corrosion to verify the effectiveness of lubricating oil programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
The staff reviewed the Lubricating Oil Analysis Program and the One-Time Inspection Program that the applicant proposes for managing loss of material for steel heat exchanger components in lubricating oil environments and determines that they will adequately manage the aging effects for the period of extended operation. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program in managing loss of material for steel components exposed to lubricating oil. On the basis of its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.9 by verifying the effectiveness of the Lubricating Oil Analysis Program by one-time inspections.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.9 criteria. For those line items that apply to LRA Section 3.3.2.2.9, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.10 Loss of Material Due to Pitting and Crevice Corrosion The staff reviewed LRA Section 3.3.2.2.10 against the following criteria in SRP-LR Section 3.3.2.2.10:
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(1) LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in elastomer-lined steel components exposed to treated or treated borated water, stating that this aging effect is not present because the HNP spent fuel pool cooling and cleanup components have no elastomer lining.
SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in BWR and PWR steel piping with elastomer lining or stainless steel cladding exposed to treated water and treated borated water if the cladding or lining is degraded.
On the basis that the HNP spent fuel pool cooling and cleanup systems do not use elastomer linings, the staff finds acceptable the application's evaluation that this aging effect is not present.
(2) LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in stainless steel, steel with stainless cladding, and aluminum components exposed to treated water, stating that such loss of material for BWR Spent Fuel Pool Cooling and Cleanup, Reactor Water Cleanup, and Shutdown Cooling System piping components is occurs in BWR plants only. The SRP-LR applies this aging mechanism or effect to both BWR and PWR plants; however, Unique Items VII.A4-11, VII.E3-15, VII.E4-14, VII.A4-5, VII.E3-7, and VII.E4-4 apply only to BWR plants.
SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in stainless steel and aluminum piping, piping components, piping elements, and for stainless steel and steel with stainless steel cladding heat exchanger components exposed to treated water. The existing AMP monitors and controls reactor water chemistry to manage the aging effects of loss of material from pitting and crevice corrosion; however, high concentrations of impurities in crevices and with stagnant flow conditions may cause pitting or crevice corrosion; therefore, the effectiveness of water chemistry control programs should be verified to ensure that corrosion does not occur.
The GALL Report recommends further evaluation of programs to manage loss of material from pitting and crevice corrosion to verify the effectiveness of water chemistry control programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
The staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
(3) LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in copper alloy HVAC components exposed to condensation, stating that for copper alloy with a zinc content of less than 15 percent the AMR methodology does not predict aging effects in the absence of contaminants. In the HVAC systems, condensation is present but drained away as it forms on the cooling coil to inhibit the concentration of contaminants.
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SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in copper alloy heating, ventilation, and air conditioning (HVAC) piping, piping components, and piping elements exposed to condensation (external).
The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately managed.
The staff reviewed LRA Section 3.3.2.2.10, which states that copper alloy HVAC piping, piping components, and piping elements exposed to condensation have no probable aging effects. During the audit and review, the staff asked the applicant to explain why there are no aging effects for the copper alloy HVAC components.
In its response, the applicant explained that the specific HVAC components for this aging effect are the actual cooling coils within the HVAC unit and that, due to the orientation of the tubing comprising the cooling coils and its round shape with no fins, contaminants cannot collect and concentrate. Additionally, the air is filtered and contaminants removed before they can settle on the tubing and filters are periodically replaced to ensure their effectiveness. Lastly, the plant-specific operating experience shows no external age-related degradation for copper alloy HVAC cooling coils. On the basis that contaminants are not able to collect and concentrate on the cooling coils because of their orientation absence of fins, the staff concurs that there are no aging effects.
(4) LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in copper alloy HVAC piping components exposed to lubricating oil, stating that such loss of material could occur for copper alloy piping, piping components, and piping elements exposed to lubricating oil. The Lubricating Oil Analysis Program and the One-Time Inspection Program manage piping components exposed to lubricating oil. The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to loss of material, cracking, or reduction of heat transfer. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in copper alloy piping, piping components, and piping elements exposed to lubricating oil. The existing AMP periodically samples and analyzes lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment not conducive to corrosion; however, control of lube oil contaminants may not always be fully effective in precluding corrosion; therefore, the effectiveness of lubricating oil control should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to manage corrosion to verify the effectiveness of lubricating oil programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
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The staff reviewed the Lubricating Oil Analysis Program and the One-Time Inspection Program that the applicant proposes for managing loss of material for copper and copper alloy components in lubricating oil environments and determines that they will adequately manage the aging effects for the period of extended operation. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program in managing loss of material for steel components exposed to lubricating oil. On the basis of its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.10 by verifying the effectiveness of the Lubricating Oil Analysis Program by one-time inspections.
(5) LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in aluminum HVAC components and stainless steel components exposed to condensation, stating that such loss of material could occur for HVAC aluminum piping, piping components, and piping elements and stainless steel ducting and components so exposed. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages this aging effect for the bird screens in the containment purge system by internal inspections during the periodic system and component surveillances or during maintenance activities when the surfaces are accessible to assure that environmental conditions cause no material degradation that could result in a loss of component intended functions.
SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in HVAC aluminum piping, piping components, and piping elements and stainless steel ducting and components exposed to condensation. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately managed.
The staff reviewed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program that the applicant proposed in lieu of a plant-specific program and determined that by visual techniques for inspecting stainless steel and aluminum HVAC components exposed to condensation, the aging effects will be adequately managed for the period of extended operation.
(6) LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in copper alloy fire protection piping components exposed to condensation, stating that such loss of material could occur for copper alloy fire protection system piping, piping components, and piping elements so exposed. The applicant considers condensing environments as capable of concentrating contaminants and assumed, therefore, a raw water environment for these components. Either the Fire Water System Program or the Selective Leaching of Materials Program manages fire protection system copper alloy components exposed internally to condensation. The Fire Water System Program monitors system pressure, evaluates wall thickness, periodically tests flow and pressure in accordance with applicable National Fire Protection Association commitments, and periodically inspects overall system condition visually. The Selective Leaching of Materials Program includes one-time inspections and qualitative determinations for selected components that may be susceptible to selective leaching.
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SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in copper alloy fire protection system piping, piping components, and piping elements exposed to internal condensation. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately managed.
The staff reviewed the Fire Water System Program and the Selective Leaching of Materials Program, either of which the applicant proposes for managing loss of material for copper alloy fire protection piping, piping components, and piping elements internally exposed to condensation environments. The staff determines that either program will adequately manage the aging effects for the period of extended operation because either adequately detects and quantifies loss of material for these components. On this basis, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.10.
(7)  LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in stainless steel piping components exposed to soil, stating that this aging effect is not present because the systems containing service water and the fire protection, diesel generator fuel oil storage and transfer system, and emergency diesel generator system have no stainless steel components exposed to soil; therefore, this loss of material is not present.
SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in stainless steel piping, piping components, and piping elements exposed to soil.
On the basis that the HNP has no stainless steel piping components exposed to soil, the staff finds acceptable the application's evaluation that this aging effect is not present.
(8)  LRA Section 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion of the BWR standby liquid control system, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.3.2.2.10 states that loss of material due to pitting and crevice corrosion may occur in stainless steel piping, piping components, and piping elements of the BWR standby liquid control system exposed to sodium pentaborate solution.
The staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.10 criteria. For those line items that apply to LRA Section 3.3.2.2.10, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
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3.3.2.2.11 Loss of Material Due to Pitting, Crevice, and Galvanic Corrosion The staff reviewed LRA Section 3.3.2.2.11 against the criteria in SRP-LR Section 3.3.2.2.11.
LRA Section 3.3.2.2.11 addresses loss of material due to pitting, crevice, and galvanic corrosion, stating that this aging effect does not apply to HNP, a PWR plant.
SRP-LR Section 3.3.2.2.11 states that loss of material due to pitting, crevice, and galvanic corrosion may occur in copper alloy piping, piping components, and piping elements exposed to treated water.
The staff finds acceptable the applicant's evaluation that this aging effect is not present at HNP, a PWR plant.
On the basis that HNP has no components from this group, the staff finds that this aging effect is not present.
3.3.2.2.12 Loss of Material Due to Pitting, Crevice, and Microbiologically-Influenced Corrosion The staff reviewed LRA Section 3.3.2.2.12 against the following criteria in SRP-LR Section 3.3.2.2.12:
(1)  LRA Section 3.3.2.2.12 addresses loss of material due to pitting and crevice corrosion and MIC in stainless steel, aluminum, and copper alloy components exposed to fuel oil, stating that such loss of material could occur in stainless steel, aluminum, and copper alloy piping, piping components, and piping elements exposed to fuel oil. The Fuel Oil Chemistry and the One-Time Inspection Programs manage piping components (except the diesel-driven fire pump fuel oil supply line) exposed to fuel oil. The Fuel Oil Chemistry Program monitors and controls fuel oil contamination to maintain fuel oil quality in accordance with plans technical specifications and American Society for Testing and Materials guidelines. Exposure to fuel oil contaminants (e.g., water and microbiological organisms) is minimized by periodic draining or cleaning of tanks and by verifying new oil quality before its introduction into the storage tanks. One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation. Aging management of the diesel-driven fire pump fuel oil line is by a combination of the Fuel Oil Chemistry Program and the Fire Protection Program.
SRP-LR Section 3.3.2.2.12 states that loss of material due to pitting and crevice corrosion and MIC may occur in stainless steel, aluminum, and copper alloy piping, piping components, and piping elements exposed to fuel oil. The existing AMP relies on the fuel oil chemistry program for monitoring and control of fuel oil contamination to manage loss of material due to corrosion; however, corrosion may occur at locations where contaminants accumulate and the effectiveness of fuel oil chemistry control should be verified to ensure that corrosion does not occur. The GALL Report 3-338
 
recommends further evaluation of programs to manage corrosion to verify the effectiveness of the fuel oil chemistry control program. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained during the period of extended operation.
The staff reviewed the Fuel Oil Chemistry Program and the One-Time Inspection Program that the applicant proposes for managing aging effects of stainless steel, aluminum, and copper alloy piping and tanks in fuel oil environments. The Fuel Oil Chemistry Program verifies fuel oil quality before introducing it into the system tanks and periodically checks for water accumulation, biological growth, and sediments. The Fuel Oil Chemistry Program requires corrective actions when fuel oil condition is out of tolerance. The One-Time Inspection Program verifies Fuel Oil Chemistry Program effectiveness. On the basis of the requirements of the Fuel Oil Chemistry Program and One-Time Inspection Program, the staff determines that they will adequately manage the aging effects through the period of extended operation.
For the diesel-driven fire pump fuel oil line, the Fuel Oil Chemistry Program verifies fuel oil quality before introducing it into the system tanks and periodically checks for water accumulation, biological growth, and sediments. The Fire Protection Program, upon enhancement, will periodically visually inspect the fuel oil supply piping for leakage. On this basis, the staff determines that the Fuel Oil Chemistry and Fire Protection Programs will manage the aging effects through the period of extended operation for the diesel-driven fire pump fuel oil line.
(2) LRA Section 3.3.2.2.12 addresses loss of material due to pitting and crevice corrosion and MIC in stainless steel piping components exposed to lubricating oil, stating that such loss of material could occur in stainless steel piping, piping components, and piping elements exposed to lubricating oil. A combination of the Lubricating Oil Analysis Program and the One-Time Inspection Program manages piping components exposed to lubricating oil. The Lubricating Oil Analysis Program maintains oil system contaminants (primarily water and particulates) within acceptable limits to preserve an environment not conducive to loss of material, cracking, or reduction of heat transfer.
One-Time Inspection Program inspections either verify that unacceptable degradation has not occurred or trigger additional actions to maintain the intended function(s) of affected components during the period of extended operation.
SRP-LR Section 3.3.2.2.12 states that loss of material due to pitting, crevice, and MIC may occur in stainless steel piping, piping components, and piping elements exposed to lubricating oil. The existing program periodically samples and analyzes lubricating oil to maintain contaminants within acceptable limits, thereby preserving an environment not conducive to corrosion; however, control of lube oil contaminants may not always be fully effective in precluding corrosion; therefore, the effectiveness of lubricating oil control should be verified to ensure that corrosion does not occur. The GALL Report recommends further evaluation of programs to manage corrosion to verify the effectiveness of lubricating oil programs. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion does not occur 3-339
 
and that component intended functions will be maintained during the period of extended operation.
The staff reviewed the Lubricating Oil Analysis Program and the One-Time Inspection Program that the applicant proposes for managing stainless steel piping, piping elements, and piping components in lubricating oil environments and determines that they will adequately manage the aging effects for the period of extended operation. The staff determined that the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program in managing loss of material for steel components exposed to lubricating oil. On the basis of its review, the staff finds that the applicant has met the criteria of SRP-LR Section 3.3.2.2.12 by verifying the effectiveness of the Lubricating Oil Analysis Program by one-time inspections.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.12 criteria. For those line items that apply to LRA Section 3.3.2.2.12, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.13 Loss of Material Due to Wear The staff reviewed LRA Section 3.3.2.2.13 against the criteria in SRP-LR Section 3.3.2.2.13.
LRA Section 3.3.2.2.13 addresses loss of material due to wear, stating that such loss of material could occur in elastomer seals and components in an indoor air environment. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages the internal surfaces of HVAC system components by internal inspections during the periodic system and component surveillances or during maintenance activities when the surfaces are made accessible to assure that environmental conditions cause no material degradation that could result in a loss of component intended functions.
LRA Section 3.3.2.2.13 addresses management of loss of material due to wear for the external surfaces of the ventilation system components by External Surfaces Monitoring Program system inspections and walkdowns. This program periodically visually inspects steel components (e.g., piping, piping components, ducting) and other components within the scope of license renewal and subject to AMR in order to manage aging effects through visual inspection of external surfaces for material loss.
SRP-LR Section 3.3.2.2.13 states that loss of material due to wear may occur in the elastomer seals and components exposed to air - indoor uncontrolled (internal or external). The GALL Report recommends further evaluation to ensure that the aging effect is adequately managed.
The staff reviewed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components and External Surfaces Monitoring Programs, which together inspect internal and external surfaces of HVAC components during periodic system walkdowns and inspections 3-340
 
when the surfaces are accessible. On the basis of periodic inspections, including opportunistic inspections of component internal surfaces, the staff determines that the Internal Surfaces in Miscellaneous Piping and Ducting Components and the External Surfaces Monitoring Programs will adequately manage the aging effects through the period of extended operation.
Based on the programs identified above, the staff concludes that the applicants programs meet SRP-LR Section 3.3.2.2.13 criteria. For those line items that apply to LRA Section 3.3.2.2.13, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.2.14 Loss of Material Due to Cladding Breach The staff reviewed LRA Section 3.3.2.2.14 against the criteria in SRP-LR Section 3.3.2.2.14.
LRA Section 3.3.2.2.14 addresses loss of material due to cladding breach, stating that this aging effect is not present because the charging pumps are fabricated from stainless steel and not from carbon steel with stainless steel cladding.
SRP-LR Section 3.3.2.2.14 states that loss of material due to cladding breach may occur in PWR steel charging pump casings with stainless steel cladding exposed to treated borated water.
On the basis that HNP has no steel charging pump casings with stainless steel cladding exposed to treated borated water, the staff finds acceptable the application's evaluation that this aging effect is not present.
On the basis that HNP has no components from this group, the staff finds that this aging effect is not present.
3.3.2.2.15 Quality Assurance for Aging Management of Nonsafety-Related Components SER Section 3.0.4 documents the staffs evaluation of the applicants QA program.
3.3.2.3 AMR Results Not Consistent with or Not Addressed in the GALL Report In LRA Tables 3.3.2-1 through 3.3.2-71, the staff reviewed additional details of the AMR results for material, environment, AERM, and AMP combinations not consistent with or not addressed in the GALL Report.
In LRA Tables 3.3.2-1 through 3.3.2-71, the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report. The applicant provided further information about how it will manage the aging effects. Specifically, Note F indicates that the material for the AMR line item 3-341
 
component is not evaluated in the GALL Report. Note G indicates that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicates that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicates that the aging effect identified in the GALL Report for the line item component, material, and environment combination is not applicable.
Note J indicates that neither the component nor the material and environment combination for the line item is evaluated in the GALL Report.
For component type, material, and environment combinations not evaluated in the GALL Report, the staff reviewed the applicants evaluation to determine whether the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. The staffs evaluation is documented in the following sections.
3.3.2.3.1 Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and Volume Control System - LRA Table 3.3.2-1 The staff reviewed LRA Table 3.3.2-1, which summarizes the results of AMR evaluations for the chemical and volume control system component groups.
In LRA Table 3.3.2-1, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to environments of air-indoor.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload of stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
In LRA Table 3.3.2-1, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for gray cast-iron CSIP lube oil pumps and gray cast-iron or copper alloy greater than 15-percent zinc CSIP lube oil piping components exposed to internal environments of lubricating oil or hydraulic fluid.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended function for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching," with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of gray cast-iron CSIP lube oil pumps and gray cast-iron or copper alloy greater than 15 percent zinc 3-342
 
CSIP lube oil piping components exposed to internal environments of lubricating oil or hydraulic fluid will be effectively managed by the Selective Leaching of Materials Program.
In LRA Table 3.3.2-1, the applicant proposed a TLAA to manage cracking due to thermal fatigue for carbon or low-alloy steel piping, piping components, and piping elements exposed to internal environments of treated water.
The staff evaluation of the TLAA is documented in SER Section 4.3.
In LRA Table 3.3.2-1, the applicant proposed the Lubricating Oil Analysis and One-Time Inspection Programs to manage SCC for stainless steel CSIP gear oil cooler, CSIP oil cooler, and CSIP lube oil piping component types exposed to internal lubricating oil or hydraulic fluid environments.
The staff's evaluations of the Lubricating Oil Analysis and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The Lubricating Oil Analysis Program description states that the program maintains oil system contaminates (primarily water and particulates) within acceptable limits by sampling to preserve an environment not conducive to cracking. The One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program. On the basis of its review, the staff finds that the aging effect of SCC for stainless steel CSIP gear oil cooler, CSIP oil cooler, and CSIP lube oil piping component types exposed to internal lubricating oil or hydraulic fluid environments will be effectively managed by the Lubricating Oil Analysis and One-Time Inspection Programs.
In LRA Table 3.3.2-1, the applicant proposed the Lubricating Oil Analysis and One-Time Inspection Programs to manage loss of material due to galvanic corrosion for carbon or low-alloy steel CSIP gear lube oil pumps exposed to internal environments of lubricating oil or hydraulic fluid.
The staff's evaluations of the Lubricating Oil Analysis and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The Lubricating Oil Analysis Program description states that the program maintains the oil system contaminates (primarily water and particulates) within acceptable limits by sampling to preserve an environment not conducive to loss of material. During the onsite audit, the staff asked the applicant to clarify the use of this program to manage loss of material due to galvanic corrosion.
In its response dated August 20, 2007, the applicant stated that lubricating oil produces no potential aging effects due to galvanic corrosion without water contamination and pooling in contact with dissimilar metals. On the basis that the Lubricating Oil Analysis Program maintains the water contamination within acceptable limits, the staff finds this response acceptable. In addition, the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program. On the basis of its review, the staff finds that the aging effect of loss of material due to galvanic corrosion of carbon or low-alloy steel CSIP gear lube oil pumps exposed to internal environments of lubricating oil or hydraulic fluid will be effectively managed by the Lubricating Oil Analysis and One-Time Inspection Programs.
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In LRA Table 3.3.2-1, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer tank diaphragm component types exposed to internal environments of treated water or environments of air-indoor. The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. During the onsite audit, the staff asked the applicant to clarify how a visual inspection would detect the change in material properties for elastomer component types.
In its response dated August 20, 2007, the applicant stated that it would amend the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to include in addition to visual inspections physical manipulation of the elastomer components to detect aging degradation. Physical manipulation of the elastomer component types adds a mechanism to detect change in material properties due to aging degradation. In the same August 20, 2007 letter, the applicant amended the LRA Section B.2.24 program description to add elastomeric component physical manipulations to detect aging effects.
The staff finds this response acceptable. On the basis of its review, the staff finds that the aging effect of change in material properties and cracking due to various degradation mechanisms for elastomer tank diaphragm component types exposed to internal environments of treated water or environments of air-indoor will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
LRA Table 3.3.2-1 states that piping thermal insulation exposed to air-indoor environments exhibits no AERMs. During the audit and review, the staff confirmed that the materials in HNP thermal insulation include elastomeric closed-cell foam, phenolic foam, calcium silicate, sodium silicate, mineral wool, glass wool, refractory fiber, rigid fibrous glass, insulation board, and fiberglass, that these insulation types similar to those elsewhere in the industry have exhibited no age-related degradation, and that plant-specific operating experience shows no aging effects for these materials. The staff finds this LRA statement acceptable because there is no indication in industry operating experience that thermal insulation material exposed to air-indoor environments has any AERMs for its intended function.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.2 Auxiliary Systems - Summary of Aging Management Evaluation - Boron Thermal Regeneration System - LRA Table 3.3.2-2 The staff reviewed LRA Table 3.3.2-2, which summarizes the results of AMR evaluations for the boron thermal regeneration system component groups.
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In LRA Table 3.3.2-2, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to external air-indoor environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload of stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
In LRA Table 3.3.2-2, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to internal environments of lubricating oil or hydraulic fluid.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching," with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to internal environments of lubricating oil or hydraulic fluid will be effectively managed by the Selective Leaching of Materials Program.
In LRA Table 3.3.2-2, the applicant proposed the Lubricating Oil Analysis and One-Time Inspection Programs to manage loss of material due to galvanic corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to internal environments of lubricating oil or hydraulic fluid.
The staff's evaluations of the Lubricating Oil Analysis and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The Lubricating Oil Analysis Program description states that the program maintains oil system contaminates (primarily water and particulates) within acceptable limits by sampling to preserve an environment not conducive to loss of material. During the onsite audit, the staff asked the applicant to clarify the use of this program to manage loss of material due to galvanic corrosion.
In its letter dated August 20, 2007, the applicant stated that lubricating oil produces no potential aging effects due to galvanic corrosion without water contamination and pooling in contact with dissimilar metals. On the basis that the Lubricating Oil Analysis Program maintains the water contamination within acceptable limits, the staff finds this statement acceptable. In addition, the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program. On the basis of its review, the staff finds that the aging effect of loss of material due 3-345
 
to galvanic corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to internal environments of lubricating oil or hydraulic fluid will be effectively managed by the Lubricating Oil Analysis and One-Time Inspection Programs.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.3 Auxiliary Systems - Summary of Aging Management Evaluation - Primary Makeup System - LRA Table 3.3.2-3 The staff reviewed LRA Table 3.3.2-3, which summarizes the results of AMR evaluations for the primary makeup system component groups.
In LRA Table 3.3.2-3, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments or air-outdoor and carbon or low-alloy steel closure bolting exposed to environments of air-outdoor.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload of stainless steel closure bolting exposed to air-indoor environments or air-outdoor and carbon or low-alloy steel closure bolting exposed to environments of air-outdoor will be effectively managed by the Bolting Integrity Program.
In LRA Table 3.3.2-3, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer tank diaphragm component types exposed to internal environments of treated water or environments of air-indoor.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of degradation. During the onsite audit, the staff asked the applicant to clarify how a visual inspection would detect change in material properties for elastomer component types.
In its letter dated August 20, 2007, the applicant stated that it would amend the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to include physical 3-346
 
manipulation of the elastomer components to detect aging degradation in addition to visual inspections. Physical manipulation of the elastomer component types adds a mechanism to detect change in material properties due to aging degradation. In the same August 20, 2007, letter, the applicant amended the LRA Section B.2.24 program description to add elastomeric component physical manipulations to detect aging effects. The staff finds this response acceptable. On the basis of its review, the staff finds that the aging effect of change in material properties and cracking due to various degradation mechanisms for elastomer tank diaphragm component types exposed to internal environments of treated water or an external environment of air-indoor will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
LRA Table 3.3.2-3 states that stainless steel piping, piping components, and piping elements exposed to environments of air-outdoor and stainless steel reactor makeup water storage tank component types exposed to internal or environments of air-outdoor exhibit no AERMs. The staff finds this statement acceptable because there is no indication in industry operating experience that stainless steel exposed to air-outdoor environments has any AERMs.
Furthermore, the GALL Report does not indicate any AERMs for stainless steel exposed to external uncontrolled air-indoor environments.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.4 Auxiliary Systems - Summary of Aging Management Evaluation - Primary Sampling System - LRA Table 3.3.2-4 The staff reviewed LRA Table 3.3.2-4, which summarizes the results of AMR evaluations for the primary sampling system component groups.
In LRA Table 3.3.2-4, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes that bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload of stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
In LRA Table 3.3.2-4, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to crevice and pitting corrosion for stainless steel piping, piping components, and piping elements 3-347
 
exposed to internal environments of air/gas (wetted).
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice and pitting corrosion for stainless steel piping, piping components, and piping elements exposed to internal environments of air/gas (wetted) will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-4, the applicant proposed the Water Chemistry Program to manage reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for stainless steel primary sampling cooler components exposed to internal treated water environments.
The staff's evaluation of the Water Chemistry Program is documented in SER Section 3.0.3.1.1.
During the onsite audit, the staff asked the applicant to clarify how it verifies the effectiveness of the Water Chemistry Program for this AMR. In its letter dated August 20, 2007, the applicant stated that the heat transfer intended function is preserved by the Closed-Cycle Cooling Water System Program on the external surfaces of the primary sampling cooler tubes. The staff finds this statement acceptable because the effectiveness of the Water Chemistry Program will be verified by the Closed-Cycle Cooling Water System Program and affirmed by the continual operation of the sampling system. If the heat transfer function became degraded due to aging effects, the plant staff would detect it during the sampling process. On the basis of its review, the staff finds that the aging effect of reduction of heat transfer effectiveness due to fouling of stainless steel primary sampling cooler component heat transfer surfaces exposed to internal treated water environments will be effectively managed by the Water Chemistry Program.
In LRA Table 3.3.2-4, the applicant proposed the Water Chemistry Program to manage SCC for stainless steel primary sampling cooler components exposed to internal treated water environments.
The staff's evaluation of the Water Chemistry Program is documented in SER Section 3.0.3.1.1.
The Water Chemistry Program description states that the program controls water chemistry for impurities (e.g., oxygen, chlorides, fluorides, and sulfates) that accelerate corrosion and cracking. On the basis of its review, the staff finds that the aging effect of SCC for stainless steel primary sampling cooler components exposed to internal treated water environments will be effectively managed by the Water Chemistry Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
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3.3.2.3.5 Auxiliary Systems - Summary of Aging Management Evaluation - Post-Accident Sampling System - LRA Table 3.3.2-5 The staff reviewed LRA Table 3.3.2-5, which summarizes the results of AMR evaluations for the post-accident sampling system component groups.
In LRA Table 3.3.2-5, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload of stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
In LRA Table 3.3.2-5, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to crevice and pitting corrosion for stainless steel containment isolation piping and components and piping, piping components, and piping element component types exposed to internal air/gas (wetted) environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice and pitting corrosion for stainless steel containment isolation piping and components and piping, piping components, and piping element component types exposed to internal air/gas (wetted) environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
LRA Table 3.3.2-5 states that piping thermal insulation exposed to air-indoor environments exhibits no AERMs. During the audit and review, the staff confirmed that the materials in thermal insulation include elastomeric closed cell foam, phenolic foam, calcium silicate, sodium silicate, mineral wool, glass wool, refractory fiber, rigid fibrous glass, insulation board, and fiberglass, that these insulation types similar to those elsewhere in the industry have exhibited no age-related degradation, and that plant-specific operating experience shows no aging effects for these materials. The staff finds this LRA statement acceptable because there is no indication in industry operating experience that thermal insulation material exposed to air-indoor environments has any AERMs for its intended function.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR 3-349
 
results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.6 Auxiliary Systems - Summary of Aging Management Evaluation - Circulating Water System - LRA Table 3.3.2-6 The staff reviewed LRA Table 3.3.2-6, which summarizes the results of AMR evaluations for the circulating water system component groups.
In LRA Table 3.3.2-6, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal raw water environments or air-indoor environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of its review, the staff finds that the aging effect of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal raw water environments or air-indoor environments will be effectively managed by the External Surfaces Monitoring Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.7 Auxiliary Systems - Summary of Aging Management Evaluation - Cooling Tower System - LRA Table 3.3.2-7 The staff reviewed LRA Table 3.3.2-7, which summarizes the results of AMR evaluations for the cooling tower system component groups.
LRA Table 3.3.2-7 states that fiber glass or fiber reinforced plastic buried piping, piping components, and piping elements exposed to raw water internal environments or soil environments exhibit no AERMs. The staff finds this statement acceptable because there is no indication in industry operating experience that fiber glass or fiber reinforced plastic exposed to raw water internal environments or soil environments have any AERMs. These materials are generally for component types exposed to untreated water or soil environments.
In LRA Table 3.3.2-7, the applicant proposed the Bolting Integrity Program to manage loss of 3-350
 
material due to crevice, pitting, general, and microbiologically influenced corrosion and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
LRA Table 3.3.2-7 states that polyvinyl chloride (PVC) or thermoplastic piping, piping components, piping element, and spray nozzle component types exposed to both raw water internal and external environments exhibit no AERMs. The staff finds this LRA statement acceptable because there is no indication in industry operating experience that PVC or thermoplastics exposed to raw water internal or external environments have any AERMs. These materials are generally for component types exposed to untreated water environments.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.8 Auxiliary Systems - Summary of Aging Management Evaluation - Cooling Tower Make-up System - LRA Table 3.3.2-8 The staff reviewed LRA Table 3.3.2-8, which summarizes the results of AMR evaluations for the cooling tower make-up system component groups. The staff determined that all AMR evaluation results in LRA Table 3.3.2-8 are consistent with the GALL Report.
3.3.2.3.9 Auxiliary Systems - Summary of Aging Management Evaluation - Screen Wash System - LRA Table 3.3.2-9 The staff reviewed LRA Table 3.3.2-9, which summarizes the results of AMR evaluations for the screen wash system component groups.
In LRA Table 3.3.2-9, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to erosion for carbon or low-alloy steel fire service screen wash pumps and flow blockage due to general corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to raw water internal environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting 3-351
 
Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to erosion for carbon or low-alloy steel fire service screen wash pumps and flow blockage due to general corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to raw water internal environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-9, the applicant proposed the Bolting Integrity Program to manage loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.10 Auxiliary Systems - Summary of Aging Management Evaluation - Normal Service Water System - LRA Table 3.3.2-10 The staff reviewed LRA Table 3.3.2-10, which summarizes the results of AMR evaluations for the normal service water system component groups.
In LRA Table 3.3.2-10, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to erosion of carbon or low-alloy steel normal service water pumps and normal service water seal and bearing water booster pumps exposed to raw water internal environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff 3-352
 
finds that the aging effect of loss of material due to erosion of carbon or low-alloy steel normal service water pumps and normal service water seal and bearing water booster pumps exposed to raw water internal environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-10, the applicant proposed the Bolting Integrity Program to manage loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
LRA Table 3.3.2-10 states that stainless steel piping, piping components, and piping elements and system strainer component types exposed to air-indoor environments exhibit no AERMs.
The staff finds this LRA statement acceptable because stainless steel is highly resistant to corrosion in dry atmospheres in the absence of corrosive species (which would be reflective of indoor-air), as documented in the Metals Handbook, Volume 3 (page 65) and Volume 13 (page 555) (Ninth Edition, American Society for Metals International, 1980 and 1987). Components are not subject to moisture in dry air environments; therefore, stainless steel in indoor-air environments exhibits no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.11 Auxiliary Systems - Summary of Aging Management Evaluation - Emergency Service Water System - LRA Table 3.3.2-11 The staff reviewed LRA Table 3.3.2-11, which summarizes the results of AMR evaluations for the emergency service water system component groups.
LRA Table 3.3.2-11 states that elastomer piping, piping components, and piping elements exposed to air/gas (dry) internal or air-indoor environments exhibit no AERMs. These materials, unlike metals, do not display corrosion rates but rely on chemical resistance to environments to which they are exposed; therefore, based on industry operating experience and the assumption of proper design and application of the material, the staff finds that elastomer piping, piping 3-353
 
components, and piping elements exposed to air/gas (dry) internal or air-indoor environments exhibit no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-11, the applicant proposed the Open-Cycle Cooling Water System Program to manage loss of material due to erosion of carbon or low-alloy steel emergency service water pumps and flow blockages due to general corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to raw water internal environments.
The staff's evaluation of the Open-Cycle Cooling Water System Program is documented in SER Section 3.0.3.1.4. The Open-Cycle Cooling Water System Program description includes surveillances and control techniques to manage aging effects caused by biofouling, corrosion, erosion, and silting in open-cycle cooling water systems or structures and components serviced by such systems. On the basis of its review, the staff finds that the aging effect of loss of material due to erosion of carbon or low-alloy steel emergency service water pumps and flow blockages due to general corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to raw water internal environments will be effectively managed by the Open-Cycle Cooling Water System Program.
In LRA Table 3.3.2-11, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to external air-indoor environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of its review, the staff finds that the aging effects of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to external air-indoor environments will be effectively managed by the External Surfaces Monitoring Program.
In LRA Table 3.3.2-11, the applicant proposed the "Bolting Integrity Program to manage loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting, general, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
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In LRA Table 3.3.2-11, the applicant proposed the Bolting Integrity Program to manage loss of material due to crevice, pitting, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting, and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
LRA Table 3.3.2-11 states that stainless steel closure bolting and piping, piping components, and piping element component types exposed to air-outdoor environments exhibit no AERMs.
The staff finds this LRA statement acceptable because the GALL Report indicates that there are no aging effects for stainless steel exposed to uncontrolled indoor air. Furthermore, there is no likelihood of age-related degradation for stainless steel in an air-outdoor environment without an aggressive factor like salt air or an industrial location. Stainless steel is highly resistant to corrosion in dry atmospheres in the absence of corrosive species (which would be reflective of uncontrolled indoor air), as documented in the Metals Handbook, Volume 3 (page 65) and Volume 13 (page 555) (Ninth Edition, American Society for Metals International, 1980 and 1987). During the onsite audit, the staff confirmed that HNP is not located near the sea nor in an industrial location; therefore, stainless steel closure bolting and piping, piping components, and piping elements in air-outdoor environments exhibit no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
LRA Table 3.3.2-11 states that piping thermal insulation component types exposed to air-indoor environments exhibits no AERMs. During the audit and review, the staff confirmed that the materials in HNP thermal insulation include elastomeric closed cell foam, phenolic foam, calcium silicate, sodium silicate, mineral wool, glass wool, refractory fiber, rigid fibrous glass, insulation board, and fiberglass, that these insulation types similar to those elsewhere in the industry have demonstrated no age-related degradation, and that plant-specific operating experience shows no aging effects for these materials. The staff finds this LRA statement acceptable because there is no indication in industry operating experience that thermal insulation material exposed to air-indoor environments has any AERMs for its intended function.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.12 Auxiliary Systems - Summary of Aging Management Evaluation - Component Cooling Water System - LRA Table 3.3.2-12 3-355
 
The staff reviewed LRA Table 3.3.2-12, which summarizes the results of AMR evaluations for the component cooling water system component groups.
In LRA Table 3.3.2-12, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
LRA Table 3.3.2-12 states that piping thermal insulation component types exposed to air-indoor environments exhibits no AERMs. During the audit and review, the staff confirmed that the materials HNP thermal insulation include elastomeric closed cell foam, phenolic foam, calcium silicate, sodium silicate, mineral wool, glass wool, refractory fiber, rigid fibrous glass, insulation board, and fiberglass, that these insulation types similar to those elsewhere in the industry have exhibited no age-related degradation, and that plant-specific operating experience shows no aging effects for these materials. The staff finds this LRA statement acceptable because there is no indication in industry operating experience that thermal insulation material exposed to air-indoor environments has any AERMs for its intended function.
LRA Table 3.3.2-12 states that carbon or low-alloy steel component cooling water surge tank component types exposed to external air-indoor environments exhibit no AERMs. The staff finds this statement acceptable because the GALL Report indicates no AERMs for this material exposed to controlled air-indoor environments; therefore, carbon or low-alloy steel component cooling water surge tank component types exposed to external air-indoor environments exhibit no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.13 Auxiliary Systems - Summary of Aging Management Evaluation - Waste Processing Building Cooling Water System - LRA Table 3.3.2-13 The staff reviewed LRA Table 3.3.2-13, which summarizes the results of AMR evaluations for the waste processing building cooling water system component groups. The staff determined that all AMR evaluation results in LRA Table 3.3.2-13 are consistent with the GALL Report.
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3.3.2.3.14 Auxiliary Systems - Summary of Aging Management Evaluation - Essential Services Chilled Water System - LRA Table 3.3.2-14 The staff reviewed LRA Table 3.3.2-14, which summarizes the results of AMR evaluations for the essential services chilled water system component groups.
In LRA Table 3.3.2-14, the applicant proposed the Lubricating Oil Analysis and One-Time Inspection Programs to manage loss of material due to galvanic corrosion for carbon or low-alloy steel essential chilled water compressor oil cooler components exposed to internal or external environments of lubricating oil or hydraulic fluid.
The staff's evaluations of the Lubricating Oil Analysis and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The Lubricating Oil Analysis Program description states that the program maintains the oil system contaminates (primarily water and particulates) within acceptable limits by sampling to preserve an environment not conducive to loss of material. During the onsite audit, the staff asked the applicant to clarify the use of this program to manage loss of material due to galvanic corrosion.
In its letter dated August 20, 2007, the applicant stated that lubricating oil does not produce any potential aging effects due to galvanic corrosion without water contamination and pooling in contact with dissimilar metals. On the basis that the Lubricating Oil Analysis Program monitors oil quality for moisture in its samples to preserve an environment not conducive to galvanic corrosion, the staff finds this statement acceptable. In addition, the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program. On the basis of its review, the staff finds that the aging effect of loss of material due to galvanic corrosion for carbon or low-alloy steel essential chilled water compressor oil cooler components exposed to internal or external environments of lubricating oil or hydraulic fluid will be effectively managed by the Lubricating Oil Analysis and One-Time Inspection Programs.
In LRA Table 3.3.2-14, the applicant proposed the Open-Cycle Cooling Water System Program to manage loss of material due to MIC for stainless steel flow-restricting elements exposed to internal environments of treated water (for both pressure boundary and throttling intended functions).
The staff's evaluation of the Open-Cycle Cooling Water System Program is documented in SER Section 3.0.3.1.4. The Open-Cycle Cooling Water System Program description includes surveillances and control techniques to manage aging effects caused by biofouling, corrosion, erosion, and silting in open-cycle cooling water systems or structures and components serviced by such systems. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for stainless steel flow-restricting elements exposed to internal environments of treated water (for both pressure boundary and throttling intended functions) will be effectively managed by the Open-Cycle Cooling Water System Program.
In LRA Table 3.3.2-14, the applicant proposed the Open-Cycle Cooling Water System Program to manage flow blockage due to general corrosion for carbon or low-alloy steel piping, piping components, piping elements, and tanks and flow-restricting element component types exposed 3-357
 
to raw water internal environments.
The staff's evaluation of the Open-Cycle Cooling Water System Program is documented in SER Section 3.0.3.1.4. The Open-Cycle Cooling Water System Program description includes surveillances and control techniques to manage aging effects caused by biofouling, corrosion, erosion, and silting in open-cycle cooling water systems or structures and components serviced by such systems. On the basis of its review, the staff finds that the aging effect of flow blockage due to general corrosion for carbon or low-alloy steel piping, piping components, piping elements, and tanks and flow-restricting element component types exposed to raw water internal environments will be effectively managed by the Open-Cycle Cooling Water System Program.
In LRA Table 3.3.2-14, the applicant proposed the Closed-Cycle Cooling Water System Program to manage loss of material due to MIC for carbon, low-alloy, or stainless steel piping, piping components, piping elements, and tanks exposed to treated water internal environments.
The staff's evaluation of the Closed-Cycle Cooling Water System Program is documented in SER Section 3.0.3.2.7. The Closed-Cycle Cooling Water System Program description states that it is an effective chemistry program augmented by component testing and inspection based on "Closed Cooling Water Chemistry Guideline: Revision 1 to TR-107396, Closed Cooling Water Chemistry Guideline," EPRI, Palo Alto, CA: 2004, to maintain license renewal intended functions. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for carbon, low-alloy, or stainless steel piping, piping components, piping elements, and tanks exposed to treated water internal environments will be effectively managed by the Closed-Cycle Cooling Water System Program.
In LRA Table 3.3.2-14, the applicant proposed the Closed-Cycle Cooling Water System Program to manage loss of material due to MIC for carbon or low-alloy steel tanks exposed to treated water internal environments.
The staff's evaluation of the Closed-Cycle Cooling Water System Program is documented in SER Section 3.0.3.2.7. The Closed-Cycle Cooling Water System Program description states that is an effective chemistry program augmented by component testing and inspection based on "Closed Cooling Water Chemistry Guideline: Revision 1 to TR-107396, Closed Cooling Water Chemistry Guideline," EPRI, Palo Alto, CA: 2004, to maintain license renewal intended functions. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for stainless steel tanks exposed to treated water internal environments will be effectively managed by the Closed-Cycle Cooling Water System Program.
In LRA Table 3.3.2-14, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to MIC for carbon or low-alloy steel tanks exposed to air/gas (wetted) internal environments and flow blockages due to fouling for stainless steel system strainer screens/elements exposed to treated water external environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting 3-358
 
Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for carbon or low-alloy steel tanks exposed to air/gas (wetted) internal environments and flow blockages due to fouling for stainless steel system strainer screens/elements exposed to treated water environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-14, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc piping, piping components, piping elements, and tanks exposed to internal environments of lubricating oil or hydraulic fluid.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching," with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc piping, piping components, piping elements, and tanks exposed to internal environments of lubricating oil or hydraulic fluid will be effectively managed by the Selective Leaching of Materials Program.
In LRA Table 3.3.2-14, the applicant proposed the External Surfaces Monitoring Program to manage loss of material due to crevice and pitting corrosion for stainless steel piping, piping components, piping elements, and tanks exposed to air-indoor environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice corrosion for stainless steel piping, piping components, piping elements, and tanks exposed to air-indoor environments will be effectively managed by the External Surfaces Monitoring Program.
LRA Table 3.3.2-14 states that stainless steel piping, piping components, and piping elements and tanks exposed to air/gas (wetted) internal environments exhibit no AERMs. The plant-specific note for this line item indicates that this environment consists of potentially moist service air connected to the top of the essential services chiller water system surge tank with no direct connection to the chilled water and no source of contaminants like chlorides or sulfides.
The staff finds this LRA statement acceptable because stainless steel is highly resistant to 3-359
 
corrosion in dry atmospheres in the absence of corrosive species, as documented in the Metals Handbook, Volume 3 (page 65) and Volume 13 (page 555) (Ninth Edition, American Society for Metals International, 1980 and 1987); therefore, stainless steel in air/gas (wetted) internal environments exhibits no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
LRA Table 3.3.2-14 states that glass essential chilled water system chiller cooler components exposed to air/gas (dry) internal environments exhibit no AERMs. The staff finds this statement acceptable because the GALL Report lists no aging effects for glass exposed to a range of fluid environments; therefore, glass essential chilled water system chiller cooler components exposed to air/gas (dry) internal environments exhibit no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.15 Auxiliary Systems - Summary of Aging Management Evaluation - Non-Essential Serviced Chilled Water System - LRA Table 3.3.2-15 The staff reviewed LRA Table 3.3.2-15, which summarizes the results of AMR evaluations for the non-essential serviced chilled water system component groups.
In LRA Table 3.3.2-15, the applicant proposed the Closed-Cycle Cooling Water System Program to manage loss of material due to MIC for carbon, low-alloy, or stainless steel piping, piping components, and piping elements exposed to treated water internal environments.
The staff's evaluation of the Closed-Cycle Cooling Water System Program is documented in SER Section 3.0.3.2.7. The Closed-Cycle Cooling Water System Program description states that it is an effective chemistry program augmented by component testing and inspection based on "Closed Cooling Water Chemistry Guideline: Revision 1 to TR-107396, Closed Cooling Water Chemistry Guideline," EPRI, Palo Alto, CA: 2004, to maintain license renewal intended functions. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for carbon, low-alloy, or stainless steel piping, piping components, and piping elements exposed to treated water internal environments will be effectively managed by the Closed-Cycle Cooling Water System Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
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3.3.2.3.16 Auxiliary Systems - Summary of Aging Management Evaluation - Emergency Screen Wash System - LRA Table 3.3.2-16 The staff reviewed LRA Table 3.3.2-16, which summarizes the results of AMR evaluations for the emergency screen wash system component groups.
In LRA Table 3.3.2-16, the applicant proposed the Open-Cycle Cooling Water System Program to manage flow blockage due to general corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to raw water internal environments.
The staff's evaluation of the Open-Cycle Cooling Water System Program is documented in SER Section 3.0.3.1.4. The Open-Cycle Cooling Water System Program description includes surveillances and control techniques to manage aging effects caused by biofouling, corrosion, erosion and silting in open-cycle cooling water systems or structures and components serviced by such systems. In addition, the plant-specific note for this line item states that flushing or replacement of these piping sections is included in the Open-Cycle Cooling Water System Program. On the basis of its review, the staff finds that the aging effect of flow blockage due to general corrosion for carbon or low-alloy steel piping, piping components, and piping elements exposed to raw water internal environments will be effectively managed by the Open-Cycle Cooling Water System Program.
In LRA Table 3.3.2-16, the applicant proposed the Bolting Integrity Program to manage loss of material due to crevice, pitting, and general corrosion and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting, and general corrosion and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for carbon or low-alloy steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
In LRA Table 3.3.2-16, the applicant proposed the "Bolting Integrity Program to manage loss of material due to crevice and pitting corrosion and MIC and loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to raw water environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity," with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of material due to crevice, pitting corrosion, and MIC and loss of preload due to thermal effects, gasket 3-361
 
creep, and self-loosening for stainless steel closure bolting exposed to raw water environments will be effectively managed by the Bolting Integrity Program.
LRA Table 3.3.2-16 states that piping thermal insulation component types exposed to air-indoor environments exhibit no AERMs. During the audit and review, the staff confirmed that the materials in HNP thermal insulation include elastomeric closed cell foam, phenolic foam, calcium silicate, sodium silicate, mineral wool, glass wool, refractory fiber, rigid fibrous glass, insulation board, and fiberglass, that these insulation types similar to those elsewhere in the industry have exhibited no age-related degradation, and that plant-specific operating experience shows no aging effects for these materials. The staff finds this LRA statement acceptable because there is no indication in industry operating experience that thermal insulation material exposed to air-indoor environments has any AERMs for its intended function.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.17 Auxiliary Systems - Summary of Aging Management Evaluation - Emergency Diesel Generator System - LRA Table 3.3.2-17 The staff reviewed LRA Table 3.3.2-17, which summarizes the results of AMR evaluations for the emergency diesel generator system component groups.
LRA Table 3.3.2-17 states that copper alloy greater than 15 percent zinc diesel engine turbocharger intercooler components exposed to air/gas (wetted) external environments exhibit no AERMs. The staff finds this statement acceptable because the GALL Report indicates no AERMs for copper alloy greater than 15 percent zinc component types exposed to air with borated water leakage, a harsher environment; therefore, copper alloy greater than 15 percent zinc diesel engine turbocharger intercooler components exposed to air/gas (wetted) environments exhibit no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-17, the applicant proposed a TLAA to manage cracking due to thermal fatigue for carbon, low-alloy, or stainless steel diesel combustion air intake piping, piping components, and piping elements exposed to air/gas (wetted) internal environments.
The staff evaluation of the TLAA is documented in SER Section 4.3.
In LRA Table 3.3.2-17, the applicant proposed a TLAA to manage cracking due to thermal fatigue for carbon or low alloy or stainless steel piping, piping components, and piping elements exposed to diesel exhaust internal environment.
The staff evaluation of the TLAA is documented in SER Section 4.3.
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In LRA Table 3.3.2-17, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to pitting and crevice corrosion for stainless steel diesel combustion air intake piping, piping components, and piping elements exposed to air/gas (wetted) internal environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to pitting and crevice corrosion for stainless steel diesel combustion air intake piping, piping components, and piping elements exposed to air/gas (wetted) internal environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-17, the applicant proposed the "Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc diesel engine governor oil cooler components exposed to internal environments of lubricating oil or hydraulic fluid.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching," with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc diesel engine governor oil cooler components exposed to internal environments of lubricating oil or hydraulic fluid will be effectively managed by the Selective Leaching of Materials Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.18 Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator Fuel Oil Storage and Transfer System - LRA Table 3.3.2-18 The staff reviewed LRA Table 3.3.2-18, which summarizes the results of AMR evaluations for the diesel generator fuel oil storage and transfer system component groups.
LRA Table 3.3.2-18 states that stainless steel fuel oil tank flame arresters exposed to air/gas (wetted) internal environments exhibit no AERMs. The staff finds this statement acceptable 3-363
 
because stainless steel is highly resistant to corrosion in dry atmospheres in the absence of corrosive species, as documented in the Metals Handbook, Volume 3 (page 65) and Volume 13 (page 555) (Ninth Edition, American Society for Metals International, 1980 and 1987); therefore, stainless steel in this air/gas (wetted) internal environment exhibits no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-18, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage the reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for stainless steel fuel oil tank flame arrester elements exposed to air/gas (wetted) environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to pitting and crevice corrosion for stainless steel fuel oil tank flame arrester elements exposed to air/gas (wetted) external environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.19 Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator Lubrication System - LRA Table 3.3.2-19 The staff reviewed LRA Table 3.3.2-19, which summarizes the results of AMR evaluations for the diesel generator lubrication system component groups.
LRA Table 3.3.2-19 states that copper alloy greater than 15 percent zinc lube oil cooler components exposed to treated water internal environments exhibit no AERMs. The staff finds this statement acceptable because the GALL Report indicates no AERMs for copper alloy greater than 15 percent zinc component types exposed to air with borated water leakage, a harsher environment than treated water; therefore, copper alloy greater than 15 percent zinc lube oil cooler components exposed to treated water internal environments exhibit no aging effect, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-19, the applicant proposed the Lubricating Oil Analysis and One-Time Inspection Programs to manage SCC for stainless steel flow restricting elements and piping, piping components, and piping elements and stainless steel system strainer screens/elements 3-364
 
exposed to environments of lubricating oil or hydraulic fluid.
The staff's evaluations of the Lubricating Oil Analysis and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The Lubricating Oil Analysis Program description states that the program maintains the oil system contaminates (primarily water and particulates) within acceptable limits by sampling to preserve an environment not conducive to SCC. On the basis that the Lubricating Oil Analysis Program maintains water contamination within acceptable limits, the staff finds the applicants proposal acceptable. In addition, the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program. On the basis of its review, the staff finds that the aging effect of SCC for stainless steel flow restricting elements and piping, piping components, and piping elements exposed to internal environments of lubricating oil or hydraulic fluid and stainless steel system strainer screens/elements exposed to environments of lubricating oil or hydraulic fluid will be effectively managed by the Lubricating Oil Analysis and One-Time Inspection Programs.
LRA Table 3.3.2-19 states that carbon or low-alloy steel piping, piping components, and piping elements exposed to lubricating oil or hydraulic fluid internal environments exhibit no AERMs.
During the onsite audit, the staff asked the applicant for the specific component or components addressed in this line item.
In its letter dated August 20, 2007, the applicant stated that this line represents an immersion heater configured in the tank not to come in contact with water in the event of contamination or pooling. The staff finds this statement acceptable because without the presence of water this component type would exhibit no AERMs; therefore, carbon or low-alloy steel piping, piping components, and piping elements exposed to lubricating oil or hydraulic fluid internal environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.20 Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator Cooling Water System - LRA Table 3.3.2-20 The staff reviewed LRA Table 3.3.2-20, which summarizes the results of AMR evaluations for the diesel generator cooling water system component groups.
LRA Table 3.3.2-20 states that copper alloy greater than 15 percent zinc jacket water cooler components exposed to treated water external environments exhibit no AERMs. The staff finds this statement acceptable because the GALL Report indicates no AERMs for copper alloy greater than 15 percent zinc component types exposed to air with borated water leakage, an environment more aggressive than the treated water external environment in this line item; therefore, copper alloy greater than 15 percent zinc jacket water cooler components exposed to 3-365
 
treated water external environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.21 Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator Air Starting System - LRA Table 3.3.2-21 The staff reviewed LRA Table 3.3.2-21, which summarizes the results of AMR evaluations for the diesel generator air starting system component groups.
LRA Table 3.3.2-21 states that copper alloy less than 15 percent zinc piping, piping components, and piping elements exposed to air/gas (wetted) internal environments exhibit no AERMs. The staff finds this statement acceptable because the GALL Report indicates no AERMs for copper alloy less than 15 percent zinc component types exposed to air with borated water leakage, an environment more aggressive than the air/gas (wetted) internal environment in this line item; therefore, copper alloy less than 15 percent zinc piping, piping components, and piping elements exposed to air/gas (wetted) internal environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-21, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to air/gas (wetted) internal environments.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching, with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to air/gas (wetted) internal environments will be effectively managed by the Selective Leaching of Materials Program.
In LRA Table 3.3.2-21, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to pitting and crevice corrosion for carbon or low-alloy greater than 15 percent zinc piping, piping 3-366
 
components, and piping elements exposed to air/gas (wetted) internal environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to pitting and crevice corrosion for carbon or low-alloy steel greater than 15 percent zinc piping, piping components, and piping elements exposed to air/gas (wetted) internal environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-21, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage SCC and loss of material due to pitting and crevice corrosion for stainless steel piping, piping components, and piping elements exposed to air/gas (wetted) internal environments and stainless steel system strainer screens/elements exposed to air/gas (wetted) environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effects of SCC and loss of material due to pitting and crevice corrosion for stainless steel piping, piping components, and piping elements exposed to air/gas (wetted) internal environments and stainless steel system strainer screens/elements exposed to air/gas (wetted) external environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.22 Auxiliary Systems - Summary of Aging Management Evaluation - Security Power System - LRA Table 3.3.2-22 The staff reviewed LRA Table 3.3.2-22, which summarizes the results of AMR evaluations for the security power system component groups.
In LRA Table 3.3.2-22, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to external air-indoor environments.
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The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of its review, the staff finds that the aging effects of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to external air-indoor environments will be effectively managed by the External Surfaces Monitoring Program.
LRA Table 3.3.2-22 states that elastomers, PVC or thermoplastic piping, piping components, and piping elements exposed to internal fuel oil environments exhibit no AERMs. These materials, unlike metals, do not display corrosion rates but rely on chemical resistance to environments to which they are exposed; therefore, based on industry operating experience and the assumption of proper design and application of the material, the staff finds that elastomers, PVC or thermoplastic piping, piping components, and piping elements exposed to internal fuel oil environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
LRA Table 3.3.2-22 states that elastomer piping, piping components, and piping elements exposed to air/gas (wetted) environments exhibit no AERMs. This commodity group consists of the fuel oil hoses connecting sections of the fuel oil supply and return line that transfers oil between the main, buried storage, and fuel oil day tanks. The selected environment represents conditions in this space, cool and damp. The staff finds this LRA statement acceptable because industry operating experience shows no aging effects likely for this material and environment combination; therefore, elastomer piping, piping components, and piping elements exposed to air/gas (wetted) environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
LRA Table 3.3.2-22 states that PVC or thermoplastic piping, piping components, and piping elements exposed to air-indoor environments exhibit no AERMs. PVC or thermoplastics, unlike metals, do not display corrosion rates but rely on chemical resistance to environments to which they are exposed. On this basis, the staff finds that PVC or thermoplastic piping, piping components, and piping elements exposed to air-indoor environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-22, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc fuel oil system transfer pumps and piping, piping components, and piping elements exposed to fuel oil internal environments.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process 3-368
 
affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching, with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc fuel oil system transfer pumps and piping, piping components, and piping elements exposed to fuel oil internal environments will be effectively managed by the Selective Leaching of Materials Program.
LRA Table 3.3.2-22 states that aluminum or aluminum alloy fuel oil tank flame arresters exposed to either internal air/gas (wetted) or air-outdoor environments exhibit no AERMs.
Aluminum has an excellent resistance to corrosion when exposed to humid air (outdoor or moist air/gas environment). The aluminum oxide film bonds strongly to its surface and, if damaged, reforms immediately in most environments. On a surface freshly abraded and then exposed to air, the oxide film is only 5 to 10 nanometers thick but highly effective in protecting the aluminum from corrosion; therefore, the staff finds that aluminum or aluminum alloy fuel oil tank flame arresters exposed to either internal air/gas (wetted) or air-outdoor environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-22, the applicant proposed the Lubricating Oil Analysis and One-Time Inspection Programs to manage SCC for stainless steel lube oil cooler components exposed to environments of lubricating oil or hydraulic fluid.
The staff's evaluations of the Lubricating Oil Analysis and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.18 and 3.0.3.1.5, respectively. The Lubricating Oil Analysis Program description states that the program maintains oil system contaminates (primarily water and particulates) within acceptable limits by sampling to preserve an environment not conducive to SCC. On the basis that the Lubricating Oil Analysis Program maintains water contamination within acceptable limits, the staff finds the applicants proposal acceptable. In addition, the One-Time Inspection Program verifies the effectiveness of the Lubricating Oil Analysis Program. On the basis of its review, the staff finds that the aging effect of SCC for stainless steel lube oil cooler components exposed to environments of lubricating oil or hydraulic fluid will be effectively managed by the Lubricating Oil Analysis and One-Time Inspection Programs.
In LRA Table 3.3.2-22, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc lube oil cooler components and piping, piping components, and piping elements and gray cast-iron piping, piping components, and piping elements exposed to fuel oil internal environments.
The staff's evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, "Selective Leaching, with an 3-369
 
exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicant's program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc lube oil cooler components and piping, piping components, and piping elements and gray cast-iron piping, piping components, and piping elements exposed to fuel oil internal environments will be effectively managed by the Selective Leaching of Materials Program.
In LRA Table 3.3.2-22, the applicant proposed the Closed-Cycle Cooling Water System Program to manage loss of material due to crevice and pitting corrosion for aluminum or aluminum alloy radiator components exposed to treated water internal environments.
The staff's evaluation of the Closed-Cycle Cooling Water System Program is documented in SER Section 3.0.3.2.7. The Closed-Cycle Cooling Water System Program description states that it is an effective chemistry program augmented by component testing and inspection based on "Closed Cooling Water Chemistry Guideline: Revision 1 to TR-107396, Closed Cooling Water Chemistry Guideline," EPRI, Palo Alto, CA: 2004, to maintain license renewal intended functions. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice and pitting corrosion for aluminum or aluminum alloy radiator components exposed to treated water internal environments will be effectively managed by the Closed-Cycle Cooling Water System Program.
In LRA Table 3.3.2-22, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal fuel oil environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of the external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. The plant-specific note for this line item indicates that this commodity group consists of elastomer hoses. The aging effects for such hoses are driven more by temperature than the environment to which they are exposed; therefore, the external surface is a reasonable indicator of aging effects on internal surfaces and the External Surfaces Monitoring Program is a reasonable approach. On the basis of its review, the staff finds that the aging effect of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal fuel oil environments will be effectively managed by the External Surfaces Monitoring Program.
In LRA Table 3.3.2-22, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for aluminum or aluminum alloy or stainless steel fuel oil tank flame arrester elements exposed to air/gas (wetted) environments.
The staff's evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting 3-370
 
Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The plant-specific note for this line item indicates that the flame arrester requires periodic cleaning to function properly. On the basis of its review, the staff finds that the aging effect of reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for aluminum or aluminum alloy or stainless steel fuel oil tank flame arrester elements exposed to air/gas (wetted) external environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
LRA Table 3.3.2-22 states that fiberglass or fiber-reinforced plastic buried tanks exposed to soil environments exhibit no AERMs. Fiberglass or fiber-reinforced plastic, unlike metals, do not display corrosion rates and rely on chemical resistance to environments to which they are exposed. On this basis, the staff finds that fiberglass or fiber-reinforced plastic buried tanks exposed to soil environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-22, the applicant proposed a TLAA to manage cracking due to thermal fatigue for carbon or low-alloy steel piping, piping components, and piping elements (diesel engine exhaust) exposed to diesel exhaust internal environments.
The staff evaluation of the TLAA is documented in SER Section 4.3.
In LRA Table 3.3.2-22, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer diesel combustion air intake piping, piping components, and piping elements exposed to air/gas (wetted) internal or air-indoor environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. The plant-specific note for this line item indicates that this commodity group consists of elastomer hoses. The aging effects for such hoses are driven more by temperature than the environments to which they are exposed; therefore, the external surface is a reasonable indicator of aging effects on the internal surfaces and the External Surfaces Monitoring Program is a reasonable approach. On the basis of its review, the staff finds that the aging effects of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal fuel oil environments will be effectively managed by the External Surfaces Monitoring Program.
In LRA Table 3.3.2-22, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer seals and components exposed to fuel oil, lubricating oil, or hydraulic fluid internal 3-371
 
environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. The plant-specific note for this line item indicates that this commodity group consists of elastomer hoses. The aging effects for these elastomer hoses are driven more by temperature than the environments to which they are exposed; therefore, the external surface is a reasonable indicator of aging effects on internal surfaces and the External Surfaces Monitoring Program is a reasonable approach. On the basis of its review, the staff finds that the aging effects of change in material properties and cracking due to various degradation mechanisms for elastomer seals and components exposed to fuel oil, lubricating oil, or hydraulic fluid internal environments will be effectively managed by the External Surfaces Monitoring Program.
In LRA Table 3.3.2-22, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer seals and components exposed to air-indoor environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of its review, the staff finds that the aging effect of change in material properties and cracking due to various degradation mechanisms for elastomer seals and components exposed to air-indoor environments will be effectively managed by the External Surfaces Monitoring Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.23 Auxiliary Systems - Summary of Aging Management Evaluation - Instrument Air System - LRA Table 3.3.2-23 The staff reviewed LRA Table 3.3.2-23, which summarizes the results of AMR evaluations for the instrument air system component groups.
In LRA Table 3.3.2-23, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments.
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The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity, with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effects of loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.24 Auxiliary Systems - Summary of Aging Management Evaluation - Service Air System
- LRA Table 3.3.2-24 The staff reviewed LRA Table 3.3.2-24, which summarizes the results of AMR evaluations for the service air system component groups. The staff determined that all AMR evaluation results in LRA Table 3.3.2-24 are consistent with the GALL Report.
3.3.2.3.25 Auxiliary Systems - Summary of Aging Management Evaluation - Bulk Nitrogen Storage System - LRA Table 3.3.2-25 The staff reviewed LRA Table 3.3.2-25, which summarizes the results of AMR evaluations for the bulk nitrogen storage system component groups.
In LRA Table 3.3.2-25, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity, with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
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3.3.2.3.26 Auxiliary Systems - Summary of Aging Management Evaluation - Hydrogen Gas System - LRA Table 3.3.2-26 The staff reviewed LRA Table 3.3.2-26, which summarizes the results of AMR evaluations for the hydrogen gas system component groups.
In LRA Table 3.3.2-26, the applicant proposed the Bolting Integrity Program to manage loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments.
The staff's evaluation of the Bolting Integrity Program is documented in SER Section 3.0.3.2.5.
The Bolting Integrity Program description includes bolting and closure inspections. This program is consistent with GALL AMP XI.M18, "Bolting Integrity, with an exception to the ASME Code version cited in the GALL Report. On the basis of its review, the staff finds that, because these components will be inspected periodically, the aging effect of loss of preload due to thermal effects, gasket creep, and self-loosening for stainless steel closure bolting exposed to air-indoor environments will be effectively managed by the Bolting Integrity Program.
On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.3.2.3.27 Auxiliary Systems - Summary of Aging Management Evaluation - Fire Protection System - LRA Table 3.3.2-27 The staff reviewed LRA Table 3.3.2-27, which summarizes the results of AMR evaluations for the fire protection system component groups.
In LRA Table 3.3.2-27, the applicant proposed the Fire Water System Program to manage loss of material due to crevice and pitting corrosion and MIC for copper alloy greater than 15 percent zinc piping, piping components, and piping elements and sprinkler heads exposed to air/gas (wetted) internal environments.
The staffs evaluation of the Fire Water System Program is documented in SER Section 3.0.3.2.11. The Fire Water System Program description includes system pressure monitoring, wall thickness evaluations, periodic flow and pressure testing in accordance with applicable National Fire Protection Association commitments, and periodic visual inspection of overall system condition. These activities determine whether corrosion and biofouling occur. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice and pitting corrosion and MIC for copper alloy greater than 15 percent zinc piping, piping components, and piping elements and sprinkler heads exposed to air/gas (wetted) internal environments will be effectively managed by the Fire Water System Program.
In LRA Table 3.3.2-27, the applicant proposed the Fire Water System Program to manage loss 3-374
 
of material due to crevice, general, and pitting corrosion and MIC for gray cast-iron piping, piping components, and piping elements exposed to air/gas (wetted) internal environments.
The staffs evaluation of the Fire Water System Program is documented in SER Section 3.0.3.2.11. The Fire Water System Program description includes system pressure monitoring, wall thickness evaluations, periodic flow and pressure testing in accordance with applicable National Fire Protection Association commitments, and periodic visual inspection of overall system condition. These activities determine whether corrosion and biofouling occur. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice, general, and pitting corrosion and MIC for gray cast-iron piping, piping components, and piping elements exposed to air/gas (wetted) internal environments will be effectively managed by the Fire Water System Program.
In LRA Table 3.3.2-27, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc and gray cast-iron piping, piping components, and piping elements and copper alloy greater than 15 percent zinc sprinkler heads exposed to air/gas (wetted) internal environments or copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to lubricating oil or hydraulic fluid internal environments.
The staffs evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, Selective Leaching, with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicants program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc and gray cast-iron piping, piping components, and piping elements and copper alloy greater than 15 percent zinc sprinkler heads exposed to air/gas (wetted) internal environments or copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to lubricating oil or hydraulic fluid internal environments will be effectively managed by the Selective Leaching of Materials Program.
LRA Table 3.3.2-27 states that aluminum or aluminum alloy heat exchanger components exposed to air-outdoor environments exhibit no AERMs. Aluminum has an excellent resistance to corrosion when exposed to humid air (air-outdoor environment). The aluminum oxide film bonds strongly to its surface and, if damaged, reforms immediately in most environments. On a surface freshly abraded and then exposed to air, the oxide film is only 5 to 10 nanometers thick but highly effective in protecting the aluminum from corrosion; therefore, the staff finds that aluminum or aluminum alloy heat exchanger components exposed to air-outdoor environments exhibit no aging effects, and the component or structure will remain capable of performing intended functions consistent with the CLB for the period of extended operation.
In LRA Table 3.3.2-27, the applicant proposed the Fire Protection and Fuel Oil Chemistry Programs to manage loss of material due to MIC for carbon or low-alloy steel piping, piping components, and piping elements exposed to fuel oil internal environments.
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The staffs evaluations of the Fire Protection and Fuel Oil Chemistry Programs are documented in SER Sections 3.0.3.2.10 and 3.0.3.2.12, respectively. The Fire Protection Program description states that the program manages aging of the diesel-driven fire pump fuel oil supply lines and fire barrier assemblies including fire doors, penetration seals, fire wrap, barrier walls, barrier ceilings and floors, and seismic joint filler. The effective Fire Protection Program will adequately manage cracking and loss of material. The Fuel Oil Chemistry Program description states that the program maintains fuel oil quality by monitoring and controlling fuel oil contamination in accordance with ASTM standards. The program minimizes exposure to fuel oil contaminants (e.g., water and microbiological organisms) by verifying the quality of new oil and adding stabilizers before its introduction into the storage tanks and by periodic sampling for whether the tanks are free of water, particulates, and biological growth. During the onsite audit, the staff noted that the Fuel Oil Chemistry Program added stabilizers with a biocide. In its letter dated August 20, 2007, the applicant amended the LRA to include the following:
Exposure to fuel oil contaminants, such as water and microbiological organisms, is minimized by verifying the quality of new oil and the addition of a stabilizer, which contains a biocide and corrosion inhibitors, before the fuel oil is added to the storage tanks that supply the Emergency Diesel Generator and Security Power Diesel Generator. Continued quality levels are assured by periodically checking for and removing water from tank drains, sampling to confirm that the bulk properties of water and sediment, particulate contamination, and biological growth are within administrative target values or Technical Specification limits.
The plant-specific note for this line item indicates that the Fuel Oil Chemistry Program addresses the possibility of loss of material due to MIC. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC in carbon or low-alloy steel piping, piping components, and piping elements exposed to fuel oil internal environments will be effectively managed by the Fire Protection and Fuel Oil Chemistry Programs.
In LRA Table 3.3.2-27, the applicant proposed the Fire Water System Program to manage loss of material due to MIC for stainless steel containment isolation piping, piping components, piping elements, and system strainer screens/elements and aluminum or aluminum alloy piping, piping components, and piping elements exposed to internal raw water environments.
The staffs evaluation of the Fire Water System Program is documented in SER Section 3.0.3.2.11. The Fire Water System Program description states that the program includes system pressure monitoring, wall thickness evaluations, periodic flow and pressure testing in accordance with applicable National Fire Protection Association commitments, and periodic visual inspection of overall system condition. These activities determine whether corrosion and biofouling occur. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for stainless steel containment isolation piping, piping components, piping elements, and system strainer screens/elements and aluminum or aluminum alloy piping, piping components, and piping elements exposed to internal raw water environments will be effectively managed by the Fire Water System Program.
In LRA Table 3.3.2-27, the applicant proposed the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage loss of material due to MIC 3-376
 
for carbon or low-alloy steel piping, piping components, and piping elements exposed to air/gas (wetted) internal environments.
The staffs evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program description includes periodic visual inspections of internal surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. On the basis of its review, the staff finds that the aging effect of loss of material due to MIC for carbon or low-alloy steel piping, piping components, and piping elements exposed to air/gas (wetted) internal environments will be effectively managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
In LRA Table 3.3.2-27, the applicant proposed the Selective Leaching of Materials Program to manage loss of material due to selective leaching for copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to fuel oil internal environments.
The staffs evaluation of the Selective Leaching of Materials Program is documented in SER Section 3.0.3.2.14. The Selective Leaching of Materials Program description states that examinations will determine whether selective leaching has occurred and whether the process affects component ability to perform intended functions for the period of extended operation.
This new program is consistent with GALL AMP XI.M33, Selective Leaching, with an exception to the Brinell hardness test. An acceptable alternative examination method will not affect the ability of the applicants program to detect selective leaching. On the basis of its review, the staff finds that the aging effect of loss of material due to selective leaching of copper alloy greater than 15 percent zinc piping, piping components, and piping elements exposed to fuel oil internal environments will be effectively managed by the Selective Leaching of Materials Program.
In LRA Table 3.3.2-27, the applicant proposed the Closed-Cycle Cooling Water System Program to manage loss of material due to crevice and pitting corrosion for aluminum or aluminum alloy heat exchanger components exposed to treated water internal environments.
The staffs evaluation of the Closed-Cycle Cooling Water System Program is documented in SER Section 3.0.3.2.7. The Closed-Cycle Cooling Water System Program description states that it is an effective chemistry program augmented by component testing and inspection based on Closed Cooling Water Chemistry Guideline: Revision 1 to TR-107396, Closed Cooling Water Chemistry Guideline, EPRI, Palo Alto, CA: 2004, to maintain license renewal intended functions. On the basis of its review, the staff finds that the aging effect of loss of material due to crevice and pitting corrosion for aluminum or aluminum alloy heat exchanger components exposed to treated water internal environments will be effectively managed by the Closed-Cycle Cooling Water System Program.
In LRA Table 3.3.2-27, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal environments of either treated water, fuel oil, lubricating oil, or hydraulic fluid.
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The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. The plant-specific note for this line item indicates that this commodity group consists of elastomer hoses. The aging effects for these elastomer hoses are driven more by temperature than the environments to which they are exposed; therefore, the external surface is a reasonable indicator of aging effects on the internal surfaces and the External Surfaces Monitoring Program is a reasonable approach. On the basis of its review, the staff finds that the aging effects of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to internal environments of either treated water, fuel oil, lubricating oil, or hydraulic fluid will be effectively managed by the External Surfaces Monitoring Program.
In LRA Table 3.3.2-27, the applicant proposed the External Surfaces Monitoring Program to manage change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to air-indoor environments.
The staff's evaluation of the External Surfaces Monitoring Program is documented in SER Section 3.0.3.2.16. The External Surfaces Monitoring Program description includes periodic visual inspections of external surfaces of piping, piping elements, ducting, and components for timely detection of component degradation. The program directs thorough and consistent inspections of SSCs with inspection criteria that focus on detection of aging effects. On the basis of its review, the staff finds that the aging effects of change in material properties and cracking due to various degradation mechanisms for elastomer piping, piping components, and piping elements exposed to air-indoor environments will be effectively managed by the External Surfaces Monitoring Program.
In LRA Table 3.3.2-27, the applicant proposed the Fire Water System Program to manage loss of material due to galvanic corrosion and MIC for aluminum or aluminum alloy heat exchanger components and reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for copper alloy less than 15 percent zinc heat exchanger tubes exposed to internal raw water environments.
The staffs evaluation of the Fire Water System Program is documented in SER Section 3.0.3.2.11. The Fire Water System Program description states that the program includes system pressure monitoring, wall thickness evaluations, periodic flow and pressure testing in accordance with applicable National Fire Protection Association commitments, and periodic visual inspection of overall system condition. These activities determine whether corrosion and biofouling occur. On the basis of its review, the staff finds that the aging effects of loss of material due to galvanic and MIC for aluminum or aluminum alloy heat exchanger components and reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for copper alloy less than 15 percent zinc heat exchanger tubes exposed to internal raw water environments will be effectively managed by the Fire Water System Program.
In LRA Table 3.3.2-27, the applicant proposed the Inspection of Internal Surfaces in 3-378
 
Miscellaneous Piping and Ducting Components Program to manage loss of material due to crevice, general, and pitting corrosion for carbon or low-alloy steel filters exposed to lubricating oil or hydraulic fluid internal environments, reduction of heat transfer effectiveness due to fouling of heat transfer surfaces for stainless steel fuel oil tank flame arrester elements exposed to air/gas (wetted) environments, and loss of material due to crevice and pitting corrosion for stainless steel fuel oil tank flame arresters and piping, piping components, and piping elements exposed to air/gas (wetted) internal environments.
The staffs evaluation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is documented in SER Section 3.0.3.1.7. The Inspe}}

Latest revision as of 17:36, 14 January 2025

Safety Evaluation Report with Open Items Related to the License Renewal of Shearon Harris Nuclear Power Plant, Unit 1
ML080780632
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 03/18/2008
From:
Carolina Power & Light Co
To:
Office of Nuclear Reactor Regulation
Heath, M, NRR/DLR/RLRA, 415-3137
Shared Package
ML080780628 List:
References
Download: ML080780632 (983)
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