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| number = ML061460313
| number = ML061460313
| issue date = 06/01/2006
| issue date = 06/01/2006
| title = Safety Evaluation Report Related to the License Renewal of the Nine Mile Point Nuclear Station, Units 1 and 2 (TAC Nos. MC3272 and MC3273)
| title = Safety Evaluation Report Related to the License Renewal of the Nine Mile Point Nuclear Station, Units 1 and 2
| author name =  
| author name =  
| author affiliation = NRC/NRR
| author affiliation = NRC/NRR
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=Text=
=Text=
{{#Wiki_filter:Safety Evaluation Report Related to the License Renewal of Nine Mile Point Nuclear Station, Units 1 and 2 Docket Nos. 50-220 and 50-410Constellation Energy Group, LLCU.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation June 2006 THIS PAGE IS INTENTIONALLY LEFT BLANK.
{{#Wiki_filter:}}
iii ABSTRACT This safety evaluation report (SER) documents t he technical review of the Nine Mile Point Nuclear Station Units 1 and 2 (NMPNS), license renewal application (LRA) by the staff of the
 
U.S. Nuclear Regulatory Commission (NRC) (the staff). By letter dated May 26, 2004, Constellation Energy Group, LLC submitted the LRA for NMPNS in accordance with Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54). Due to concerns with the adequacy of support for and documentation of the license renewal activities in the initial
 
submission, the applicant submitted an amended LRA (ALRA) on July 14, 2005. Constellation Energy Group, LLC is requesting renewal of the operating licenses for NMPNS (Facility
 
Operating License Numbers DPR-63 and NPF-69, re spectively), for a period of 20 years beyond the current expiration dates of midnight August 22, 2009, for Unit 1 (NMP1) and midnight
 
October 31, 2026, for Unit 2 (NMP2).
NMPNS is located approximately six miles northeast of Oswego, NY. The NRC issued the construction permits for NMP1 on April 12, 1965, and for NMP2 on June 24, 1974. The NRC
 
issued the operating licenses for NMP1 on December 26, 1974 and for NMP2 on July 2, 1987.
 
NMP1 is a boiling water reactor design with a Mark 1 containment. The nuclear steam supply
 
system was supplied by General Electric and t he balance of the plant was originally designed and constructed by Stone and Webster with the assistance of its agent, Niagra Mohawk Power
 
Corporation. NMP1's licensed power output is 1850 megawatt thermal, with a gross electrical
 
output of approximately 615 megawatt electric. NMP2 is a boiling water reactor design with a
 
Mark 2 containment. The nuclear steam supply sy stem was supplied by General Electric and the balance of the plant was originally designed and constructed by Stone and Webster.
 
NMP2's licensed power output is 3467 megawatt thermal, with a gross electrical output of
 
approximately 1144 megawatt electric.
This SER presents the status of the staff's review of information submitted to the staff through April 21, 2006, the cutoff date for consideration in this SER. On March 3, 2006, the staff issued
 
a draft SER which identified two open items that had to be resolved before the staff makes a
 
final determination on the application. The two open items have now been resolved and SER
 
Section 1.5 summarizes these items and their resolutions. SER Section 6 provides the staff's
 
final conclusion on the review of the NMPNS License Renewal Application dated May 26, 2004, as amended July 14, 2005, and all its subsequent supplemental letters as listed in SER
 
Appendix B.
THIS PAGE IS INTENTIONALLY LEFT BLANK.
v TABLE OF CONTENTSAbstract...................................................................iiiTable of Contents............................................................vAbbreviations..............................................................xix
 
1  Introduction and General Discussion.........................................1-1 1.1  Introduction.....................................................1-1
 
===1.2 License===
Renewal Background.......................................1-31.2.1  Safety Review............................................1-4
 
====1.2.2 Environmental====
Review.....................................1-51.3  Principal Review Matters...........................................1-6
 
===1.4 Interim===
Staff Guidance.............................................1-7
 
===1.5 Summary===
of Open Items...........................................1-91.6  Summary of Confirmatory Items....................................1-10
 
===1.7 Summary===
of Proposed License Conditions............................1-10 2  Structures and Components Subject to Aging Management Review.................2-1
 
===2.1 Scoping===
and Screening Methodology.................................2-1 2.1.1  Introduction..............................................2-12.1.2  Summary of Technical Information in the Amended Application.....2-1 2.1.2.1  Scoping Methodology...............................2-2 2.1.2.2  Screening Methodology.............................2-62.1.3  Staff Evaluation...........................................2-7 2.1.3.1  Scoping Methodology...............................2-8 2.1.3.2  Screening Methodology............................2-272.1.4  Evaluation Findings.......................................2-312.2  Plant-Level Scoping Results.......................................2-32 2.2.1  Introduction.............................................2-322.2.2  Summary of Technical Information in the Amended Application....2-322.2.3  Staff Evaluation..........................................2-33 2.2.4  Conclusion.............................................2-362.3  Scoping and Screening Results: Mechanical Systems...................2-362.3A  NMP1 Scoping and Screening Results: Mechanical Systems............2-372.3A.1  Reactor Vessel, Internals, and Reactor Coolant Systems........2-372.3A.1.1  NMP1 Reactor Pressure Vessel....................2-37 2.3A.1.2  NMP1 Reactor Pressure Vessel Internals.............2-39 2.3A.1.3  NMP1 Reactor Pressure Vessel Instrumentation System.2-42 2.3A.1.4  NMP1 Reactor Recirculation System.................2-43 2.3A.1.5  NMP1 Control Rod Drive System...................2-45
 
2.3A.1.6  NMP1 Reactor Coolant Pressure Boundary Components inOther Systems....................................2-472.3A.2  Engineered Safety Features Systems.......................2-482.3A.2.1  NMP1 Automatic Depressurization System............2-49 2.3A.2.2  NMP1 Containment Spray System..................2-50 2.3A.2.3  NMP1 Core Spray System.........................2-51
 
2.3A.2.4  NMP1 Emergency Cooling System..................2-53 vi2.3A.3  Auxiliary Systems.......................................2-54 2.3A.3.1  NMP1 Administration Building Heating, Ventilation, and Air Conditioning (HVAC) System........................2-552.3A.3.2  NMP1 Circulating Water System....................2-56 2.3A.3.3  NMP1 City Water System.........................2-58 2.3A.3.4  NMP1 Compressed Air Systems....................2-60 2.3A.3.5  NMP1 Containment Systems.......................2-63 2.3A.3.6  NMP1 Control Room HVAC System.................2-65
 
2.3A.3.7  NMP1 Diesel Generator Building Ventilation System....2-67 2.3A.3.8  NMP1 Emergency Diesel Generator System...........2-68 2.3A.3.9  NMP1 Fire Detection and Protection System..........2-71 2.3A.3.10  NMP1 Hydrogen Water Chemistry System...........2-762.3A.3.11  NMP1 Liquid Poison System......................2-77
 
2.3A.3.12  NMP1 Miscellaneous Non-Contaminated Vents and Drains System....................................2-792.3A.3.13  NMP1 Neutron Monitoring System.................2-80 2.3A.3.14  NMP1 Process Radiation Monitoring System.........2-82
 
2.3A.3.15  NMP1 Radioactive Waste Disposal Building HVAC System.........................................2-832.3A.3.16  NMP1 Radioactive Waste System..................2-84
 
2.3A.3.17  NMP1 Reactor Building Closed Loop Cooling Water System .........................................2-882.3A.3.18  NMP1 Reactor Building HVAC System..............2-90
 
2.3A.3.19  NMP1 Reactor Water Cleanup System..............2-922.3A.3.20  NMP1 Sampling System.........................2-96 2.3A.3.21  NMP1 Service Water System.....................2-99 2.3A.3.22  NMP1 Shutdown Cooling System.................2-101 2.3A.3.23  NMP1 Spent Fuel Pool Filtering and Cooling System..2-104
 
2.3A.3.24  NMP1 Technical Support Center HVAC System......2-106 2.3A.3.25  NMP1 Turbine Building Closed Loop Cooling Water System ........................................2-1072.3A.3.26  NMP1 Turbine Building HVAC System.............2-108 2.3A.3.27  NMP1 Electric Steam Boiler System...............2-109
 
2.3A.3.28  NMP1 Makeup Demineralizer System..............2-1102.3A.4  Steam and Power Conversion Systems.....................2-1122.3A.4.1  NMP1 Condensate and Condensate Transfer System..2-112 2.3A.4.2  NMP1 Condenser Air Removal and Off-Gas System...2-117
 
2.3A.4.3  NMP1 Feedwater/High Pressure Coolant Injection System ........................................2-119 2.3A.4.4  NMP1 Main Generator and Auxiliary System.........2-1242.3A.4.5  NMP1 Main Steam System.......................2-125 2.3A.4.6  NMP1 Main Turbine and Auxiliary Systems...........2-129 2.3A.4.7  NMP1 Moisture Separator Reheater Steam System....2-1302.3B  NMP2 Scoping and Screening Results: Mechanical Systems...........2-1322.3B.1  Reactor Vessel, Internals, and Reactor Coolant Systems.......2-1322.3B.1.1  NMP2 Reactor Pressure Vessel...................2-132 2.3B.1.2  NMP2 Reactor Pressure Vessel Internals............2-134
 
2.3B.1.3  NMP2 Reactor Pressure Vessel Instrumentation System........................................2-136 vii2.3B.1.4  NMP2 Reactor Recirculation System................2-1382.3B.1.5  NMP2 Control Rod Drive System..................2-139
 
2.3B.1.6  NMP2 Reactor Coolant Pressure Boundary Components in Other Systems.................................2-1412.3B.2  Engineered Safety Features Systems......................2-1422.3B.2.1  NMP2 Automatic Depressurization System...........2-142
 
2.3B.2.2  NMP2 Hydrogen Recombiner System...............2-1432.3B.2.3  NMP2 High Pressure Core Spray System............2-144 2.3B.2.4  NMP2 Low Pressure Core Spray System............2-145 2.3B.2.5  NMP2 Primary Containment Isolation System.........2-147 2.3B.2.6  NMP2 Reactor Core Isolation Cooling System........2-148
 
2.3B.2.7  NMP2 Residual Heat Removal System..............2-149 2.3B.2.8  NMP2 Standby Gas Treatment System..............2-1512.3B.3  Auxiliary Systems......................................2-1522.3B.3.1  NMP2 Air Startup-Standby Diesel Generator System...2-153 2.3B.3.2  NMP2 Alternate Decay Heat Removal System........2-156
 
2.3B.3.3  NMP2 Auxiliary Service Building HVAC System.......2-1582.3B.3.4  NMP2 Chilled Water Ventilation System (Removed)....2-159 2.3B.3.5  NMP2 Compressed Air Systems...................2-159 2.3B.3.6  NMP2 Containment Atmosphere Monitoring System...2-162
 
2.3B.3.7  NMP2 Containment Leakage Monitoring System......2-1642.3B.3.8  NMP2 Control Building Chilled Water System.........2-165 2.3B.3.9  NMP2 Control Building HVAC System...............2-166 2.3B.3.10  NMP2 Diesel Generator Building Ventilation System..2-167 2.3B.3.11  NMP2 Domestic Water System...................2-169
 
2.3B.3.12  NMP2 Engine-Driven Fire Pump Fuel Oil System.....2-170 2.3B.3.13  NMP2 Fire Detection and Protection System........2-171 2.3B.3.14  NMP2 Floor and Equipment Drains System.........2-187 2.3B.3.15  NMP2 Generator Standby Lube Oil System.........2-1912.3B.3.16  NMP2 Glycol Heating System (Removed)...........2-194 2.3B.3.17  NMP2 Hot Water Heating System.................2-194
 
2.3B.3.18  NMP2 Makeup Water System....................2-1972.3B.3.19  NMP2 Neutron Monitoring System................2-198 2.3B.3.20  NMP2 Primary Containment Purge System..........2-199 2.3B.3.21  NMP2 Process Sampling System.................2-201 2.3B.3.22  NMP2 Radiation Monitoring System...............2-203
 
2.3B.3.23  NMP2 Reactor Building Closed Loop Cooling Water System........................................2-2052.3B.3.24  NMP2 Reactor Building HVAC System.............2-206
 
2.3B.3.25  NMP2 Reactor Water Cleanup System.............2-2072.3B.3.26  NMP2 Seal Water System (Removed).............2-211 2.3B.3.27  NMP2 Service Water System....................2-211 2.3B.3.28  NMP2 Spent Fuel Pool Cooling and Cleanup System..2-213
 
2.3B.3.29  NMP2 Standby Diesel Generator Fuel Oil System....2-216 2.3B.3.30  NMP2 Standby Diesel Generator Protection (Generator)System........................................2-220 2.3B.3.31  NMP2 Standby Liquid Control System..............2-2242.3B.3.32  NMP2 Yard Structures Ventilation System..........2-228
 
2.3B.3.33  NMP2 Auxiliary Boiler System....................2-229 viii2.3B.3.34  NMP2 Circulating Water System..................2-230 2.3B.3.35  NMP2 Makeup Water Treatment System...........2-232 2.3B.3.36  NMP2 Radioactive Liquid Waste Management System........................................2-233 2.3B.3.37  NMP2 Roof Drainage System....................2-234 2.3B.3.38  NMP2 Sanitary Drains and Disposal System.........2-2352.3B.3.39  NMP2 Service Water Chemical Treatment System....2-236
 
2.3B.3.40  NMP2 Turbine Building Closed Loop Cooling Water System........................................2-2372.3B.4  Steam and Power Conversion Systems.....................2-238 2.3B.4.1  NMP2 Main Condenser Air Removal System.........2-239 2.3B.4.2  NMP2 Condensate System.......................2-240 2.3B.4.3  NMP2 Feedwater System........................2-2442.3B.4.4  NMP2 Main Steam System.......................2-247
 
2.3B.4.5  NMP2 Moisture Separator and Reheater System......2-250 2.3B.4.6  NMP2 Extraction Steam and Feedwater Heater Drain System........................................2-2512.3B.4.7  NMP2 Turbine Main System......................2-252
 
===2.4 Scoping===
and Screening Results: Structures and Component Supports.....2-2542.4A  NMP1 Structures..............................................2-2552.4A.1  NMP1 Primary Containment Structure......................2-255 2.4A.1.1  Summary of Technical Information in the Amended Application......................................2-2552.4A.1.2  NMP1 Reactor Building..........................2-263 2.4A.1.3  NMP1 Essential Yard Structures...................2-263
 
2.4A.1.4  NMP1 Fuel Handling System......................2-2642.4A.1.5  NMP1 Material Handling System...................2-266 2.4A.1.6  NMP1 Offgas Building...........................2-268
 
2.4A.1.7  NMP1 Personnel/Equipment Access System.........2-2692.4A.1.8  NMP1 Radwaste Solidification and Storage Building...2-270 2.4A.1.9  NMP1 Screen and Pump House Building............2-2722.4A.1.10  NMP1 Turbine Building.........................2-274 2.4A.1.11  NMP1 Vent Stack.............................2-277 2.4A.1.12  NMP1 Waste Disposal Building...................2-2782.4B  NMP2 Structures..............................................2-2802.4B.1  NMP2 Primary Containment Structure......................2-281 2.4B.1.1  Summary of Technical Information in the Amended Application......................................2-2812.4B.1.2  Staff Evaluation................................2-283 2.4B.1.3  Conclusion....................................2-2842.4B.2  NMP2 Reactor Building.................................2-284 2.4B.2.1  Summary of Technical Information in the Amended Application......................................2-2842.4B.2.2  Staff Evaluation................................2-286 2.4B.2.3  Conclusion....................................2-2882.4B.3  NMP2 Auxiliary Service Building..........................2-288 2.4B.3.1  Summary of Technical Information in the Amended Application......................................2-2882.4B.3.2  Staff Evaluation................................2-289 ix2.4B.3.3  Conclusion....................................2-2902.4B.4  NMP2 Control Room Building.............................2-290 2.4B.4.1  Summary of Technical Information in the Amended Application......................................2-2902.4B.4.2  Staff Evaluation................................2-291 2.4B.4.3  Conclusion....................................2-2912.4B.5  NMP2 Diesel Generator Building..........................2-292 2.4B.5.1  Summary of Technical Information in the Amended Application......................................2-2922.4B.5.2  Staff Evaluation................................2-293 2.4B.5.3  Conclusion....................................2-2932.4B.6  NMP2 Essential Yard Structures..........................2-293 2.4B.6.1  Summary of Technical Information in the Amended Application......................................2-2932.4B.6.2  Staff Evaluation................................2-295 2.4B.6.3  Conclusion....................................2-296 2.4B.7  NMP2 Fuel Handling System.............................2-296 2.4B.7.1  Summary of Technical Information in the Amended Application......................................2-2962.4B.7.2  Staff Evaluation................................2-297 2.4B.7.3  Conclusion....................................2-2972.4B.8  NMP2 Main Stack......................................2-298 2.4B.8.1  Summary of Technical Information in the Amended Application......................................2-2982.4B.8.2  Staff Evaluation................................2-299 2.4B.8.3  Conclusion....................................2-2992.4B.9  NMP2 Material Handling System..........................2-299 2.4B.9.1  Summary of Technical Information in the Amended Application......................................2-2992.4B.9.2  Staff Evaluation................................2-300 2.4B.9.3  Conclusion....................................2-3002.4B.10  NMP2 Motor Operated Doors System.....................2-300 2.4B.10.1  Summary of Technical Information in the Amended Application......................................2-3002.4B.10.2  Staff Evaluation...............................2-301 2.4B.10.3  Conclusion...................................2-3012.4B.11  NMP2 Radwaste Building...............................2-301 2.4B.11.1  Summary of Technical Information in the Amended Application......................................2-3012.4B.11.2  Staff Evaluation...............................2-303 2.4B.11.3  Conclusion...................................2-3032.4B.12  NMP2 Screenwell Building..............................2-303 2.4B.12.1  Summary of Technical Information in the Amended Application......................................2-3032.4B.12.2  Staff Evaluation...............................2-305 2.4B.12.3  Conclusion...................................2-3062.4B.13  NMP2 Standby Gas Treatment Building....................2-307 2.4B.13.1  Summary of Technical Information in the Amended Application......................................2-307 x2.4B.13.2  Staff Evaluation...............................2-3082.4B.13.3  Conclusion...................................2-3082.4B.14  NMP2 Turbine Building.................................2-308 2.4B.14.1  Summary of Technical Information in the Amended Application......................................2-3082.4B.14.2  Staff Evaluation...............................2-310 2.4B.14.3  Conclusion...................................2-3102.4C  NMPNS Structural Commodities..................................2-311 2.4C.1  Component Supports...................................2-311 2.4C.1.1  Summary of Technical Information in the Amended Application......................................2-3112.4C.1.2  Staff Evaluation................................2-312 2.4C.1.3  Conclusion....................................2-3132.4C.2  Fire Stops and Seals...................................2-313 2.4C.2.1  Summary of Technical Information in the Amended Application......................................2-3132.4C.2.2  Staff Evaluation................................2-314 2.4C.2.3  Conclusion....................................2-314
 
===2.5 Scoping===
and Screening Results: Electrical and Instrumentation and ControlsSystems...................................................2-314
 
====2.5.1 NMPNS====
Electrical Commodities............................2-316 2.5.1.1  Cables and Connectors...........................2-3172.5.1.2  Non-Segregated/Switchyard Bus....................2-318 2.5.1.3  Containment Electrical Penetrations.................2-3202.5.1.4  Switchyard Components..........................2-321
 
===2.6 Conclusion===
for Scoping and Screening..............................2-3223  Aging Management Review Results..........................................3-13.0  Applicant's Use of the Generic Aging Lessons Learned Report.............3-13.0.1  Format of the License Renewal Application.....................3-23.0.1.1  Overview of Table 1................................3-33.0.1.2  Overview of Table 2................................3-33.0.2  Staff's Review Process.....................................3-43.0.2.1  Review of AMPs...................................3-5 3.0.2.2  Review of AMR Results.............................3-6 3.0.2.3  UFSAR and USAR Supplements......................3-6 3.0.2.4  Documentation and Documents Reviewed..............3-63.0.3  Aging Management Programs...............................3-63.0.3.1  AMPs That Are Consistent with the GALL Report........3-12 3.0.3.2  AMPs That Are Consistent with the GALL Report with Exceptions or Enhancements........................3-26 3.0.3.3  AMPs That Are Not Consistent with or Not Addressed in theGALL Report....................................3-122
 
====3.0.4 Quality====
Assurance Program Attributes Integral to Aging ManagementPrograms.............................................3-160 3.0.4.2  Staff Evaluation.................................3-161 3.0.4.3  Conclusion.....................................3-162
 
===3.1 Aging===
Management of Reactor Vessel, Internals, and Reactor Coolant Systems...................................................3-162 xi 3.1A  NMP1 Aging Management of Reactor Vessel, Internals, and Reactor CoolantSystems...................................................3-162 3.1A.1  Summary of Technical Information in the Amended Application..3-163 3.1A.2  Staff Evaluation.......................................3-1633.1A.2.1  AMR Results That Are Consistent with the GALL Report3-171
 
3.1A.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended............3-180 3.1A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-1923.1A.3  Conclusion...........................................3-202 3.1B  NMP2 Aging Management of Reactor Vessel, Internals, and Reactor CoolantSystems...................................................3-203 3.1B.1  Summary of Technical Information in the Amended Application..3-203 3.1B.2  Staff Evaluation.......................................3-2033.1B.2.1  AMR Results That Are Consistent with the GALL Report3-211
 
3.1B.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-215 3.1B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-2243.1B.3  Conclusion...........................................3-238 3.2A  NMP1 Aging Management of Engineered Safety Features.............3-2383.2A.1  Summary of Technical Information in the Amended Application..3-238 3.2A.2  Staff Evaluation.......................................3-2383.2A.2.1  AMR Results That Are Consistent with the GALL Report3-242
 
3.2A.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-245 3.2A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-2503.2A.3  Conclusion...........................................3-262 3.2B  NMP2 Aging Management of Engineered Safety Features.............3-2623.2B.1  Summary of Technical Information in the Amended Application..3-262 3.2B.2  Staff Evaluation.......................................3-2633.2B.2.1  AMR Results That Are Consistent with the GALL Report3-266
 
3.2B.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-268 3.2B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-2733.2B.3  Conclusion...........................................3-2853.3  Aging Management of Auxiliary Systems............................3-285 3.3A  NMP1 Aging Management of Auxiliary Systems......................3-2853.3A.1  Summary of Technical Information in the Amended Application..3-286 3.3A.2  Staff Evaluation.......................................3-2863.3A.2.1  AMR Results That Are Consistent with the GALL Report3-292
 
3.3A.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended............3-297 3.3A.2.3  AMR Results That Are Not Consistent with or Not Addressed inthe GALL Report.................................3-3053.3A.3  Conclusion...........................................3-346 3.3B  NMP2 Aging Management of Auxiliary Systems......................3-346 xii3.3B.1  Summary of Technical Information in the Amended Application..3-3473.3B.2  Staff Evaluation.......................................3-3473.3B.2.1  AMR Results That Are Consistent with the GALL Report3-353
 
3.3B.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-359 3.3B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-3663.3B.3  Conclusion...........................................3-400
 
===3.4 Aging===
Management of Steam and Power Conversion Systems...........3-401 3.4A  NMP1 Aging Management of Steam and Power Conversion Systems.....3-4013.4A.1  Summary of Technical Information in the Amended Application..3-401 3.4A.2  Staff Evaluation.......................................3-4013.4A.2.1  AMR Results That Are Consistent with the GALL Report3-404
 
3.4A.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-408 3.4A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-4113.4A.3  Conclusion...........................................3-420 3.4B  NMP2 Aging Management of Steam and Power Conversion Systems.....3-4203.4B.1  Summary of Technical Information in the Amended Application..3-421 3.4B.2  Staff Evaluation.......................................3-4213.4B.2.1  AMR Results That Are Consistent with the GALL Report3-424
 
3.4B.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-426 3.4B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-4293.4B.3  Conclusion...........................................3-435
 
===3.5 Aging===
Management of Structures and Component Supports.............3-435 3.5A  NMP1 Aging Management of Structures and Component Supports.......3-4353.5A.1  Summary of Technical Information in the Amended Application..3-435 3.5A.2  Staff Evaluation.......................................3-4363.5A.2.1  AMR Results That Are Consistent with the GALL Report3-442
 
3.5A.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-446 3.5A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-4553.5A.3  Conclusion...........................................3-471 3.5B  NMP2 Aging Management of Structures and Component Supports.......3-4713.5B.1  Summary of Technical Information in the Amended Application..3-471 3.5B.2  Staff Evaluation.......................................3-4723.5B.2.1  AMR Results That Are Consistent with the GALL Report3-478
 
3.5B.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-482 3.5B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report......................3-4943.5B.3  Conclusion...........................................3-511
 
===3.6 Aging===
Management of Electrical and Instrumentation and Controls........3-5113.6.1  Summary of Technical Information in the Application............3-511
 
====3.6.2 Staff====
Evaluation.........................................3-511 xiii3.6.2.1  AMR Results That Are Consistent with the GALL Report3-514 3.6.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended.........3-515 3.6.2.3  AMR Results That Are Not Consistent With or Not Addressed in the GALL Report......................3-5163.6.3  Conclusion............................................3-5253.7  Conclusion for Aging Management Review Results....................3-5264  Time-limited Aging Analyses...............................................4-1
 
===4.1 Identification===
of Time-Limited Aging Analyses...........................4-14.1.1  Summary of Technical Information in the Amended Application.....4-14.1.2  Staff Evaluation.....................................4-24.1.3  Conclusion..............................................4-24.2  Reactor Vessel Neutron Embrittlement Analysis.........................4-24.2.1  Upper-Shelf Energy.......................................4-4 4.2.1.1  Summary of Technical Information in the Amended Application........................................4-44.2.1.2  Staff Evaluation...................................4-4 4.2.1.3  UFSAR and USAR Supplements......................4-94.2.1.4  Conclusion.......................................4-94.2.2  Pressure-Temperature (P-T) Limits...........................4-9 4.2.2.1  Summary of Technical Information in the Amended Application........................................4-94.2.2.2  Staff Evaluation..................................4-10 4.2.2.3  UFSAR and USAR Supplements.....................4-104.2.2.4  Conclusion......................................4-114.2.3  Elimination of Circumferential Weld Inspection (NMP1 Only).......4-11 4.2.3.1  Summary of Technical Information in the Amended Application.......................................4-114.2.3.2  Staff Evaluation..................................4-12
 
4.2.3.3  UFSAR Supplement...............................4-144.2.3.4  Conclusion......................................4-144.2.4  Axial Weld Failure Probability...............................4-14 4.2.4.1  Summary of Technical Information in the Amended Application.......................................4-144.2.4.2  Staff Evaluation..................................4-14 4.2.4.3  UFSAR and USAR Supplements.....................4-154.2.4.4  Conclusion......................................4-15
 
===4.3 Metal===
Fatigue Analysis............................................4-15
 
====4.3.1 Reactor====
Vessel Fatigue Analysis............................4-16 4.3.1.1  Summary of Technical Information in the Amended Application.......................................4-164.3.1.2  Staff Evaluation..................................4-16 4.3.1.3  UFSAR and USAR Supplements.....................4-184.3.1.4  Conclusion......................................4-19 4.3.2  ASME Section III Class 1 Piping and Components Fatigue Analysis (NMP2 Only)...........................................4-19
 
4.3.2.1  Summary of Technical Information in the Amended xivApplication.......................................4-194.3.2.2  Staff Evaluation..................................4-19
 
4.3.2.3  USAR Supplement................................4-194.3.2.4  Conclusion......................................4-19
 
====4.3.3 Feedwater====
Nozzle and Control Rod Drive Return Line (CRDRL) Nozzle Fatigue and Cracking Analyses............................4-20 4.3.3.1  Summary of Technical Information in the Amended Application.......................................4-204.3.3.2  Staff Evaluation..................................4-20 4.3.3.3  UFSAR and USAR Supplements.....................4-224.3.3.4  Conclusion......................................4-22 4.3.4  Non-ASME Section III Class 1 Piping and Components Fatigue Analysis...............................................4-23
 
4.3.4.1  Summary of Technical Information in the Amended Application.......................................4-234.3.4.2  Staff Evaluation..................................4-23 4.3.4.3  UFSAR and USAR Supplements.....................4-244.3.4.4  Conclusion......................................4-24
 
====4.3.5 Reactor====
Vessel Internals Fatigue Analysis.....................4-24 4.3.5.1  Summary of Technical Information in the Amended Application.......................................4-244.3.5.2  Staff Evaluation..................................4-24 4.3.5.3  UFSAR and USAR Supplements.....................4-254.3.5.4  Conclusion......................................4-254.3.6  Environmentally Assisted Fatigue............................4-26 4.3.6.1  Summary of Technical Information in the Amended Application.......................................4-264.3.6.2  Staff Evaluation..................................4-26 4.3.6.3  UFSAR and USAR Supplements.....................4-274.3.6.4  Conclusion......................................4-274.3.7  Fatigue of the Emergency Condenser (NMP1 Only)..............4-27 4.3.7.1  Summary of Technical Information in the Amended Application.......................................4-274.3.7.2  Staff Evaluation..................................4-27
 
4.3.7.3  UFSAR Supplement...............................4-284.3.7.4  Conclusion......................................4-284.4  Environmental Qualification........................................4-284.4.1  Electrical Equipment EQ...................................4-28 4.4.1.1  Summary of Technical Information in the Amended Application.......................................4-284.4.1.2  Staff Evaluation..................................4-29 4.4.1.3  UFSAR and USAR Supplements.....................4-294.4.1.4  Conclusion......................................4-294.4.2  Mechanical Equipment EQ (NMP2 Only)......................4-294.4.2.1  Summary of Technical Information in the Application.....4-30
 
4.4.2.3  USAR Supplement................................4-314.4.2.4  Conclusion......................................4-31
 
===4.5 Concrete===
Containment Tendon Prestress Analysis......................4-31
 
===4.6 Containment===
Liner Plate, Metal Containments, and Penetrations Fatigue xvAnalysis.....................................................4-314.6.1  Torus Shell and Vent System Fatigue Analysis (NMP1 Only)......4-31 4.6.1.1  Summary of Technical Information in the Amended Application.......................................4-324.6.1.2  Staff Evaluation..................................4-32
 
4.6.1.3  UFSAR Supplement...............................4-334.6.1.4  Conclusion......................................4-334.6.2  Torus Attached Piping Analysis (NMP1 Only)..................4-33 4.6.2.1  Summary of Technical Information in the Amended Application.......................................4-334.6.2.2  Staff Evaluation..................................4-33
 
4.6.2.3  UFSAR Supplement...............................4-344.6.2.4  Conclusion......................................4-344.6.3  Torus Wall Thickness (NMP1 Only)..........................4-35 4.6.3.1  Summary of Technical Information in the Amended Application.......................................4-354.6.3.2  Staff Evaluation..................................4-35
 
4.6.3.3  UFSAR Supplement...............................4-354.6.3.4  Conclusion......................................4-354.6.4  Containment Liner Analysis (NMP2 Only).....................4-36 4.6.4.1  Summary of Technical Information in the Amended Application.......................................4-364.6.4.2  Staff Evaluation..................................4-36
 
4.6.4.3  USAR Supplement................................4-364.6.4.4  Conclusion......................................4-36
 
====4.6.5 Fatigue====
of Primary Containment Penetrations..................4-37 4.6.5.1  Summary of Technical Information in the Amended Application.......................................4-374.6.5.2  Staff Evaluation..................................4-37 4.6.5.3  UFSAR and USAR Supplements.....................4-384.6.5.4  Conclusion......................................4-38
 
====4.6.6 Downcomer====
and Safety/relief Valve Discharge Line Fatigue Evaluation(NMP2 Only)...........................................4-38
 
4.6.6.1  Summary of Technical Information in the Amended Application.......................................4-384.6.6.2  Staff Evaluation..................................4-39
 
4.6.6.3  USAR Supplement................................4-394.6.6.4  Conclusion......................................4-394.7  Other Plant-Specific TLAAs........................................4-404.7.1  RPV Biological Shield (NMP2 Only)..........................4-404.7.1.1  Summary of Technical Information in the Application.....4-40 4.7.1.2 Staff Evaluation...................................4-41
 
4.7.1.3  USAR Supplement................................4-444.7.1.4  Conclusion......................................4-444.7.2  Main Steam Isolation Valve Corrosion Allowance (NMP2 Only).....4-44 4.7.2.1  Summary of Technical Information in the Amended Application.......................................4-444.7.2.2  Staff Evaluation..................................4-45
 
4.7.2.3  USAR Supplement................................4-45 xvi4.7.2.4  Conclusion......................................4-464.7.3  Stress Relaxation of Core Plate Hold-Down Bolts (NMP2 Only)....4-46 4.7.3.1  Summary of Technical Information in the Amended Application.......................................4-464.7.3.2  Staff Evaluation..................................4-47
 
4.7.3.3  USAR Supplement................................4-484.7.3.4  Conclusion......................................4-48
 
====4.7.4 Reactor====
Vessel and Reactor Vessel Closure Head Weld Flaw Evaluations (NMP1 Only).................................4-49
 
4.7.4.1  Summary of Technical Information in the Amended Application.......................................4-494.7.4.2  Staff Evaluation..................................4-50
 
4.7.4.3  UFSAR Supplement...............................4-514.7.4.4  Conclusion......................................4-51
 
====4.7.5 Reactor====
Water Cleanup System Weld Overlay Fatigue Flaw GrowthEvaluations (NMP1 Only).................................4-52
 
4.7.5.1  Summary of Technical Information in the Amended Application.......................................4-524.7.5.2  Staff Evaluation..................................4-52
 
4.7.5.3  USAR Supplement................................4-554.7.5.4  Conclusion......................................4-564.8  Conclusion for Time-Limited Aging Analyses..........................4-56
: 5. Review by the Advisory Committee on Reactor Safeguards.......................5-16. Conclusion.............................................................6-1 Appendices Appendix A:  Commitments for License Renewal.................................A-1 Appendix B:  Chronology....................................................B-1Appendix C:  Principal Contributors............................................C-1 Appendix D:  References....................................................D-1 TablesTable 3.0.3-1  NMPNS's Aging Management Programs............................3-7 Table 3.1A-1  Staff Evaluation for NMP1 Reactor Vessel, Internals, and Reactor CoolantSystems Components in the GALL Report...............................3-164 Table 3.1B-1  Staff Evaluation for NMP2 Reactor Vessel, Internals, and Reactor CoolantSystems Components in the GALL Report...............................3-204 Table 3.2A-1  Staff Evaluation for NM P1 Engineered Safety Features Systems Components in the GALL Report......................................3-239 xvii Table 3.2B-1  Staff Evaluation for NM P2 Engineered Safety Features Systems Components in the GALL Report......................................3-263 Table 3.3A-1  Staff Evaluation for NMP1 Auxiliary Systems Components in the GALL Report......................................................3-287 Table 3.3B-1  Staff Evaluation for NMP2 Auxiliary Systems Components in the GALL Report......................................................3-348 Table 3.4A-1  Staff Evaluation for NM P1 Steam and Power Conversion Systems Components in the GALL Report......................................3-402 Table 3.4B-1  Staff Evaluation for NM P2 Steam and Power Conversion Systems Components in the GALL Report......................................3-422 Table 3.5A-1  Staff Evaluation for NMP1 Structures and Component Supports in the GALL Report......................................................3-437 Table 3.5B-1  Staff Evaluation for NMP2 Structures and Component Supports in the GALL Report......................................................3-473 Table 3.6-1  Staff Evaluation for Electrical and Instrumentation and Controls SystemsComponents in the GALL Report......................................3-512 Table 4.2-1  Reactor Vessel USE Analysis Summary for NMP1 and NMP2.............4-8 Table 4.2-2  RV Circumferential Weld Inspection Relief Analysis....................4-13 Table 4.2-3  RV Axial Weld Probability of Failure Analysis.........................4-15 xviii ABBREVIATIONS115KVAC115KV AC electrical distribution120VAC120V AC electrical distribution 125VDC125V DC electrical distribution 13.8KVAC13.8KV AC electrical distribution 24VDC24V DC electrical distribution 4.16KVAC4.16KV AC electrical distribution 600VAC600V AC electrical distributionACalternating currentACIAmerican Concrete Institute ACRSAdvisory Committee on Reactor Safeguards ADAMSAgency Document Access Management System AERMaging effects requiring management AFWauxiliary feedwater AISCAmerican Institute of Steel Construction ALARAas low as reasonably achievable ALRAamended license renewal application AMPaging management program AMRaging management review ANSIAmerican National Standards Institute ARIalternate rod insertion ARTadjusted reference temperature ASBauxiliary service building ASMEAmerican Society of Mechanical Engineers ASTMAmerican Society for Testing and Materials ATWSanticipated transient without scramB24Vbattery-24V-stationBSWbiological shield wall BTPbranch technical position BWRboiling water reactor BWROGBoiling Water Reactor Owners Group BWRVIPboiling water reactor vessel internals projectCAPcorrective action programCAScompressed air system CASScast austentitic stainless steel CBFcycle-based fatigue CCCWSclosed-cycle cooling water system CEGConstellation Energy Group CFchemistry factor
 
CFR Code of Federal RegulationsCGGConstellation Generation Group CIconfirmatory item CLBcurrent licensing basis CMEBChemical and Mechanical Engineering Branch CNSConstellation Nuclear Services xixCR condition reportCRBcontrol room building CRDcontrol rod drive CRDRLcontrol rod drive return line CSHhigh pressure core spray CSTcondensate storage tank CUFcumulative usage factorDBAdesign basis accidentDBDdesign basis document DBEdesign basis event DBTTductile-to-brittle transition temperature DCdirect current DERdeviation event report DGdiesel generator DGBdiesel generator buildingECemergency condenserECCSemergency core cooling systems ECPelectrochemical cooling system ECSemergency cooling system ECTeddy current testing EDGemergency diesel generator EFPYeffective full power years EMAequivalent margin analysis EOLend of life EPRIElectric Power Research Institute EQenvironmental qualification ERVelectromatic relief valve ESFengineered safety feature EVT-1enhanced VT-1 visual inspection EYSessential yard structuresFACflow-accelerated corrosion F en environmental fatigue life correction factorFMPfatigue monitoring program FPfire protection FPEEfire protection engineering evaluation FSARfinal safety analysis report FWfeedwater FW/HPCIfeedwater/ high pressure coolant injection FWSfeedwater systemGALLGeneric Aging Lessons Learned ReportGDCgeneral design criteria or general design criterion GEgeneral electric GEISGeneric Environmental Impact Statement GLgeneric letter GSIgeneric safety issue xxGWTground water tableHCUhydraulic control unitHELBhigh-energy line break HEPAhigh efficiency particulate air HFIRhigh flux isotope reactor HPCIhigh pressure coolant injection HPCShigh pressure core spray HVACheating, ventilation, and air conditioning HWChydrogen water chemistry HXheat exchangerI&Cinstrumentation and controlsIASCCirradiation assisted stress corrosion cracking IBAintermediate-break accident IEEEInstitute of Electrical and Electronics Engineers IGAintergranular attack IGSCCintergranular stress corrosion cracking INinformation notice INPOInstitute of Nuclear Power Operations IPAintegrated plant assessment ISGinterim staff guidance ISIinservice inspection ISPintegrated surveillance programJjouleJ-Rjoule-resistentKVkilovoltKVAkilovolt AmperesLBSleakage boundary (spatial)LOCAloss of coolant accident LOOPloss of offsite power LPCIlow pressure coolant injection LPCSlow pressure core spray LRlicense renewal LRAlicense renewal application LRTleak rate testMCCmotor control centerMELmaster equipment list MICmircrobiologically induced corrosion MGmotor generator MSmain steam MSIVmain steam isolation valve MWemegawatt electric MWtmegawatt thermal xxiNDEnon-destructive examinationsNEINuclear Energy Institute NEILNuclear Electric Insurance Limited NEPANational Environmental Policy Act of 1969 NERNuclear Engineering Report NFPANational Fire Protection Association NMP1Nine Mile Point Unit 1 NMP2Nine Mile Point Unit 2 NMPCNiagra Mohawk Power Corporation NMPNSNine Mile Point Nuclear Station NRCU.S. Nuclear Regulatory Commission NSRnonsafety-related NSSSnuclear steam supply system NUMARCNuclear Management and Resources Council (now NEI)
NUREGU.S. Nuclear Regulatory Commission Regulatory GuideOCCWopen-cycle cooling waterODSCCoutside-diameter stress-corrosion cracking OGBoffgas building OIopen item ORNLOak Ridge National LaboratoryP&IDpiping and instrumentation diagramPAAprogram attribute assessment PCSprimary containment structure PEOperiod of extended operation PMpreventive maintenance PMTpost-maintenance test P-Tpressure-temperature PTSpressurized thermal shock PUARplant-unique analysis report PWRpressurized water reactor PWSCCprimary water stress-corrosion crackingRAIrequest for additional informationRBreactor building RBCLCreactor building closed look cooling RBEDTreactor building equipment drain tank RCICreactor core isolation cooling RCPBreactor coolant pressure boundary RCSreactor coolant system RGregulatory guide RHRresidual heat removal RI-ISIrisk-informed inservice inspection RPSreactor protection system RPTreactor recirculation pump trip RPVreactor pressure vessel RSSBradwaste solidification and storage building
 
RT NDT reference temperature nil ductility transition xxiiRVIDreactor vessel integrity databaseRVSPReactor Vessel Surveillance Program RWBradwaste building RWCUreactor water cleanupS&WStone and WebsterSBAsmall-break accident SBFstress based fatigue SBOstation blackout SCstructure and component SCCstress-corrosion cracking SDCshutdown cooling SEsafety evaluation SERsafety evaluation report SGTBstandby gas treatment building SGTSstandby gas treatment system SHEstandard hydorgen reference electrode SIAstructural integrity attached SILservice information letters SOCstatements of consideration SPHscreen and pumphouse SRsafety-related SRPStandard Review Plan SRP-LRStandard Review Plan for Review of License Renewal Applications for Nuclear Power PlantsSSCsystem, structure, and component SSEsafe-shutdown earthquake SWBscreenwell buildingtthicknessTAPtorus attached piping TBturbine building TBCLCturbine building closed loop cooling TERtechnical evaluation report TLAAtime-limited aging analysis TStechnical specificationUFSARupdated final safety analysis report (for Nine Mile Point Unit 1)UPSuninterruptible power supplies USARupdated safety analysis report (for Nine Mile Point Unit 2)
USASUnited States of America Standards USEupper-shelf energy UTultrasonic testing UVultra violetVVolt WDBwaste disposal buildingWOwork order 1-1 SECTION 1 INTRODUCTION AND GENERAL DISCUSSION
 
===1.1 Introduction===
This document is a safety evaluation report (SER) on the license renewal application (LRA) for Units 1 and 2 of Nine Mile Point Nuclear Station (NMPNS), as filed by Constellation Energy
 
Group, LLC (CEG or the applicant). By letter dated May 26, 2004, CEG submitted its application
 
to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the NMPNS operating
 
licenses for an additional 20 years. By letter to NMPNS, dated December 7, 2004, the staff
 
stated its concern regarding the applicant's inadequate support of license renewal activities for
 
the initial submission. In its response, by letter dated January 3, 2005, the applicant stated that
 
it had taken additional actions to resolve the contributing factors for past performance and
 
agreed to provide supplemental support for the license renewal process. By letter dated March
 
3, 2005, NMPNS requested a 90-day grace period to recover the quality of the NMP LRA. In
 
response to the NMPNS request, the NRC staff (the staff) informed the applicant, by letter dated
 
March 7, 2005, that the review of the NMP LRA had been suspended and that the standard
 
22-month review schedule would not be met due to the suspended period. On July 14, 2005, NMPNS submitted its amended LRA (ALRA).
In the ALRA, the applicant revised the original LRA sections and tables where applicable to identify each nonsafety-related (NSR) system or NSR portion of a safety-related (SR) system that is within the scope of license renewal. In conjunction with this amended information, the
 
applicant also identified additional NSR component types and intended function(s) and made
 
them consistent with the standardized list of intended functions described in the staff Standard
 
Review Plan for License Renewal (SRP-LR) and Nuclear Energy Institute (NEI) 95-10, "Industry
 
Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule."
The staff prepared this report, which summarizes the results of its safety review of the LRA and ALRA for compliance with the requirements of Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." The NRC license renewal project manager for the NMPNS license renewal
 
review is Ngoc B. (Tommy) Le. Mr. Le can be contacted by telephone at 301-415-1458 or by
 
electronic mail at nbl@nrc.gov. Alternatively, written correspondence may be sent to the
 
following address:
License Renewal and Environmental Impacts Program U.S. Nuclear Regulatory Commission
 
Washington, D.C. 20555-0001
 
Attention: Ngoc B. (Tommy) Le, Mail Stop 0-11F1 In its May 26, 2004 submittal letter, as supplemented by its July 14, 2005, letter the applicant requested renewal of the operating licenses issued under Section 104b (Operating License
 
No. DPR-63) and Section 103 (Operating License No. NPF-69) of the Atomic Energy Act of
 
1954, as amended, for Unit 1 (NMP1) and Unit 2 (NMP2), for a period of 20 years beyond the 1-2 current license expiration dates of midnight August 22, 2009, for NMP1 and midnight October 31, 2026, for NMP2.
NMPNS is located approximately six miles northeast of Oswego, NY. The NRC issued the construction permits for NMP1 on April 12, 1965, and for NMP2 on June 24, 1974. The NRC
 
issued the operating licenses for NMP1 on December 26, 1974 and for NMP2 on July 2, 1987.
 
NMP1 is a boiling water reactor design with a Mark 1 containment. The nuclear steam supply
 
system was supplied by General Electric and t he balance of the plant was originally designed and constructed by Stone and Webster, with the assistance of its agent, Niagra Mohawk Power
 
Corporation. NMP1's licensed power output is 1850 megawatt thermal, with a gross electrical
 
output of approximately 615 megawatt electric. NMP2 is a boiling water reactor design with a
 
Mark 2 containment. The nuclear steam supply sy stem was supplied by General Electric and the balance of the plant was originally designed and constructed by Stone and Webster.
 
NMP2's licensed power output is 3467 megawatt thermal, with a gross electrical output of
 
approximately 1144 megawatt electric. The NMP1 updated final safety analysis report (UFSAR) and the NMP2 updated safety analysis report (USAR) contain details concerning the plant and
 
the site.The license renewal process consists of two concurrent reviews: (1) a technical review of safety issues and (2) an environmental review. The NRC regulations found in 10 CFR Parts 54 and 51, respectively, set forth the requirements against which license renewal applications are
 
reviewed. The safety review for the NMPNS license renewal is based on the applicant's original
 
LRA, ALRA, and on responses to the staff's requests for additional information. The applicant
 
supplemented its LRA and ALRA and provided clarifications through its responses to requests
 
for additional information in audits, meetings, and docketed correspondence. Unless otherwise
 
noted, the staff reviewed and considered information submitted through April 21, 2006. The staff
 
reviewed information received after this date on a case-by-case basis depending on the stage
 
of the safety review and on the volume and complexity of the information. The public may view
 
the LRA, ALRA, and all pertinent information and materials, including the UFSAR and USAR
 
mentioned above, at the NRC Public Document Room, located on the first floor of One White
 
Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738 (301-415-4737 / 800-397-4209),
and at the Penfield Library, Reference and Documents Department, 7060 State Route 104, State University of New York, Oswego, NY 13126. In addition, the public may find the LRA and
 
ARLA, as well as materials related to the license renewal review, on the NRC Web Site at
 
http://www.nrc.gov/reactors/operating/licensing/renewal/applications/nine-mile-pt.html
.This SER summarizes the results of the staff's safety review of the NMPNS LRA and ALRA, and describes the technical details considered in evaluating the safety aspects of the proposed
 
operation for an additional 20 years beyond the term of the current operating licenses. The staff
 
reviewed the LRA and ALRA in accordance with NRC regulations and the guidance provided in
 
NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear
 
Power Plants" (SRP-LR), dated July 2001.
SER Sections 2 through 4 address the staff's review and evaluation of license renewal issues that it has considered during the review of the application. Section 5 is reserved for the report of
 
the Advisory Committee on Reactor Safeguards (ACRS). Conclusions of this report are
 
presented in Section 6.
1-3 SER Appendix A contains a table that identifies the applicant's commitments associated with the renewal of the operating licenses. Appendix B provides a chronology of the principal
 
correspondence, between the staff and the applicant, related to the review of the application.
 
Appendix C is a list of the principal contributors to this SER. Appendix D is a bibliography of the
 
references used in support of the 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 related to
 
renewing the licenses for NMPNS. The staff issued draft Supplement 24 to NUREG-1437
 
"Generic Environmental Impact Statement for Li cense Renewal of Nuclear Plants, Regarding Nine Mile Point Nuclear Station, Units 1 and 2, Draft Report for Comment," on September 29, 2005. The final Supplement 24 to NUREG-1437 report was published on May 16, 2006.1.2  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. These licenses can be renewed
 
for up to 20 additional years. The original 40-year license term was selected on the basis of
 
economic and antitrust considerations, rather than on technical limitations; however, some
 
individual plant and equipment designs may have been engineered on the basis of 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 staff to establish a comprehensive program plan for nuclear
 
plant aging research. On the basis of the results of that research, a technical review group
 
concluded that many aging phenomena are r eadily manageable and do not pose technical issues that would preclude 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 the license renewal rule in 10 CFR Part 54 (the Rule). The staff participated in an industry-sponsored demonstration program to apply the Rule to a pilot plant
 
and to gain experience necessary to develop im plementation guidance. To establish a scope of review for license renewal, the Rule defined age-related degradation unique to license renewal;
 
however, during the demonstration program, the staff found that adverse aging effects occur and are managed during the period of initial license. In addition, the staff found that the scope of
 
the review did not allow sufficient credit for existing programs, particularly the implementation of
 
the Maintenance Rule, which could also manage plant-aging phenomena. As a result, the staff
 
amended the license renewal rule in 1995. The amended Rule established a regulatory process
 
that is simpler, more stable, and more predictable than the previous license renewal rule. In
 
particular, the staff amended the Rule to focus on managing the adverse effects of aging, rather
 
than on identifying age-related degradation unique to license renewal. The staff initiated these
 
rule changes to ensure that important syst ems, structures, and components (SSCs) will continue to perform their intended functions during the period of extended operation. In addition, the revised Rule clarified and simplified the integrated plant assessment process to be
 
consistent with the revised focus on passive, long-lived structures and components (SCs).
1-4 In parallel with these efforts, the staff pursued a separate rulemaking effort and developed an amendment to 10 CFR Part 51 to focus the scope of the review of environmental impacts on
 
license renewal and fulfill the NRC's 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 provide and maintain an acceptable level of safety, with the possible
 
exception of the detrimental effects of aging on the functionality 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 defines the scope of license renewal as including those SSCs: (1) that are safety-related; (2) whose failure could affect safety-related
 
functions; and (3) that are relied on to demonstrate compliance with the NRC's regulations for
 
fire protection (FP), environmental qualification (EQ), pressurized thermal shock, anticipated
 
transient without scram (ATWS), and station blackout (SBO).
Pursuant to 10 CFR 54.21(a), an applicant for a renewed license must review all SSCs that are within the scope of the Rule to identify SCs that are subject to an aging management review (AMR). Those SCs that are subject to an AMR perform an intended function without moving
 
parts or without a change in configuration or properties, and are not subject to replacement
 
based on a qualified life or specified time period. As required by 10 CFR 54.21(a), an applicant
 
for a renewed license must demonstrate that the effects of aging will be managed in such a way
 
that the intended function(s) of those SCs will be maintained, consistent with the current
 
licensing basis (CLB), for the period of extended operation; however, active equipment is
 
considered to be adequately monitored and maintained by existing programs. In other words, the detrimental effects of aging that may affect active equipment are more readily detectable
 
and can be identified and corrected through routine surveillance, performance monitoring, and
 
maintenance activities. The surveillance and ma intenance activities programs for active equipment, as well as other aspects of maintaining the plants' 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 supplement to the UFSAR and USAR. This supplement must contain a summary description of the applicant's programs and
 
activities for managing the effects of aging and evaluation of time-limited aging analyses (TLAAs) for the period of extended operation.
License renewal also requires the identification and updating of the TLAAs. During the design phase for a plant, certain assumptions are made about the length of time that the plant can
 
operate. These assumptions are incorporated into design calculations for several of the plant's
 
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 1-5 end of the period of extended operation, or demonstrate that the effects of aging on the intended function(s) will be adequately managed for the period of extended operation.
In 2001, the staff developed and issued Regulatory Guide (RG) 1.188, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses." This regulatory
 
guide endorses Nuclear Energy Institute 95-10, "Industry Guideline for Implementing the
 
Requirements of 10 CFR Part 54 - The License Renewal Rule," Revision 3, dated March 2001.
 
Nuclear Energy Institute 95-10 details an acceptable method of implementing the Rule. The
 
staff also used the SRP-LR to review the application.
In the LRA, the applicant fully utilized the process defined in NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," dated July 2001. The GALL Report provides the staff with a
 
summary of staff-approved aging management progr ams (AMPs) for the aging of many SCs that are subject to an AMR. If an applicant commits to implementing these staff-approved
 
AMPs, the time, effort, and resources used to review an applicant's LRA can be greatly
 
reduced, thereby 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 also serves as a reference for both applicants and staff reviewers to quickly identify those
 
AMPs and activities that the staff determined can provide adequate aging management during
 
the period of extended operation.
 
====1.2.2 Environmental====
Review Environmental protection regulations are codified in 10 CFR Part 51. In December 1996, the staff revised the environmental protection regulations to facilitate the environmental review for
 
license renewal. The staff prepared a Generic En vironmental Impact Statement (GEIS) to document its evaluation of the possible envir onmental impacts associated with renewing licenses for nuclear power plants. For cert ain types of environmental impacts, the GEIS establishes generic findings that are applicable to all nuclear power plants. These generic
 
findings are codified in Appendix B to Subpart A of 10 CFR  Part 51. Pursuant to
 
10 CFR 51.53(c)(3)(i), an applicant for license renewal may incorporate these generic findings
 
in its environmental report. In accordance with 10 CFR 51.53(c)(3)(ii), an environmental report
 
must also include analyses of those 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 the requirements of 10 CFR Part 51, the staff performed a plant-specific review of the environmental impacts of
 
license renewal, including whether new and significant information existed that the GEIS did not
 
consider. As part of its scoping process, the staff held a public meeting on September 21, 2004, in Scriba, NY, to identify environmental issues specific to the plant. The draft, plant-specific
 
Supplement 24 to the GEIS, dated September 29, 2005, documents the results of the
 
environmental review and includes a preliminary recommendation with respect to the license
 
renewal action. The staff held two other public meetings on November 17, 2005, in Scriba, NY, to discuss draft GEIS Supplement 24. After considering comments on the draft, the staff
 
published the final, plant-specific GEIS Supplement 24 on May 16, 2006.
1-61.3  Principal Review Matters The requirements for renewing operating licenses for nuclear power plants are described in 10 CFR Part 54. The staff performed its technical review of the NMPNS LRA and ALRA in
 
accordance with NRC guidance and the requirements of 10 CFR Part 54. The standards for
 
renewing a license are set forth in 10 CFR 54.29. This SER describes the results of the staff's
 
safety review.
In 10 CFR 54.19(a), the NRC requires a license renewal applicant to submit general information. The applicant provided this general information in the original LRA Section 1, submitted by letter May 26, 2004, and the ALRA, submitted by letter dated July 14, 2005. The
 
staff reviewed Section 1 of the LRA and ALRA and found that the applicant had submitted the
 
information required by 10 CFR 54.19(a).
In 10 CFR 54.19(b), the NRC requires that each 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." In its LRA and ALRA, the applicant stated the following
 
regarding this issue:
The current indemnity agreement for NMPNS does not contain a specific expiration term for the operating licenses. Therefore, conforming changes to
 
account for the expiration term of the proposed renewed licenses are not
 
necessary, unless the license number is changed upon issuance of the renewed
 
licenses.The staff intends to maintain the original license numbers upon issuance of the renewed licenses, if approved. Therefore, conforming changes to the indemnity agreement do not need
 
to be made and the requirements of 10 CFR 54.19(b) have been met.
In 10 CFR 54.21, the NRC requires that each LRA contain: (a) an integrated plant assessment, (b) a description of any CLB changes that occurred during the staff's review of the LRA, (c) an
 
evaluation of TLAAs, and (d) an FSAR supplement. Sections 3, 4 and Appendix B of the LRA
 
and ALRA address the license renewal requirements of 10 CFR 54.21(a), (b), and (c).
 
Appendix A of the LRA and ALRA contains the license renewal requirements of
 
10 CFR 54.21(d).
In 10 CFR 54.21(b), the NRC requires that each year following submission of the LRA, and at least three months before the scheduled completion of the staff's review, the applicant must
 
submit an amendment to the LRA that identifies any changes to the facility's CLB that materially
 
affect the contents of the LRA, including the UFSAR and USAR supplements. The applicant
 
submitted an update to the LRA, by letter dated December 20, 2005, which summarizes the
 
changes to the CLB that have occurred during the staff's review of the original LRA. This
 
submission satisfies the requirements of 10 CFR 54.21(b).
In 10 CFR 54.22, the NRC requires that the LRA include changes or additions to the technical specifications that are necessary to manage the effects of aging during the period of extended
 
operation. In Appendix D of the LRA and ALRA, the applicant stated that it had not identified
 
any technical specification changes necessary to support issuance of the renewed operating
 
licenses for NMPNS. This adequately addresses the requirement specified in 10 CFR 54.22.
1-7 The staff evaluated the technical information required by 10 CFR 54.21 and 10 CFR 54.22 in accordance with NRC regulations and the guidance provided by the SRP-LR. SER Sections 2, 3, and 4 document the staff's evaluation of the technical information contained in the LRA and
 
ALRA.As required by 10 CFR 54.25, the ACRS will issue a report to document its evaluation of the staff's review of the LRA, ALRA, and associated SER. SER Section 5 will incorporate the ACRS
 
report, once it is issued. SER Section 6 documents the staff's conclusion as required by
 
10 CFR 54.29.
The final, plant-specific GEIS Supplement 24 documents the staff's evaluation of the environmental information required by 10 CFR 54.23 and specifies the considerations related to
 
renewing the licenses for NMPNS. The staff prepares this supplement separately from this SER.
 
===1.4 Interim===
Staff Guidance The license renewal program 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 staff's 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 it is incorporated into the license renewal guidance documents such as the
 
SRP-LR and the GALL Report.
The following table provides the current ISG, issued by the staff, as well as the SER sections in which the staff addresses each ISG issue.
ISG Issue(Approved ISG No.)PurposeSER Section GALL Report presents oneacceptable way to manage aging
 
effects (ISG-1)This ISG clarifies that the GALL Report contains one acceptable way, but not the only way, to manage aging for license renewal.
N/A SBO Scoping (ISG-2)The license renewal rule10 CFR 54.4(a)(3) includes 10 CFR 50.63(a)(1)-SBO.The SBO rule requires that a plantmust withstand and recover from an SBO event. The recovery time for offsite power is much faster than
 
that of EDGs.The offsite power system should beincluded within the scope of license renewal.2.1.2.1 2.1.2.1.4 2.1.3.1.1 2.1.4.3.5 Concrete AMP (ISG-3)Lessons learned from the GALL demonstration project indicated that GALL is not clear on whether
 
concrete requires an AMP.
3.5A.2.2 (NMP1) 3.5B.2.2 (NMP2)
 
3.5.C.1.2 (Common)
 
3.5.C.3.1 (Common)
ISG Issue(Approved ISG No.)PurposeSER Section 1-8FP System Piping (ISG-4)This ISG clarifies the staff positionfor wall-thinning of the FP piping system in GALL AMPs XI.M26 and XI.M27.The staff's new position is that thereis no need to disassemble FP piping, as disassembly can introduce oxygen to FP piping, which can accelerate corrosion.
 
Instead, use a non-intrusive
 
method, such as volumetric
 
inspection.Testing of sprinkler heads shouldbe performed at year 50 of sprinkler system service life, and every 10 years thereafter.This ISG eliminates theHalon/carbon dioxide system
 
inspections for charging pressure, valve line-ups, and the automatic
 
mode of operation test from GALL;
 
the staff considers these test
 
verifications to be operational
 
activities.
3.0.3.2.14 Identification and Treatment ofElectrical Fuse Holders (ISG-5)This ISG includes electrical fuse holders AMR and AMP (i.e., same
 
as terminal blocks and other
 
electrical connections).The position includes only fuse holders that are not inside the
 
enclosure of active components (e.g., inside of switchgears and
 
inverters).
Operating experience finds that metallic clamps (spring-loaded clips) have a history of age-related
 
failures from aging stressors such as vibration, thermal cycling, mechanical stress, corrosion, and
 
chemical contamination.The staff finds that visual inspection of fuse clips is not sufficient to
 
detect the aging effects from
 
fatigue, mechanical stress, and
 
vibration.
3.0.3.3.4 ISG Issue(Approved ISG No.)PurposeSER Section 1-9The ISG Process (ISG-8)This ISG provides clarification and update to the ISG process on Improved License Renewal
 
Guidance Documents.
N/AStandardized Format for LicenseRenewal Applications (ISG-10)The purpose of this ISG is to provide a standardized license renewal application format for
 
applicants.
N/A1.5  Summary of Open Items and its Resolutions An issue is considered open if the applicant has not presented sufficient basis for resolution and; therefore, has not met all applicable regulatory requirements. As a result of its review of the
 
LRA and ALRA, including additional information submitted to the staff through April 21, 2006, the staff identified the following open items:
Open Item 3.0.3.2.17-1
: Subsequent to the onsite audit and review of NMP ALRA, the staff also reviewed the applicant's Inservice Inspection Owner Activity Report, dated July 23, 2003. In this
 
report, the applicant has stated that, for NMP1, corrosion was identified over the entire 360
 
degree circumference of the drywell interior surface of the liner plate at the 225 foot elevation.
 
The applicant further stated in the report that (1) a subsequent detailed (D-VT) visual
 
examination (VT-1) was performed and that (2) no unacceptable degradation in the visible areas
 
of the drywell liner was found and that (3) no immediate corrective action was taken. The staff
 
has asked the applicant to provide further discussion to address the staff concern regarding the
 
loss of material due to corrosion for the NMP1 drywell.
On March 27, 2006, the applicant met with the staff to discuss the issue identified in OI 3.0.3.2.17-1, and by letter dated April 4, 2006, the applicant provided its response to
 
OI 3.0.3.2.17-1. The applicant stated in the letter that during the March 2003, NMP1 refueling
 
outage, a general visual examination of 100 percent of the accessible portion of the interior
 
surface of the drywell shell was performed. Six localized areas, coinciding with the area coolers, were observed to have significant corrosion. In accordance with ASME Section XI Subsection
 
IWE, a detailed visual examination (VT-1) was performed of the six localized areas. The
 
corrosion was characterized as "major" (i.e., greater than 5 percent of the base metal was
 
judged to be lost). The applicant further stated that the drywell is entirely within a nitrogen
 
inerted atmosphere, and that it has performed appropriate calculation and concluded that the
 
drywell shell will not reach its minimum design thickness until 45 years, which is 19 years
 
beyond the end of the period of extended operation. The applicant further stated that it will
 
continue its monitoring of the drywell shell via a proposed NMP1 Drywell Supplemental
 
Program. This supplemental inspection program is in addition to other AMPs that have been credited for NMP1 containment aging management activities already reviewed and accepted by the staff. These AMPs include the Structural Monitoring, ASME Section XI Subsection IWE, and
 
10 CFR 50 Appendix J Programs. After reviewing the April 4, 2006, response to OI 3.0.3.2.17-1, the staff concludes that the applicant's response is acceptable; therefore, OI 3.0.3.2.17-1 is
 
closed. The staff's evaluation of the applicant's response is detailed in SER Section 3.0.
1-10 Open Item 4.7B.1-1:
The neutron fluence methodology for TLAA Section 4.7.1, "RPV Biological Shield (NMP2 Only)," is based on neutron fluence calculations that have been reported in SANDIA Report No. SAND 92-2420, "Accelerated 54 °C Irradiated Test of Shippingport Neutron
 
Shield Tank and HFIR Vessel Materials [January 1993]." However, the methodology for
 
calculating the neutron fluence values reported in SANDIA Report No. SAND 92-2420 has not
 
been approved by the staff. Therefore, the staff r equested that Constellation Energy submit an updated 54 EPFY neutron fluence calculation for the biological shield wall (BSW) during the
 
NRC's allocated review period for the amended license renewal application.
The staff also requested that the 54 EFPY neutron fluence calculation be based on a methodology that conforms to the NRC's recommendations in RG 1.190, "Calculational and
 
Dosimetry Methods for Determining Pressure Vessel Neutron Fluence [March 2001]," and be
 
submitted for the staff's review and approval.
The applicant responded to OI 4.7B.1-1 by letter dated March 23, 2006, and submitted a summary of a new RG 1.190 based analysis for its determination of the maximum neutron
 
fluence at the NMP2 biological shield wall. The applicant stated that the resultant information
 
from the calculation indicated that the maximum fluence to the shield at the end of Cycle 10 was
 
found to be less than 2E16 n/cm 2 and the maximum fluence at 54 EFPY was found to be 6.2E16 n/cm 2 for fast neutrons (E>1.0 MeV). The applicant further stated that since the 54 EFPY maximum fluence value at the bioshield walls is less than the threshold fluence value
 
(1E17 n/cm
: 2) for the susceptiblity of steel to neutron embrittlement identified in 10 CFR 50, Appendix H, the consideration of this aging effect no longer applies, and that TLAA criterion
 
10 CFR 54.3(a) is no longer applicable to the original analysis. Based on this information, the
 
applicant proposed to delete its original TLAA 4.7.1 submitted in the original LRA and ALRA.
 
The staff reviewed the applicant's response and found the response acceptable; therefore, OI 4.7B.1-1 is closed. The staff's evaluation of the applicant's response is detailed in SER
 
Section 4.0.1.6  Summary of Confirmatory Items A confirmatory item is an issue that the staff has resolved, but for which the applicant has not
 
yet formally submitted the resolution. After completing a review of the ALRA for NMP1 and
 
NMP2, including all additional information and clarifications submitted to the staff as of April 21, 2006, the staff has identified no confirmatory items
.1.7  Summary of Proposed License Conditions As a result of the staff's review of the LRA and ALRA, including subsequent information and clarifications provided by the applicant, the staff identified three proposed license conditions.
The first license condition requires the applicant to include the UFSAR and USAR supplements required by 10 CFR 54.21(d) in the next UFSAR and USAR updates, as required by
 
10 CFR 50.71(e), following the issuance of the renewed licenses.
The second license condition requires that the activities identified in the UFSAR and USAR supplements be completed in accordance with the schedule in Appendix A.
1-11 The third license condition requires the implementation of the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated
 
Surveillance Program (ISP) as the method to demonstrate compliance with the requirements of
 
10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule
 
must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule
 
withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be
 
incorporated into the licensing basis. If any surveillance capsules are removed without the intent
 
to test them, these capsules must be stored in a manner which maintains them in a condition
 
which would support re-insertion into the reactor pressure vessel, if necessary.
THIS PAGE IS INTENTIONALLY LEFT BLANK.
2-1 SECTION 2 STRUCTURES AND COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW
 
===2.1 Scoping===
and Screening Methodology
 
====2.1.1 Introduction====
Title 10 of the Code of Federal Regulations , Part 54 (10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," Section 54.21, "Contents of
 
Application - Technical Information," requires that each application for license renewal contain
 
an integrated plant assessment (IPA). The IPA must list and identify those structures and
 
components (SCs) that are subject to an aging management review (AMR) from all of the
 
systems, structures, and components (SSCs) that are within the scope of license renewal in accordance with 10 CFR 54.4.
In Section 2.1, "Scoping and Screening Methodology," of the original license renewal application (LRA) and amended license renewal application (ALRA), the applicant described the scoping
 
and screening methodology used to identify SSCs at the Nine Mile Point Nuclear Station (NMPNS) within the scope of license renewal and the SCs that are subject to an AMR. The staff
 
reviewed the applicant's scoping and screening methodology to determine whether it meets the
 
scoping requirements stated in 10 CFR 54.4(a) and the screening requirements stated in
 
10 CFR 54.21.
In developing the scoping and screening methodology, the applicant considered the requirements of 10 CFR Part 54, the Statements of Consideration (SOC) for 10 CFR Part 54, and the guidance presented by the Nuclear Energy Institute (NEI), "Industry Guideline for
 
Implementing the Requirements of 10 CFR Part 54 The License Renewal Rule," Revision 5, (NEI 95-10). In addition, in developing this methodology, the applicant considered the
 
correspondence between the U.S. Nuclear Regulatory Commission (NRC) and other
 
applicants and/or the NEI.2.1.2  Summary of Technical Information in the Amended Application In the original LRA and ALRA Sections 2.0 and 3.0, the applicant provided the technical information required by 10 CFR 54.21(a). In ALRA Section 2.1, "Scoping and Screening
 
Methodology," the applicant described the process used to identify the SSCs that meet the
 
license renewal scoping criteria under 10 CFR 54.4(a), as well as the process used to identify
 
the SCs that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
Additionally, the original LRA and ALRA Sections 2.2, "Plant Level Scoping Results," 2.3,"System Scoping and Screening Results: Mechanical Systems," 2.4, "Scoping and Screening
 
Results: Structures and Component Supports," and 2.5, "Scoping and Screening Results:
 
Electrical and Instrumentation and Controls Systems," amplify the process that the applicant
 
used to identify SCs subject to an AMR. ALRA Section 3, "Aging Management Review Results,"
contains the following information:
2-2    Section 3.1, "Aging Management of Reactor Vessel, Internals, and Reactor Coolant System"    Section 3.2, "Aging Management of Engineered Safety Features Systems"      Section 3.3, "Aging Management of Auxiliary Systems"    Section 3.4, "Aging Management of Steam and Power Conversion Systems"      Section 3.5, "Aging Management of Structures and Component Supports" Section 3.6, "Aging Management of Electrical and Instrumentation and Controls Components" The original LRA and ALRA Section 4, "Time-Limited Aging Analyses," contains the applicant's identification and evaluation of time-limited aging analyses (TLAAs).2.1.2.1  Scoping Methodology In the original LRA and ALRA Section 2.1, the applicant described the methodology used to scope mechanical, structural, and electrical and instrumentation and controls (I&C) SSCs
 
pursuant to the requirements of the 10 CFR 54.4(a) scoping criteria. The following sections
 
present the applicant's scoping methodology, as described in the original LRA and ALRA.
2.1.2.1.1  Application of the Scoping Criteria in 10 CFR 54.4(a)
 
The applicant described the general approach to scoping safety-related (SR) and nonsafety-related (NSR) SSCs and SSCs credited with demonstrating compliance with certain
 
regulated events in the original LRA and ALRA Section 2.1.4, "Application of License Renewal
 
Scoping Criterion." The following sections describe the scoping approaches specific to each of
 
the three 10 CFR 54.4(a) scoping criteria.
Application of the Scoping Criteria in 10 CFR 54.4(a)(1). In the original LRA and ALRA Section 2.1.4.1, "Safety Related Criteria Pursuant to 10 CFR 54.4(a)(1)," the applicant
 
discussed the scoping methodology as it pertains to SR criteria in accordance with
 
10 CFR 54.4(a)(1). With respect to the SR criteria, the applicant stated that the SSCs within the
 
scope of license renewal include SR SSCs that are relied upon during and following
 
design-basis events (DBEs). The DBEs considered are consistent with the NMP Unit 1 (NMP1) and Unit 2 (NMP2) current licensing basis (CLB). As part of the process to identify the SSCs
 
within scope of Criterion 1, NMP used a pre-established safety classification process that
 
identifies and documents the SR functions of SSCs. The Maintenance Rule scoping documents
 
are the primary repository of system function classifications, and the master equipment list (MEL) is the primary repository of component classifications. As a result, the Maintenance Rule
 
scoping documents were used as the main source for identifying SR system functions that
 
satisfy Criterion 1. Supporting information from the NMP1 updated final safety analysis report (UFSAR) and the NMP2 updated safety analysis report (USAR), technical specifications (TSs),
design documents, design drawings and MEL were reviewed to ensure all SR system functions
 
were properly identified. Implementation of the license renewal scoping and screening
 
procedure ensured that the UFSAR/USAR, TSs, Maintenance Rule scoping documents, design 2-3 documents, design drawings and MEL were reviewed, as applicable, to ensure all system functions were identified and evaluated against this criterion.
Application of the Scoping Criteria in 10 CFR 54.4(a)(2). In the original LRA and ALRA Section 2.1.4.2, "Non-Safety Related Criteria Pursuant to 10 CFR 54.4(a)(2)," the applicant
 
discussed the scoping methodology as it related to the NSR criteria in accordance with
 
10 CFR 54.4(a)(2). The applicant stated that the process used to review SSCs for
 
10 CFR 54.4(a)(2) applicability ensured that the SSCs within the scope of license renewal
 
include the NSR SSCs whose failure could prevent satisfactory accomplishment of any of the Criterion 1 functions of SSCs.
The applicant reviewed UFSAR/USAR, TSs, Maintenance Rule scoping documents, design documents, design drawings and MEL to ensure all NSR SSC functional interactions were
 
identified where an NSR SSC could fail and prevent the satisfactory accomplishment of an SR
 
intended function. The NSR SSCs meeting Criterion 2 that are explicitly identified in the CLB, such as flood barriers, were identified.
In the original LRA, the applicant identified three additional areas to review for applicability to 10 CFR 54.4(a)(2):  (1)Supports for NSR Equipment - The applicant determined that component supports required to prevent NSR SSCs from physical interacting with SR SSCs were within the
 
scope of license renewal. The LRA described the applicable supports as those that must
 
remain in place such that they do not impact equipment that is required to perform an
 
intended function in such a way as to prevent the equipment from performing its
 
intended function. The applicant considered all NSR supports to be within the scope of
 
license renewal if located in areas housing SR equipment.  (2)NSR SCs in Proximity to SR Equipm ent - The applicant reviewed NSR SCs in proximity of SR equipment in accordance with the guidance contained in NRC Interim Staff
 
Guidance (ISG) 09, "Guidance on the Identification and Treatment of Structures, Systems, and Components which Meet 10 CFR 54.4(a)(2)." The applicant used the
 
preventive option in order to satisfy ISG-09 and considered all NSR piping, fittings, and
 
equipment containing water or steam to be within the scope of license renewal if the
 
NSR SCs were located in the vicinity of SR equipment. NSR SCS were considered to be
 
in the vicinity of SR equipment if located in the same building, corridor, and floor as SR
 
equipment.  (3)SR/NSR Piping Interface - The applicant used plant drawings to identify classification boundaries and SR/NSR piping interfaces. The scope of the NSR piping system was
 
extended beyond the classification change to the first seismic anchor beyond the
 
depicted class change. The applicant determined that the piping between the depicted
 
classification boundary and the first seismic anchor was considered to be within the
 
scope of license renewal. In addition, the applicant considered all NSR piping, fittings, and equipment containing water or steam to be within the scope of license renewal if
 
located in the vicinity of SR equipment. As a result, for piping containing water or steam, the NSR portion within the scope of license renewal extended beyond the depicted class
 
change until no longer in the vicinity of SR equipment or until the first seismic anchor
 
was reached, whichever was furthest. The applicant defined the term "seismic anchor" as a series of supports and changes in piping geometry that combine to provide restraint 2-4 to the piping in six degrees of freedom. For NMP2, the term "seismic anchor" means an actual anchor that provides restraint to the piping in six degrees of freedom.
As a result of the staff's audit of the applicant's scoping and screening methodology, the applicant revised the description of the methodology used to evaluate the 10 CFR 54.4(a)(2)
 
criterion, and provided that revised description in the ALRA. The details of that revised
 
methodology, and the staff's evaluation is provided in SER Section 2.1.3.1.4.
Application of the Scoping Criteria in 10 CFR 54.4(a)(3). In the original LRA and ALRA Sections 2.1.4.3, "Regulated Event Scoping Pursuant to 10 CFR 54.4(a)(3);" 2.1.4.3.1, "Fire
 
Protection;" 2.1.4.3.2, "Environmental Qualification (EQ);" 2.1.4.3.3, "Pressurized Thermal
 
Shock; (PTS)" 2.1.4.3.4, "Anticipated Transients Without Scram (ATWS);" and 2.1.4.3.5, "Station Blackout (SBO)," the applicant discussed the scoping methodology as it related to the
 
regulated event criteria, in accordance with 10 CFR 54.4(a)(3). With respect to the scoping
 
criteria related to 10 CFR 54.4(a)(3), the applicant evaluated all regulated events including fire
 
protection, EQ, ATWS, and SBO. For each regulated event, the applicant identified and
 
reviewed the applicable UFSAR/USAR, TSs, Maintenance Rule scoping documents, design
 
documents, design drawings, and MEL to ensure all SSCs credited for compliance with the
 
regulated event were identified and evaluated against these criteria. Specific scoping for each
 
regulated event was also described in the relevant section.
In summary, the applicant included within the scope of license renewal the SSCs relied on in safety analyses or plant evaluations to perform an intended function that demonstrates
 
compliance with NRC regulations for fire protection, EQ, ATWS, and SBO, in accordance with
 
the criteria of 10 CFR 54.4(a)(3).
2.1.2.1.2  Documentation Sources Used for Scoping and Screening
 
In the original LRA and ALRA Section 2.1.1, "Introduction," the applicant stated that it had reviewed information from the following sources during the license renewal scoping and
 
screening process:
* UFSAR/USAR
* CLB information including TSs and docketed licensing correspondence
* design-basis documents (DBDs)
* Maintenance Rule scoping documents
* controlled drawings
* MEL The applicant stated that it used this information to identify the functions performed by plant systems and structures. It then compared these functions to the scoping criteria in
 
10 CFR 54(a)(1)-(3) to determine whether the associated plant system or structure performed a
 
license renewal intended function. It also used these sources to develop the list of structures
 
and components subject to an AMR.
2.1.2.1.3  Plant and System-Level Scoping 2-5 In the original LRA and ALRA Section 2.1.2, "Plant Level Scoping," the applicant briefly described the scoping methodology for SR and NSR systems and structures and for equipment
 
relied upon to perform a function for any of the five regulated events described in
 
10 CFR 54.4(a)(3). The NMP scoping process began with the review and evaluation of plant
 
systems and structures against the criteria outlined in 10 CFR 54.4(a)(1)-(3) to determine those
 
systems that met the requirements for inclusion in the scope of license renewal. During the
 
initial scoping process, all functions were defined for all systems and structures in the plant.
 
Subsequently, those functions that are intended functions were identified, and portions of the
 
systems and structures that perform those in tended functions were identified. Systems and structures meeting the scoping criteria of 10 CFR 54.4 were, therefore, established.
2.1.2.1.4  Component-Level Scoping
 
After the applicant identified the intended functions of systems or structures within the scope of license renewal, it performed a review to determine which components of each in-scope system
 
and structure supported license renewal intended functions. The applicant considered the
 
components that supported intended functions to be within the scope of license renewal and
 
screened them to determine whether an AMR was required.
The applicant considered three component classifications during this stage of the evaluation: (1) mechanical, (2) civil and structural, and (3) electrical. The applicant called the process of
 
identifying the individual components of a system or structure component screening, although it
 
also included the scoping criteria (i.e., within the scope of license renewal). The following three
 
paragraphs discuss the scoping methodology for these component classifications.    (1)Mechanical Component Scoping - The applicant described the scoping methodology for mechanical components within SR and NSR mechanical systems in the original LRA
 
and ALRA Section 2.1.5.1. For each mechanical system determined to be within the
 
scope of license renewal, the applicant developed a system evaluation boundary to
 
identify the set of structures and components necessary to perform the intended
 
functions for the given mechanical system. These evaluation boundaries included sets of
 
piping and instrumentation diagrams (P&IDs) for each system and the component list
 
from the MEL database. From the system diagrams, the applicant identified components that were required to ensure the system could perform its intended functions. Then, the
 
applicant grouped them into relevant component types associated with each function
 
within the scope of license renewal and listed them in the scoping and screening
 
database for further analysis.  (2)Structural Component Scoping - The original LRA and ALRA Section 2.1.5.2 discusses the scoping methodology associated with civil structures. The applicant reviewed the
 
UFSAR/USAR, Maintenance Rule scoping results, design- and license-basis
 
documents, regulatory requirements, the MEL, 10 CFR Part 50, Appendix B
 
determinations, and plant drawings to determine SCs within the scope of license
 
renewal. All SR SCs were included within the scope of license renewal, and include
 
items such as walls, piping and equipment supports, conduit, cable trays, electrical
 
enclosures, instrument panels, pipe whip restraints, fire barriers, liners, sump screens, doors, blowout panels, flood barriers, missile shields, and jet impingement shields relied
 
upon in the licensing basis. The NSR SCs listed in NEI 95-10, Appendix F; and NSR
 
SCs that perform a function required for compliance with fire protection, ATWS, and 2-6 SBO regulations were included within the scope of license renewal. The in-scope NSR SCs include missile shields that protec t SR equipment; overhead handling systems that could effect SR equipment; walls, curbs, dikes, and doors that provide flood protection
 
for SR equipment; and jet impingement shields and blowout panels that protect SR
 
equipment from the effects of a high-energy line break (HELB). In this way, the applicant
 
was able to compile a comprehensive list of all SCs within the scope of license renewal.  (3)Electrical and I&C Component Scoping - The applicant described the scoping process associated with electrical and I&C systems and components in the original LRA and
 
ALRA Sections 2.1.2 through 2.1.5. For these systems, the applicant elected to use the
 
same methodology that it applied to mechanical and structural SSCs, typically, a
 
bounding or spaces approach, as described in NEI 95-10. As a result, the electrical and
 
I&C component types throughout the plant were identified with regard to specific
 
electrical and I&C system intended functions. The applicant evaluated the electrical and
 
I&C component types against the scoping criteria in 10 CFR 54.4(a)(1)-(3), to determine
 
whether they perform intended functions. This was accomplished using relevant CLB
 
documentation. During the initial scoping process, the applicant described all the
 
electrical and I&C systems and defined their functions. Subsequently, those functions
 
that are intended functions were identified, and portions of the electrical and I&C
 
systems that perform those intended functions were identified. 2.1.2.2  Screening Methodology After determining the SSCs within the scope of license renewal, the applicant implemented a process for determining which SSCs would be subject to an AMR, in accordance with the
 
requirements of 10 CFR 54.21(a)(1). In the original LRA and ALRA Section 2.1.5, "Component
 
Screening," the applicant discussed the screening activities as they related to the SSCs that are
 
within the scope of license renewal. The applicant divided the screening portion of the
 
integrated license renewal plant assessment into three engineering disciplines: mechanical, civil/structural, and electrical and I&C.    (1)Mechanical Component Screening - The applicant stated in the original LRA and ALRA Section 2.1.5.1, that it screened each system identified to be within the scope of license
 
renewal. This process evaluated the individual structures and components included
 
within in-scope mechanical systems to identify specific structures and components that
 
required an AMR. The applicant evaluated each mechanical component identified in the
 
scoping phase. The in-scope SCs that perform an intended function without moving
 
parts or without a change in configuration or properties (screening criterion of
 
10 CFR 54.21(a)(1)(i)) were identified. Active/passive screening determinations were
 
based on the guidance in NEI 95-10, Appendix B, Revision 5. The passive, in-scope
 
SCs that are not subject to replacement based on a qualified life or specified time period (screening criterion of 10 CFR 54.21(a)(1)(ii)) were identified as requiring an AMR. The
 
determination of whether a passive, in-scope SC has a qualified life or specified
 
replacement time period was based on a review of maintenance programs and
 
procedures.  (2)Structural Component Screening - The original LRA and ALRA Section 2.1.5.2, discusses the screening activities related to SCs within the scope of license renewal.
 
These screening activities consisted of the identification of passive components, long-lived components, component intended functions, consumables, and component 2-7 replacement based on performance or condition. The applicant relied on the guidance in NEI 95-10 to develop the plant-specific listing of passive components of interest during
 
the review. Component supports, and fire stops and seals were considered SCs and
 
binned in separate structural commodity groupings.  (3)Electrical/I&C Component Screening - In the original LRA and ALRA Section 2.1.5.4, the applicant described the methodology used to screen electrical and I&C components.
 
Specifically, the applicant applied the screening methodology employed for electrical and
 
I&C components consistent with the guidance in NEI 95-10. All passive, long-lived
 
components, as defined by 10 CFR 54.21(a)(1)(ii), were evaluated as commodities
 
regardless of the system or structure in which they reside in the MEL. As a result, the
 
electrical systems results contain only active components not subject to AMR. An AMR
 
was then conducted on a commodity basis for the entire population of passive, long-lived
 
components. The applicant did not identify individual components that perform intended
 
functions.
Electrical and I&C components associated with the EQ Program are replaced on a specified interval based on a qualified life. Therefore, components in the EQ Program do
 
not meet the "long-lived" criteria of 10 CFR 54.21(a)(1)(ii). They are considered "short-lived" per the regulatory definition and are not subject to AMR. Using these
 
screening criteria, the applicant determined that the passive electrical and I&C
 
component commodity groups at NMPNS that require an AMR are cables and
 
connectors (including splices, connectors, terminal blocks, and fuse holders),
non-segregated/switchyard bus, containment electrical penetrations, and various
 
switchyard components.
 
====2.1.3 Staff====
Evaluation The staff evaluated the original LRA and ALRA scoping and screening methodology in accordance with the guidance contained in U.S. Nuclear Regulatory Commission Regulatory Guide (NUREG)-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear
 
Power Plants," (SRP-LR), Section 2.1, "Scoping and Screening Methodology." The following
 
regulations form the basis for the acceptance criteria for the scoping and screening
 
methodology review:
* 10 CFR 54.4(a), as it relates to the identification of plant SSCs within the scope of 10 CFR Part 54
* 10 CFR 54.4(b), as it relates to the identification of the intended functions of plant SSCs determined to be within the scope of 10 CFR Part 54
* 10 CFR 54.21(a)(1) and(2), as they relate to the methods utilized by the applicant to identify plant structures and components subject to an AMR As part of the review of the applicant's scoping and screening methodology, the staff
 
reviewed the activities described in the following sections of the original LRA and ALRA using
 
the guidance contained in the SRP-LR:
* Original LRA and ALRA Section 2.1, "Scoping and Screening Methodology," to ensure that the applicant described a process for identifying SSCs that are within the scope of
 
license renewal, in accordance with the requirements of 10 CFR 54.4(a)(1)-(3).
2-8
* Original LRA and ALRA Sections 2.2, "Plant Level Scoping Results;" 2.3, "System Scoping and Screening Results: Mechanical Systems;" 2.4, "Scoping and Screening
 
Results: Structures and Component Supports;" and 2.5, "Scoping and Screening
 
Results: Electrical and Instrumentation and Controls Systems," to ensure that the
 
applicant described a process for determining structural, mechanical, and electrical
 
components at NMPNS that are subject to an AMR in accordance with the requirements
 
of 10 CFR 54.21(a)(1) and (2).
In addition, the staff conducted a scoping and screening methodology audit at NMPNS engineering offices in Lycoming, New York, from September 27 to October 1, 2004. The audit
 
focused on ensuring that the applicant had developed and implemented adequate guidance to
 
conduct the scoping and screening of SSCs in accordance with the methodologies described in
 
the application and the requirements of 10 CFR Part 54. The staff reviewed implementation
 
procedures and engineering reports describing the applicant's scoping and screening
 
methodology. In addition, the staff conducted detailed discussions with the applicant on 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 applicant's processes for quality assurance with
 
respect to development of the original LRA and the training and qualification of the original LRA
 
development team. The staff also reviewed a sa mple of system scoping and screening results reports for the feedwater/high pressure coolant injection (FW/HPCI) system and reactor building
 
to ensure (1) that the applicant had appropriately implemented the methodology outlined in the
 
administrative controls and (2) that the results were consistent with the CLB. The staff
 
documented its review in an audit report dated November 9, 2004. The report identified several
 
issues requiring additional information from the applicant prior to completion of the review. Each
 
issue is identified and addressed in detail in this section.2.1.3.1  Scoping Methodology The original LRA scoping evaluations were performed by the applicant's license renewal project personnel and contractors from Constellation Nuclear Services (CNS). The staff discussed the
 
applicant's methodology with the applicant's license renewal project management personnel
 
and reviewed documentation pertinent to the scoping process. The staff assessed whether the
 
scoping methodology outlined in the original LRA and CNS implementation procedures was
 
appropriately implemented and whether the scoping results were consistent with CLB
 
requirements. The staff also reviewed a sample of system scoping results for the following
 
systems: FW/HPCI and reactor building (structural review).
2.1.3.1.1  Implementation Procedures and Documentation Sources Used for Scoping and Screening The staff reviewed the applicant's scoping and screening implementation procedures to verify that the process used to identify structures and components subject to an AMR was consistent
 
with the original LRA and SRP-LR and that the applicant appropriately implemented the
 
procedural guidance. Additionally, the staff reviewed the scope of CLB documentation sources
 
used to support the LRA development and the process used by the applicant to ensure that CLB
 
commitments were appropriately considered during the scoping and screening process.
2-9 Scoping and Screening Implementation Procedures. The staff performed an on-site review of the following scoping and screening methodology implementation procedures and engineering
 
reports: license renewal guidance (LRG)-01,"Lic ense Renewal Project Guidance," Revision 2; LRG-02, "License Renewal Scoping and Screening," Revision 4; LRG-04, "Aging Management
 
Review for Electrical Commodities," Revision 2; LRG-08, "Work Product Review Guideline," Revision 7; LRG-09, "Site Review Guideline," Revision 5; and LRG-10, "License Renewal
 
Application Guideline," Revision 6.
In reviewing these procedures, the staff focused on the consistency of the detailed procedural guidance with information in the original LRA and the various staff positions documented in
 
SRP-LR and ISG documents. The staff found that the scoping and screening methodology
 
instructions were generally consistent with the original LRA Section 2.1 and were of sufficient
 
detail to provide the applicant with concise guidance on the scoping and screening
 
implementation process to be followed during the LRA activities. One exception was found related to the description of the scoping and screening process used to identify electrical
 
commodity groupings. This issue is addressed further in this SER in Section 2.1.3.1.3.
In addition to reviewing the implementing procedures, the staff reviewed supplemental design information, including the DBDs, system drawings, and selected licensing documentation the
 
applicant relied up during the scoping and screening phases of the review. The staff found
 
these design documentation sources to be useful for ensuring that the initial scope of SSCs
 
identified by the applicant was consistent with the plant's CLB.
Sources of Current Licensing Basis Information. The staff reviewed the scope and depth of the applicant's CLB review to verify that the methodology was sufficiently comprehensive to identify
 
SSCs within the scope of license renewal and SCs requiring an AMR. As defined in
 
10 CFR 54.3(a), the CLB is the set of staff requirements applicable to a specific plant and an
 
applicant's written commitments for ensuring compliance with and operation within applicable
 
NRC requirements and the plant-specific design basis that are docketed and in effect. The CLB
 
includes certain NRC regulations; orders; license conditions; exemptions; TSs; and
 
design-basis information documented in the most recent FSAR. The CLB also includes
 
applicant commitments remaining in effect that were made in docketed licensing
 
correspondence, such as applicant responses to NRC bulletins, generic letters (GLs), and
 
enforcement actions, as well as applicant commitments documented in NRC safety evaluations
 
or applicant event reports.
The staff determined that the original LRA and ALRA Section 2.1.1 provides a description of the CLB and related documents used during the scoping and screening process that is consistent
 
with the guidance contained in SRP-LR and NEI 95-10. Specifically, the original LRA and ALRA
 
Section 2.1.1 identified the UFSAR/USAR, TSs, docketed licensing correspondence, MEL, controlled drawings, and the Maintenance Rule scoping documents. Additionally, in
 
Section 3.2.2 of scoping implementation procedure LRG-02, the applicant provided a
 
comprehensive listing of documents that could be used to support scoping and screening
 
evaluations. The applicant noted that system de scriptions and system intended functions were identified based on the review of applicable sections of the UFSAR/USAR, Appendix B
 
determinations, Maintenance Rule scoping document, and design and licensing basis
 
documents.
2-10 The NMP MEL is the applicant's primary repository for component safety classification information. During the audit, the staff reviewed the applicant's administrative controls for MEL
 
safety classification data and concludes that the applicant had established adequate measures
 
to control their integrity and reliability. Therefore, the staff concludes that the MEL provided a
 
sufficiently controlled source of component data to support scoping and screening evaluations.
In LRG-02, the applicant identified topical reports as a source of information to support identification of systems and structures relied upon to demonstrate compliance with certain
 
regulated events referenced in 10 CFR 54.4(a)(3). These reports were developed in accordance
 
with the NMP engineering directives that describe the requirements for preparation of Nuclear
 
Engineering Reports (NERs). These reports were developed and maintained as controlled
 
quality documents at the NMP. The topical reports contain a listing of CLB references used for
 
their development that is consistent with the original LRA Section 2.1.1. The staff concludes that
 
the preparation of the topical reports in accordance with the NMPNS requirements for
 
development of NERs provided sufficient guidance to reasonably ensure that topical reports
 
adequately summarized CLB information for the purposes of scoping.
As part of the audit, the staff evaluated the scope and depth of the applicant's document review to provide assurance that the scoping methodology considered all SSC intended functions. In
 
reviewing the original LRA and scoping and screening implementation procedures, the staff was
 
unable to determine (1) the extent that the CLB was reviewed by the applicant during the
 
development of the system description and (2) the extent that related intended function
 
evaluations were performed during the scoping phase of the review. During discussions with the
 
NMP license renewal project team, it was noted that an electronic document database was used
 
to identify CLB documents pertinent to the development of system descriptions and
 
identification of system intended functions. However, the staff remained unable to determine the
 
extent to which that electronic database was used for those purposes at the time of the audit.
In RAI 2.1-3, dated November 22, 2004, the staff requested that the applicant provide a detailed description of the methodology used to develop system descriptions and identify the system intended functions. The staff also requested that the applicant describe the controls and
 
processes, including proceduralized controls, used to ensure that the electronic CLB document
 
database was complete and accurate.
In its response, by letter dated December 22, 2004, the applicant stated, in part, that the system descriptions and system intended functions were developed in accordance with LRG-02, which
 
identified the primary sources for description and intended function information. As part of the
 
review process, the applicant described the use of several levels of review and approval
 
including an independent license project engineer review, discipline lead review, supervisor
 
review, system engineer review, and, finally, project manager review and approval. This review process was implemented to ensure a high confidence that system descriptions were accurate
 
and all functions have been properly identified. The specific documents used for the generation
 
of the system descriptions and intended functions were also referenced in the individual system
 
and structure scoping and screening report for ease of verification.
With respect to the electronic document database, the applicant clarified in its December 22, 2004, letter that the electronic file contained correspondence between the staff and NMP up to
 
February 2003. The latter correspondence was not entered into the system but evaluated as
 
part of the review process in hard copy format. The applicant also clarified that the electronic file 2-11 contained documents that were part of the CLB and were used to support the development of position papers and reports for use during the license renewal evaluation. These records were
 
researched specifically to ensure that all functions were properly identified for the fire protection, ATWS, and SBO regulated events. Specific documents reviewed included NMP responses to
 
the issuance of new regulations (i.e., ATWS and SBO), NRC safety evaluations, NMP
 
responses to the safety evaluations, as applic able, and NMP responses to GLs. The electronic files were also researched when specific questions arose during scoping and aging
 
management program reviews.
On the basis of the supplemental information provided by the applicant in response to the staff's request for information, and the clarification as to what extent that information was reviewed and
 
applied to the license renewal evaluation, the staff found that the applicant has adequately
 
addressed the staff's request for additional information. Therefore, the staff's concern described
 
in RAI 2.1-3 is resolved.
Conclusion. On the basis of a review of information provided in the original LRA and ALRA Section 2.1, a review of the applicant's detailed scoping and screening implementation
 
procedures, and the results from the scoping and screening audit including the applicant's
 
responses to the staff's RAI, the staff concludes that the applicant's scoping and screening
 
methodology considered a scope of CLB information consistent with the guidance contained in
 
SRP-LR and NEI 95-10, and is, therefore, acceptable.
2.1.3.1.2  Quality Assurance Controls Applied to LRA Development
 
The staff reviewed the quality assurance controls used by the applicant to provide reasonable confidence that the original LRA scoping and screening methodologies were adequately
 
implemented. Although the applicant did not develop the original LRA under a 10 CFR Part 50, Appendix B, quality assurance program, the staff determined that the applicant utilized the
 
following quality assurance processes during the original LRA development:
* Implementation of the scoping and screening methodology was governed by written procedures and guidelines.
* Although much of the original LRA development was performed by contractors, the applicant developed procedures to govern the conduct of owner acceptance reviews of
 
contractor work products. For example, License Renewal Project Guidance LRG-08 "Work Product Review Guideline," Revision 7; and LRG-09 "Site Review Guideline,"
Revision 5, describe the process used by the applicant and CEG to review license
 
renewal project documents developed by the CEG staff. Documents subject to this
 
acceptance review included scoping and screening review reports, AMR reports, TLAAs, and aging management program (AMP) attribute and alternatives reports.
* The original LRA was reviewed and approved by the Nuclear Safety Review Board and the Station Operation Review prior to submittal to the staff. Additionally, the applicant
 
developed procedural guidance for a final review of the original LRA prior to submittal to
 
the staff.
* The applicant planned to retain certain license renewal documents, such as AMRs, individual system scoping reports, TLAAs, and topical reports, as quality records or
 
controlled documents.
2-12
* The applicant performed an industry peer review and several quality assurance assessments of license renewal activities.
Conclusion. On the basis of review of pertinent original LRA development guidance, discussion with the applicant's license renewal staff, and review of quality audit reports, the staff concludes
 
that these quality assurance activities provided additional assurance that original LRA
 
development activities were performed consistently with the original LRA descriptions, and that
 
this consistency is maintained in the ALRA.
2.1.3.1.3  Training
 
The staff reviewed the applicant's training process to ensure the guidelines and methodology for the scoping and screening activities would be performed in a consistent and appropriate
 
manner. The screening and scoping of SSCs for license renewal was accomplished by CEG
 
personnel. The CEG LRA team included personnel who had gained previous license renewal
 
experience working on the Calvert Cliffs 1 and 2 LRA. The CEG LRA team was supplemented with additional CEG personnel that were provided with LRA-specific training. The purpose of the
 
training was to provide a framework for ensuring that the personnel assigned to the technical
 
portion of the original LRA acquired a fundamental level of knowledge of the license renewal
 
process and regulatory requirements.
The training program for these personnel consisted of "check-outs" administered by individuals with LRA experience, required reading of selected documents, and lectures by personnel
 
experienced in various LRA topics. A "check-out" is defined as a short interview between a
 
qualification trainee and a subject matter expert to determine whether the trainee has an
 
adequate understanding of a particular subject. With the exception of CEG personnel with prior
 
license renewal experience, each CEG person assigned to license renewal maintained a
 
training qualification record as part of the application development process. The results of the
 
scoping and screening activities accomplished by CEG personnel were reviewed by CEG
 
personnel. Personnel with prior experience on LRA preparation provided lectures on such topics
 
as, scoping, boundaries, screening, AMRs, and TLAA. A check list was developed and used by
 
CEG personnel to complete their reviews. The check list provided general guidance on what
 
was required to be reviewed. Reviewers were required to use the check list, and the check lists
 
were maintained as a permanent record.
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 did not identify
 
any adverse findings. Additionally, based on discussions with the applicant's license renewal
 
personnel during the audit, the staff verified that the applicant's license renewal personnel were
 
knowledgeable on the license renewal process requirements and the specific technical issues
 
within their areas of responsibility.
Conclusion. On the basis of discussions with the applicant's license renewal project team responsible for the scoping and screening process, and a review of selected design
 
documentation in support of the process, the staff concludes that the applicant's personnel
 
understood the requirements of the original LRA and adequately implemented the scoping and
 
screening methodology established in the original LRA.
2.1.3.1.4  Application of the Scoping Criteria in 10 CFR 54.4(a) 2-13 Application of the Scoping Criteria in 10 CFR 54.4(a)(1). In part, 10 CFR 54(a)(1) requires that the applicant consider all SR SSCs that are relied upon to remain functional during and
 
following DBEs to ensure the following functions:
* To maintain the integrity of the reactor coolant pressure boundary.
* To shut down the reactor and maintain it in a safe-shutdown condition.
* To prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1),
10 CFR 50.67(b)(2), or 10 CFR 100.11 to be within the scope of license renewal.
With regard to identification of DBEs, SRP-LR Section 2.1.3, "Review Procedures," states:
The set of design basis events as defined in the rule is not limited to Chapter 15 (or equivalent) of the UFSAR. Examples of design basis events 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 design basis events as defined in
 
10 CFR 50.49(b)(1) may be found in any chapter of the facility UFSAR, the
 
Commission's regulations, NRC orders, exemptions, or license conditions within
 
the CLB. These sources should also be reviewed to identify systems, structures
 
and components that are relied upon to remain functional during and following
 
design basis events (as defined in 10 CFR 50.49(b)(1)) to ensure the functions
 
described in 10 CFR 54.4(a)(1).
The staff's review of original LRA Section 2.1 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 2.1-1, dated November 22, 2004, the staff stated that during the scoping and screening
 
methodology audit, the staff questioned how non-accident DBEs, particularly DBEs that may not
 
be described in the UFSAR/USAR, were considered during scoping. The staff noted that limiting
 
the review of DBEs to those described in the UFSAR/USAR accident analysis could result in
 
omission of SR functions described in the CLB and requested the applicant provide a list of all
 
DBEs that were evaluated as part of the license renewal review. However, during the audit, the
 
staff was unable to identify such as listing. Therefore, the staff requested in RAI 2.1-1, that the
 
applicant provide a list of DBEs evaluated as part of the license renewal scoping process, and
 
describe the methodology used to ensure that all DBEs (including conditions of normal
 
operation, anticipated operational occurrences, design-basis accidents, external events, and
 
natural phenomena) were addressed during license renewal scoping In its response, by letter dated December 22, 2004, the applicant stated, in part, that the methodology used to ensure that all DBEs, including operational occurrences, abnormal
 
operating transients, anticipated and abnormal operational occurrences, design-basis accidents, and the general design criteria, were addressed during license renewal scoping was to utilize
 
the NMP controlled documents and databases that identified those SSCs and functions
 
classified as SR. These documents and databases consist of the NMP1 UFSAR and NMP2
 
USAR, safety-class boundary drawings, Appendix B determinations, Maintenance Rule scoping
 
documents, and MEL, as well as additional CLB information identified in the individual scoping 2-14 and screening reports developed for each NMP1 and NMP2 system and structure. The applicant also provided a detailed listing of the various DBEs for each unit and a description of
 
the design and configuration control processes used to ensure that all SSCs required to perform
 
an SR function are properly evaluated and identified.
The staff reviewed the additional information provided by the applicant, and discussed the response at a meeting on February 2, 2005, to verify that HELBs were specifically considered
 
within the DBE evaluations. On the basis of providing (1) a detailed listing of the DBEs for each
 
unit including HELBs; (2) a description of the design and configuration control processes used
 
to identify the SSCs credited for DBE mitigation; and (3) a description of the processes and
 
sources of DBE information used to perform the scoping evaluation consistent with the
 
requirements of 10 CFR 54.4(a)(1), the staff found that the applicant has adequately addressed
 
the staff's RAI. Therefore, the staff's concern described in RAI 2.1-1 is resolved.
The applicant's approach to satisfying the scoping requirements of 10 CFR 50.54(a)(1) was to identify and describe all plant systems and structures and evaluate those against the SR
 
criteria. As part of this process, the applicant reviewed various licensing basis documents to
 
identify SR intended functions associated with the NMP units. To accomplish this, the applicant
 
performed scoping of SR SSCs in accordance with LRG-02 Sections 3.3 and 3.7.2. LRG-09
 
Section 3.2 was used to direct the review of scoping activities by the NMP staff. The applicant
 
classified SSCs as either SR or NSR, using the information provided in the Maintenance Rule
 
scoping document and the component-specific safety classification field in the MEL.
LRG-02 Section 3.8, "Component List," requires that the MEL be used to populate the license renewal database with components of systems or structures within the scope of license
 
renewal. The MEL safety classification field was re viewed to ensure that any system or structure that has a component identified as SR was considered for inclusion in the scope of the license
 
renewal project. Additionally the MEL safety-classification and associated MEL drawings
 
provided a starting point for identifying specific mechanical and structural components required
 
to meet the 10 CFR 54.4(a)(1) criteria. The staff reviewed the safety classification criteria used
 
to determine the NMP safety classification to verify consistency with 10 CFR 54.4(a)(1) criteria.
 
The staff determined that the nuclear SR definition used by the applicant in its safety
 
classification program did not include all the exposure limitations referenced in
 
10 CFR 54(a)(1)(iii). Specifically, NMP plant procedure NIP-DES-02, "Safety Classification of
 
Items and Activities," did not include a reference to the offsite exposure limitations contained in
 
10 CFR 50.67(b)(2) for use of an alternate source term. However, during discussions with the
 
applicant it was determined that NMP had not requested a licensing basis change to use the
 
alternate source term criteria; therefore, the requirements of 10 CFR 50.67(b)(2) do not
 
currently impact the license renewal program.
 
As part of the audit discussions related to the determination of SR SSCs, the staff questioned
 
whether some components classified as SR in the facility database might not perform any of the
 
SR intended functions of 10 CFR 54.4(a)(1) due to plant-unique considerations or preferences.
 
The applicant stated that these components may have been considered outside the scope of
 
10 CFR 54.4(a)(1). During the audit, the applicant described the process used to evaluate
 
components classified as SR that did not perform an SR intended function. As part of the
 
process, the applicant stated that the safety-classification of many SR components was
 
re-evaluated in order to reconcile differences between scoping determinations and facility
 
database information or the Maintenance Rule scoping results.
2-15 In RAI 2.1-2, dated November 22, 2004, the staff requested that the applicant provide a description of the process used during license renewal scoping activities to disposition
 
components classified as SR that do not perform an SR intended function. In particular, the staff
 
requested that the applicant provide a description of any components or structures classified as
 
SR in the facility safety-classification database that were not included within the scope of
 
license renewal under the 10 CFR 54.4(a)(1) criteria. Additionally, the staff asked the applicant
 
to describe the process used to reconcile the facility database safety classification information
 
with scoping intended function determinations.
In its response, by letter dated January 31, 2005, the applicant stated, in part, that during the scoping and screening process for the NMPNS original LRA, the applicant identified a small
 
percentage of components as SR, but not required to meet any intended function for
 
compliance with 10 CFR 54.4(a)(1). These discrepancies were entered into the NMP corrective
 
action program (CAP) for resolution. The applicant provided a discussion of the specific cases
 
where such re-classifications were identified. These included several components in NSR
 
systems that were classified as SR in the plant component database, called Master Equipment List for NMP1 and NMP 2 (MEL1, MEL2) when the license renewal project was started, but
 
have since been reclassified as NSR as a result of detailed review of the CLB as part of the
 
renewal process. These components were entered into the CAP and reclassified in accordance
 
with the design change process. Secondly, the applicant explained that there were instances of
 
components identified as SR during the scoping and screening process that have been
 
removed from the plant via the modifica tion process. These components have been moved to the plant historical database. Thirdly, the applicant identified several components in MEL1
 
classified as SR that have been abandoned in place. These components are not within the
 
scope of license renewal as they perform no syst em function and, therefore, do not perform any license renewal intended function.
The applicant also noted that all components reclassified as NSR that contain liquid and are in the vicinity of SR equipment are still considered within the scope of license renewal for criterion
 
10 CFR 54.4(a)(2).
Additionally, the applicant provided a description of the process used to evaluate these components to ensure proper classification and disposition within the license renewal
 
evaluation. Generically, the process began when a license renewal team member identified an apparent discrepancy. A license renewal team member would then review the situation with a
 
system and/or design engineer to obtain more information. If it still appeared that there was a
 
component identified as SR that did not support an SR system function, it would be elevated to license renewal project supervision. If it could not be resolved at that point, or if the plant
 
database required a revision, the issue was entered into the CAP for resolution. For any
 
resolution that required a change to a design document or the plant database, the design and/or
 
configuration change process was used. Both of these processes required a review and
 
approval of the change by an individual other than the preparer. The resolutions of these
 
discrepancies were then fed back to the license renewal team member for proper incorporation
 
into the scoping and screening process.
On the basis of the supplemental information provided by the applicant in response, including identification of the types of components that were re-classified, and a description of the
 
process for evaluation and disposition of such components, the staff found that the applicant 2-16 adequately addressed the RAI. Therefore, the staff's concern described in RAI 2.1-2 is resolved.To provide additional assurance that the applicant adequately implemented its SR scoping methodology, the staff reviewed a sample of the license renewal scoping results for the
 
FW/HPCI system and the reactor building (structural review), and discussed the methodology
 
and results with the applicant's personnel who were responsible for these evaluations. The staff
 
verified that the applicant had identified and used pertinent engineering and licensing
 
information to identify the SSCs required to be within the scope of license renewal.
Conclusion. On the basis of this sample review, discussions with the applicant, review of the applicant's scoping process, and RAI responses, the staff determined that, the applicant's
 
methodology for identifying systems and structures meets the scoping criteria of
 
10 CFR 54.4(a)(1) and is therefore adequate.
Application of the Scoping Criteria in 10 CFR 54.4(a)(2). In part, 10 CFR 54(a)(2) requires that the applicant consider all NSR SSCs whose failure could prevent satisfactory accomplishment
 
of any of the functions identified in 10 CFR 54(a)(1)(i), (ii), or (iii) to be within the scope of
 
license renewal.
By letters dated December 3, 2001, and March 15, 2002, the NRC issued its position to the NEI to provide staff expectations for determining what SSCs meet 10 CFR 54.4(a)(2). The
 
December 3, 2001, letter provided specific exam ples of operating experience which identified pipe failure events (summarized in Information Notice (IN) 2001-09, "Main Feedwater System
 
Degradation in Safety-Related ASME Code Class 2 Piping Inside the Containment of a
 
Pressurized Water Reactor") and the approaches the staff considers acceptable to determine
 
which piping systems should be included within the scope of license renewal based on
 
10 CFR 54.4(a)(2). The March 15, 2002, letter further described the staff's expectations for the
 
evaluation of non-piping SSCs to determine which additional NSR SSCs are within the scope of
 
license renewal. The position stated that applicants should not consider hypothetical failures, but rather should base their evaluation on the plant's CLB, engineering judgment and analyses, and relevant operating experience. The paper further described operating experience as all
 
documented plant-specific and industry-wide experience that can be used to determine the
 
plausibility of a failure. Documentation would include NRC generic communications and event
 
reports, plant-specific condition reports (CRs), i ndustry reports such as Significant Operating Experience Reports (SOERs), and engineering evaluations.
The applicant implemented the scoping and screening process in accordance with LRG-02,"License Renewal Scoping and Screening." Paragraph 3.4.1 of LRG-02 states that NSR SSCs
 
whose failure could affect the satisfactory accomplishment of any SR functions were considered
 
within the scope of license renewal. The procedure further specified the various NSR SSCs that
 
were considered within the scope of license renewal, such as NSR features which protect SR
 
SSCs from missiles; certain overhead handling sy stems; walls, curbs and dikes which provide flood barriers to SR SSCs; NSR whip restraints, jet impingement shields, and blowout panels
 
which provide SR SSCs from the effects of a HELB; NSR piping attached to SR piping up to and
 
including the first equivalent anchor; NSR piping in the vicinity of SR equipment; and supports.
 
The applicant used the UFSAR/USAR, the plant component database, P&IDs, DBD source
 
documents, Maintenance Rule documents, safety class boundary drawings, the CLB, and plant 2-17 and industry operating experience to identify NSR SSCs for inclusion within the scope of license renewal.As part of its evaluation of the 10 CFR 54.4(a)(2) criterion, the applicant prepared a topical report titled, "Scoping and Screening Aging Management Review NSR Piping (NSR Piping
 
Report)," to document the review and evaluation performed to identify those SSCs which met
 
10 CFR 54.4(a)(2). To facilitate that evaluation, the applicant divided the potential NSR/SR
 
interactions into four separate categories: NSR SSC Within the Vicinity of SR SSCs, NSR SSCs
 
Attached to SR SSCs, NSR SSCs Providing Functional Support to SR SSCs, and Fail-Safe
 
Components. Each category is discussed in detail below.  (1)NSR SSC Within the Vicinity of SR SSCs - The applicant's NSR Piping Report contains the rationale for inclusion of NSR piping attached to SR piping and NSR piping located
 
within the vicinity of SR piping. The piping effects considered by the applicant included
 
spray, flooding, pressure and temperature rise, pipe whip, and jet impingement. The
 
applicant had utilized the preventative option as defined in NEI 95-10 and identified each
 
structure or area containing SR SSCs and NSR SSCs. The applicant then identified all
 
NSR piping systems located within areas containing SR SSCs which contained fluids.
 
The applicant then removed the NSR SSCs which contained air, gas, or oil from within
 
the scope of license renewal. The NSR SSCs that contained water or steam and were
 
within the vicinity of SR SSCs were determined to be within the scope of license
 
renewal. Discussion with the applicant indicated that a conservative definition of "in the vicinity" had been defined during the scoping process as "within the building, corridor, or floor." In
 
practice, the applicant had applied the scoping criteria to all NSR SSCs located within
 
the same building as SR SSCs (buildings identified as SR). In addition, the applicant had
 
provided an analysis, "Technical Basis for Materials-Environment Group Inputs to the
 
ConRAD Database" (the data base for equipment and components for NMPNS license
 
renewal project), which provided the basis for the exclusion of NSR oil-filled pipe within
 
the vicinity of SR SSCs, from the scope of license renewal. The plant analysis indicated
 
that there were no aging affects associated with oil-filled NSR piping systems based on
 
both plant and industry-wide experience.    (2)NSR SSCs Attached to SR SSCs - The original LRA states that for NSR SSCs attached to SR SSCs, the scope of the NSR piping system was extended beyond the
 
classification change to the first seismic anchor beyond the depicted class change. The
 
applicant determined that the piping between the depicted classification boundary and
 
the first seismic anchor was considered to be within the scope of license renewal. As a
 
result, for piping containing water or steam, the NSR portion within the scope of license
 
renewal extended beyond the depicted class change until no longer in the vicinity of SR
 
equipment or until the first seismic anchor was reached, whichever is furthest.
 
Paragraph 3.4.2.7 of LRG-02 states that for NSR SCs directly attached to SR SSCs, the
 
NSR piping and supports, up to and including the first equivalent anchor beyond the
 
NSR/SR interface, were within the scope of license renewal.
During the audit, the applicant indicated that this approach had been implemented by considering all NSR piping components within a building containing SR SSCs as within
 
scope of license renewal. However, the staff noted that the statement in the original
 
LRA, "extended beyond the depicted class change until no longer in the vicinity of SR 2-18 equipment or until the first seismic anchor is reached, whichever is furthest," had not been effectively implemented. The staff found that the applicant had not evaluated
 
beyond the vicinity of the SR SSCs (outside the building) to verify the seismic anchor (or
 
equipment acting as the seismic anchor) and had not verified that the appropriate
 
anchor/equipment had been included within the scope of license renewal.
In RAI 2.1-4(a), dated November 22, 2004, the staff stated that during the audit, it was noted that in some cases where NSR plant equipment provided a termination point for
 
NSR piping attached to SR piping, the NSR piping was placed within the scope of
 
license renewal, but the plant equipment (such as a heat exchanger) was not considered
 
to be within the scope of license renewal. For cases where an entire pipe run, including
 
both SR and NSR piping, are analyzed as part of the CLB to establish that it could
 
withstand DBE loads, the SRP-LR provides explicit scoping criteria. Specifically, SRP-LR Section 2.1.3.1.2 indicates that the scoping methodology include (1) the NSR
 
piping up to its anchors, and (2) the associated piping anchors as being within the scope
 
of license renewal under 10 CFR 54.4(a)(2). Because in some instances plant
 
equipment was used as a termination point for the NSR piping within the scope of
 
license renewal, this plant equipment appears to be equivalent to an associated piping
 
anchor as described in SRP-LR.
Therefore, the staff requested that the applicant provide additional information regarding the SR/NSR interface evaluation as follows: the definition of equivalent anchor that was
 
used for the purposes of the 10 CFR 54.4(a)(2) evaluation; the method used to identify
 
the first seismic anchor for NSR pipe attached to SR pipe, within the scope of license
 
renewal; confirmation that the NSR piping, associated plant equipment, and their
 
supports, up to and including the first seismic anchor, were within the scope of license
 
renewal and subject to aging management review; and how plant equipment identified
 
as the termination point for NSR piping was evaluated during the scoping process.
In its letter dated December 22, 2004, as supplemented by letter dated July 14, 2005, the applicant described the revised scoping methodology and complete re-scoping effort
 
that was applied to the 10 CFR 54.4(a)(2) criterion as a result of the questions resulting
 
from the staff's methodology audit. As part of those responses, the applicant stated, in
 
part, that the re-scoping was performed consistent with the guidance in NEI 95-10, Revision 5, except for those portions of the guidance with which the staff had taken
 
exceptions. For those cases, the applicant's scoping methodology followed the staff's
 
position rather than the NEI guideline. The applicant provided a revised Section 2.1.4.2
 
in its ALRA, which describes in detail the re-scoping effort associated with this criterion.
 
As a result of the re-scoping effort, the applicant included all NSR SSCs that are within
 
the boundaries of the equivalent anchor locations, including the equivalent anchors
 
themselves. As part of the ALRA, the applicant defined the equivalent anchor for each
 
unit consistent with the CLB for the plants; described the processes used to identify
 
each equivalent anchor location (including review of plant drawings and performance of
 
plant walk-downs), and ensured that all NSR SSCs within the boundaries up to and
 
including the equivalent anchor were identified and included within the scope of renewal.
 
The staff verified that the ALRA description was consistent with the prior response to the
 
RAI and the results of the staff's audit of the scoping and screening methodology. On the
 
basis of the supplemental information provided by the applicant in response to the staff's
 
RAI, and the incorporation of that information into the ALRA, the staff's concern
 
described in RAI 2.1-4(a) is resolved.
2-19  (3)NSR SSCs Providing Functional Support to SR SSCs - The staff determined that LRG-02, "License Renewal Scoping and Screening," paragraph 3.4.3.2, stated that
 
malfunctions of NSR equipment that result in a challenge to SR equipment (where the
 
SR function is maintained) is not within the scope of license renewal.
In RAI 2.1-4(b), dated November 22, 2004, the staff requested that the applicant provide the basis for this position and all applications of this position during the scoping process.
In its responses, by letter dated December 22, 2004, as supplemented by letter dated July 14, 2005, the applicant stated that its scoping methodology was revised and did not
 
use the "NSR Safety Systems and Components (SSCs) which Functionally Interact with SR SSCs" criterion from NEI 95-10, Revi sion 4, to exclude from scope any NSR SSCs that could inhibit an SR SSC from performing its intended functions. As a result of this
 
effort, NMP now includes all NSR SSCs that are within the boundaries of the equivalent
 
anchors (including the equivalent anchor) within the scope of license renewal and
 
subject to an AMR. The original LRA Section 2.1.4.2 was revised, as reflected in the
 
ALRA, to describe the methodology used in the NMP NSR re-scoping effort. The staff
 
verified that the ALRA description was consistent with the prior response to the RAI, and
 
the results of the staff's audit of the scoping and screening methodology. On the basis of
 
the supplemental information provided by the applicant in response to the staff's request
 
for information, and the incorporation of that information into the ALRA, the staff's
 
concern described in RAI 2.1-4(b) is resolved.  (4)Fail-Safe Components - In RAI 2.1-4(c), dated November 22, 2004, the staff stated that LRG-02, "License Renewal Scoping and Screening," paragraph 4.1.2, stated that
 
fail-safe components are components whose failure (through interaction with the failed
 
NSR SSC) cannot prevent the accomplishment of an SR function since the NSR SSC
 
causes the SR SSC to attain a fail-safe state. Therefore, the staff requested that the
 
applicant provide the basis for this position and all applications of this position during the
 
scoping process.
In its responses by letter dated December 22, 2004, as supplemented by letter dated July 14, 2005, the applicant stated that based on the staff's audit, its scoping
 
methodology was revised to ensure that all NSR SSCs within the vicinity of SR SSCs
 
were included within the scope of renewal regardless of whether the SR SSC was active
 
or passive. As a result, the applicant reviewed its scoping results and verified that it did
 
not exclude any NSR SSCs with potential for interaction with SR SSCs based on the
 
fail-safe logic. The staff verified that the ALRA description was consistent with the prior
 
response to RAI 2.1-4(c), and the results of the staff's audit of the scoping and screening
 
methodology. On the basis of the supplemental information provided by the applicant in
 
response to the staff's request for information, and the incorporation of that information
 
into the ALRA submittal, the staff found that the applicant has adequately addressed the
 
staff's request for additional information. Therefore, the staff's concern described in
 
RAI 2.1-4(c) is resolved.
To provide additional assurance that the applicant adequately implemented its NSR scoping methodology, the staff reviewed a sample of the license renewal scoping results for the
 
FW/HPCI system. The staff verified that the applicant had identified and used pertinent
 
engineering and licensing information to identify the SSCs required to be within the scope of
 
license renewal in accordance with the 10 CFR 54.4(a)(2) criteria.
2-20 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 meeting the scoping criteria of 10 CFR 54.4(a)(2) was adequate.
Application of the Scoping Criteria in 10 CFR 54.4(a)(3). In part, 10 CFR 54(a)(3) requires that the applicant consider all SSCs relied on in safety analyses or plant evaluations to perform a
 
function that demonstrates compliance with the regulations for fire protection, EQ, PTS, ATWS, and SBO to be within the scope of license renewal.
The applicant documented its methodology for performing the scoping of SSCs in accordance with 10 CFR 54.4(a)(3) in implementation procedures LRG-01 and LRG02 and the NERs
 
developed by the applicant for certain regulated events for the applicable NMP unit.
The applicant performed the initial scoping for regulated events by evaluating CLB information relevant to each regulated event to identify whether the structure or system met the scoping
 
criteria of 10 CFR 54.4(a)(3). For ATWS and SBO, the applicant developed an NER describing
 
the relevant 10 CFR Part 54 requirements, a functional description of the implementation of that
 
requirement at the NMPNS, specific inform ation regarding systems and components credited for the event, the process to identify the scoping boundaries associated with the systems credited, the intended functions applicable to the requirement, information on how to record the results of
 
the evaluation in the license renewal database and appropriate MEL, a list of CLB information
 
sources used for the analysis, and a list of systems and components determined to be within
 
scope for the given regulated event.
By letter dated April 1, 2002, the staff provided guidance on the scoping of equipment relied on to meet the requirements of the SBO rule, 10 CFR 50.63. In this letter, the staff noted that, consistent with the requirements specified in 10 CFR 54.4(a)(3) and 10 CFR 50.63(a)(1), 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 SBO rule. In the original LRA and
 
ALRA Section 2.1.4.3.5, the applicant stated that based on the guidance in the April 1, 2002, letter for SBO recovery, an additional evaluation was performed at NMP to determine, and bring
 
within the scope of license renewal, components credited for recovery of the offsite power
 
system. For each of the systems credited fo r SBO recovery, a scoping/screening report was developed. Additionally, an AMR was performed fo r all long-lived, passive structures and components within these systems. The scoping effort identified structures and components of
 
the offsite power system for each plant requir ed to restore power from the onsite switchyard down to the SR busses in the plant. The applicant also stated that the plant offsite power
 
system and these structures and components were classified as satisfying the criteria in
 
10 CFR 54.4(a)(3) and were included within the scope of license renewal. The staff determined
 
that the applicant's approach to scoping SSCs relied on to demonstrate compliance with the
 
SBO rule was consistent with the staff's April 1, 2002, interim guidance.
For EQ, the master list of EQ components is deta iled in each unit's MEL. Systems that contain components identified in the EQ MEL, as defined by 10 CFR 50.49, are within the scope of
 
license renewal.For fire protection, NMP1 UFSAR Sections X.10A, "Fire Hazards Analysis;" X.10B, "SafeShutdown Analysis;" and X.K, "Fire Protection Program;" and NMP2 USAR Section 9.5.1, "Fire
 
Protection Systems," describe the station fire protection and post-fire safe shutdown equipment.
2-21 Fire protection, detection, mitigation, confinement, and safe shutdown equipment used at the station were reviewed during the scoping process.
Evaluations were performed on equipment needed to meet the fire protection requirements of Appendix A to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection for
 
Nuclear Power Plants," as well as those needed to meet 10 CFR 50, Appendix R and
 
10 CFR 50.48. These evaluations were used as fire protection scoping basis documents.
 
Structures and systems that contain components relied on to protect SR structures and
 
components and equipment required to mitigate offsite release from a fire or explosion are
 
within the scope of license renewal.
SRP-LR, Section 2.1.3.1.3, "Regulated Events," states that all SSCs that are relied upon in the plant's CLB (as defined in 10 CFR 54.3), plant-specific experience, industry-wide experience (as
 
appropriate), and safety analyses or plant evaluations to perform a function that demonstrates
 
compliance with NRC regulations identified under 10 CFR 54.4(a)(3), are required to be
 
included within the scope of the 10 CFR Part 54. As part of the original LRA review, the staff
 
evaluated the scope and depth of the applicant's document review to provide assurance that the
 
scoping methodology considered all SSC intended functions.
During the scoping and screening methodology audit, the applicant identified several technical position papers as a documentation source for license renewal scoping under
 
10 CFR 54.4(a)(3). In reviewing the original LRA, scoping and screening implementation
 
procedures, and evaluation of the feedwater system during the audit, the staff was informed by
 
the applicant that two technical position papers (ATWS and SBO) had not been adequately
 
reviewed and incorporated into the original LRA during its verification activities. This
 
discrepancy was identified by the applicant during the audit and documented in
 
CR-NM-2004-4466, dated September 30, 2004. CR-NM-2004-4466 states that the original LRA
 
Section 2.3.4.B.3 is incomplete because it does not reference an SBO event in the description
 
of why components in the NMP2 feedwater system are within the scope of license renewal.
 
CR-NM-2004-4466 also states that an extent of condition review is necessary to determine
 
whether there are similar instances affecting ot her system descriptions in the original LRA.
RAI 2.1-5, dated November 22, 2004, requested that the applicant describe the methodology used to develop technical position papers and specifically describe the actions taken to ensure
 
that both NMP1 and NMP2 license renewal scoping and screening reports adequately address
 
the new ATWS and SBO DBDs, as well as any potentially affected the original LRA sections.
In its response, by letter dated January 31, 2005, the applicant stated, in part, that the technical position papers used at NMP are controlled in accordance with engineering administrative
 
procedure NEP-DES-02, "Engineering Evaluat ions." The general methodology employed involves the preparation of the engineering evaluation, a technical review or design verification, and approval by the responsible supervisor. The pr eparer is directed to "Perform the evaluation and document in sufficient detail to allow a technically qualified reviewer/design verifier to
 
understand the purpose, inputs, evaluation criteria, assumptions, method, references, and
 
conclusions of the evaluation, and to conclude adequacy without recourse to the originator."
 
Design verification is required when the evaluat ion involves SR systems, structures, or components. The evaluation is documented as an NER. This administrative procedure also applies to the review and acceptance of vendor-supplied documents. These documents also
 
require a review and approval by NMP prior to use. However, as noted above, these two 2-22 technical position papers (ATWS and SBO) were not reviewed and approved for use. It is this error that led to the apparent discrepancy with the feedwater system described above.
In response to the finding, the applicant performed additional reviews to ensure that all the required NMP2 SCs were properly identified within the scope of license renewal and to compare
 
the systems listed in the original LRA to those identified in the approved engineering reports. As
 
a result of this comparison, the applicant determined that the original LRA Section 2.3.4.B.3, "NMP2 Feedwater System," did not need to be identified as within scope for the SBO regulated
 
event since the feedwater components credited for SBO (reactor coolant/containment isolation
 
valves) were already properly included in the or iginal LRA Section 2.3.2.B.5, "NMP2 Primary Containment Isolation System." This system in cludes the reactor coolant/containment isolation valves for all systems and is properly credit ed for being within scope for the SBO regulated event. Therefore, the applicant determined that the apparent discrepancy identified during the
 
audit was determined to be incorrectly characterized.
However, during the review to ensure all systems were properly identified for the ATWS and SBO regulated events, the applicant discovered that the NMP2 common electrical system
 
should have been identified as within scope for the SBO regulated event. Therefore, ALRA
 
Section 2.5.B.4 was revised to also include the SBO regulated event as a criterion for this
 
system. On the basis of the supplemental description of the development and approval of technical position papers, and the review of the extent of condition of the apparent discrepancy, including the identification of the NMP2 common electrical system as within scope for the SBO
 
regulated event, and the incorporation of that information into ALRA Section 2.5.B.4, the staff's
 
concern described in RAI 2.1-5 is resolved.
The staff reviewed a sample of the license renewal database 10 CFR 54.4(a)(3) scoping results and discussed the methodology and results with the applicant's license renewal project
 
personnel. From the discussion, the staff concludes that the applicant had identified and used
 
pertinent engineering and licensing information to compile the SSCs required to be within scope
 
in accordance with the 10 CFR 54.4(a)(3) criteria.
On the basis of the above review and discussions with the applicant, the staff determined that the applicant's methodology for identifying systems and structures meeting the scoping criteria
 
of 10 CFR 54.4(a)(3) was adequate.
2.1.3.1.5  Plant-Level Scoping of Systems and Structures.
 
The applicant documented its methodology for performing the scoping of SSCs in accordance with 10 CFR 54.4(a) in implementation procedures LRG-01 and LRG-02. The applicant's
 
approach to system and structure scoping was consistent with the methodology described in the
 
original LRA and ALRA Section 2.1.2. Specifically, LRG-02 specified that the personnel
 
performing license renewal scoping use CLB docum ents and describe the system or structure including a list all functions that the system or structure is required to accomplish. Sources of
 
information regarding the CLB for systems included the USAR, DBDs, MEL database, Maintenance Rule scoping reports, control drawings, and docketed correspondence. The
 
applicant then compared identified system or structures function lists to the scoping criteria to
 
determine whether the functions met the scoping criteria of 10 CFR 54.4(a). The applicant
 
documented the results of the plant-level scoping process in accordance with Section 3.2.3 to
 
LRG-02. The database information included a description of the structure or system, a listing of 2-23 functions performed by the system or structure, information pertaining to system realignment (as applicable), identification of intended functions, the 10 CFR 54.4(a) scoping criteria met by the
 
system or structure, references, and the basis fo r the classification of the system or structure intended functions. During the scoping methodology audit, the staff reviewed a sampling of
 
scoping reports and concludes that the applicant's scoping results in the LR database and
 
scoping results reports contained an appropriate level of detail to document the scoping
 
process.
 
Conclusion. On the basis of a review of the original LRA and ALRA, 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 adequate. In particular, the staff determined that the applicant's
 
methodology reasonably identified systems and structures within the scope of license renewal
 
and their associated intended functions.
2.1.3.1.6  Component-Level Scoping
 
After the applicant had identified systems and structures within the scope of license renewal and their associated intended functions, a review was performed to identify the components of
 
each system and structure within the scope of license renewal that supported an intended
 
function. As described in the original LRA and ALRA Section 2.1.5, a component is considered
 
to be within the scope of license renewal if it fulfills a system intended function.
Mechanical Component Scoping. The original LRA and ALRA Section 2.1.5.1, "Mechanical Systems," and LRG-02 Section 3.6, "Component Scoping and Screening," provided the
 
applicant's proceduralized guidance for scoping mechanical system components. To identify
 
system components required to perform a syst em intended function, the applicant initially generated a listing of mechanical system components based on information derived from controlled system diagrams and the MEL. Proc edure LRG-02 discusses in detail how to (1) determine system boundaries, (2) indicate components within a specific flow path that are
 
required for performance of intended functions, and (3) determine and identify system and
 
interdisciplinary interfaces (e.g., mechanical/structural, mechanical/electrical, structural/electrical). The staff reviewed the results of the boundary evaluation and discussed
 
the process further with the applicant. The staff verified that mechanical system evaluation
 
boundaries were established for each system within the scope of license renewal. These
 
boundaries were determined by mapping the pressure boundary associated with system-level
 
license renewal intended functions onto the controlled system drawings. The applicant included
 
the mechanical component types in the scoping and screening database and the applicant
 
performed further review was performed to ensure all component types were identified. If a
 
component type was not already in the MEL, the component type was created for use in the
 
license database. A preparer and an independent reviewer performed a comprehensive
 
evaluation of the boundary drawings to ensure the completeness and accuracy of the review
 
results. The staff conducted detailed discussions with the applicant's license renewal project management personnel and reviewed documentation pertinent to the scoping process. The staff
 
assessed whether the applicant had appropriately applied the scoping methodology outlined in
 
the original LRA and implementation procedures and whether the scoping results were
 
consistent with CLB requirements. The staff determined that the applicant's proceduralized 2-24 methodology was consistent with the description provided in the original LRA and ALRA Section 2.1.5.1 and the guidance contained in SRP-LR, Section 2.1, and was adequately
 
implemented.
The staff reviewed the process of scoping for the FW/HPCI system. The staff verified that the applicant had identified and highlighted system P&IDs to develop the system boundaries in accordance with the procedural guidance. The applicant was knowledgeable about the process
 
and conventions for establishing boundaries as defined in the license renewal implementation
 
procedures. Additionally, the staff verified that the applicant had independently verified the
 
results in accordance with the governing procedures. Specifically, other LR personnel
 
knowledgeable about the system had independently reviewed the marked-up drawings to
 
ensure accurate identification of system intended functions. The applicant performed additional
 
cross-discipline verification and independent reviews of the resultant highlighted drawings
 
before final approval of the scoping effort.
On the basis of the above staff review regarding the applicant's detailed scoping implementation procedures and a sampling review of mechanical components scoping results for the FW/HPCI
 
system, the staff concludes that the applicant's methodology for identifying mechanical
 
components within the scope of license renewal met the requirements of 10 CFR 54.4(a).
Structural Component Scoping. The applicant performed its structural scoping in accordance with the methodology defined in CNS procedure LRG-02, "LR Scoping and Screening." The
 
procedure describes the source design documentation to be used for the evaluation of
 
structures and is used to evaluate plant structures and to determine their functions.
 
UFSAR/USAR, Maintenance Rule scoping results, design and license basis documents, regulatory requirements, the MEL, 10 CFR 50 Appendix B determinations, and plant drawings
 
were reviewed. From this review, a scoping report for each plant structure was developed. The
 
scoping report describes the functions for each structure and indicates the applicable
 
10 CFR 50.54(a)(1)-(3) criteria. Sections 2.4.A, 2.4.B, and 2.4.C of the original LRA and ALRA
 
provide a complete plant-specific list of structures within the scope of license renewal.
The staff conducted detailed discussions with the applicant's license renewal project management personnel and reviewed documentation pertinent to the scoping process. The staff
 
assessed whether the applicant had appropriately applied the scoping methodology outlined in
 
the original LRA and implementation procedure and whether the scoping results were
 
consistent with CLB requirements. Component supports, and fire stops and seals were binned
 
in separate structural commodity groupings. The staff reviewed scoping reports for the NMP1
 
reactor building and the NMP1 materials handling/heavy loads. In general, the staff determined
 
that the applicant's overall approach to license renewal structural scoping was adequate.
The staff reviewed the scoping procedure, discussed the structural scoping methodology with the applicant's cognizant engineers, and reviewed several plant structural scoping reports to
 
verify proper implementation of the scoping process for SCs. The staff determined that the
 
applicant's proceduralized scoping methodology was consistent with the description provided in
 
Section 2.1.4 of the original LRA and ALRA and the guidance contained in SRP-LR Section 2.1.
 
Based on these audit activities, the staff did not identify any discrepancies between the
 
methodology documented and the implementation results.
2-25 On the basis of a review of information contained in the original LRA and ALRA, the applicant's scoping implementation procedure, and a sampling review of SC scoping reports, the staff
 
concludes that the applicant's methodology for identifying SCs within the scope of license
 
renewal met the requirements of 10 CFR 54.4(a).
Electrical and I&C Component Scoping. SRP-LR Section 2.5.3.1, "Components Within the Scope of License Renewal," states that an applicant may use the plant spaces approach in
 
scoping electrical and I&C components. In the plant spaces approach, an applicant may
 
indicate that all electrical and I&C components located within a particular area are either within
 
or not within the scope of license renewal. The applicant did not choose the typical electrical
 
and I&C scoping approach, using instead an approach similar to that used for mechanical
 
systems and structures.
The staff reviewed NMP procedures LRG-01, "License Renewal Project Guidance," Revision 2, and LRG-02, "License Renewal Scoping and Screening," and determined that adequate
 
guidance was provided to the engineers performing the electrical and I&C license renewal
 
scoping process. SSCs were evaluated to determine whether they were within the scope of
 
license renewal using NMP licensing and design-basis information and regulatory requirements.
 
System descriptions were developed and intended functions were identified and documented in
 
ConRAD. Additionally, SSCs were evaluated to determine whether they provided a license renewal intended function. ConRAD was updated to reflect these conclusions. In unique cases, such as regulated events, NERs were developed to identify components required to support
 
these events. Because these documents we re developed late in the project, management deferred entering these components into ConRAD until the annual update. The majority of these
 
components have been entered into the NMP ME L. The components were evaluated by the electrical license renewal engineers, and passive, long-lived components were evaluated in an
 
AMR. This essentially completed the scoping process per LRG-02.
As part of the review, the staff noted that el ectrical commodities (i.e., cables, connectors, non-segregated bus, electrical penetrations, etc.) were identified and addressed separately from
 
the electrical system scoping evaluations. LRG-01, Section 3.2.2.2.1, stated that commodities are groupings of components that perform the same intended functions and may be associated
 
with many plant systems and structures. Standar d groupings of electrical commodities have been well established by prior license renewal applicants and emboddied in the industry
 
guidance on the preparation of the LRAs. A separate guideline, LRG-04, "Aging Management
 
Review of Electrical Commodities," was devel oped by the applicant to govern the evaluation of electrical commodities with respect to aging effects and management of those effects.
The applicant conducted a search of cable design and procurement specification documents, contracts, plant modification packages, controlled drawings, the plant equipment database, and
 
the electrical cable database (TRAC 2000) to February 21, 2006, identify all components
 
required to perform license renewal intended functions. The staff discussed the electrical
 
scoping methodology with the applicant's cognizant engineers, and reviewed several plant
 
electrical packages to verify proper implementation of the scoping process for electrical
 
components. The staff also compared a sample of electrical components identified in the
 
documentation to the electrical commodity list in the license renewal database to ensure
 
consistency.
2-26 In RAI 2.1-6, dated November 22, 2004, the staff stated that during the audit it noted that the applicant's engineering staff had an adequate understanding of the process used to scope
 
electrical and I&C components. However, the staff did identify an issue regarding the level of
 
detail in the associated procedures describing the scoping process. Specifically, the staff was
 
unable to determine the specific activities performed by the applicant's staff to identify the
 
applicable intended functions, plant electrical equipment required to perform those functions, and subsequent development of the electrical commodity list from which the aging management reviews were conducted. Therefore, the staff requested that the applicant provide a detailed
 
description of the methodology used for the scoping and screening of electrical and I&C
 
components.
In its response, by letter dated December 22, 2004, the applicant addressed the staff's request and provided (1) a detailed description of the process used to identify the intended functions, (2)
 
equipment necessary to perform those functions, and (3) development of the electrical
 
commodities evaluated as part of the AMR. Specifically, the applicant clarified that the
 
methodology used to determine whether an electrical or I&C component supported an intended
 
function is described in project procedure LRG-02. Section 3.7 of LRG-02 requires that the
 
electrical or functional boundary be described for the intended functions of electrical systems.
 
This activity identifies a group of components that support a specific intended function. For
 
example, all electrical and I&C components that ar e identified on the EQ list for a system are the group of components that support the EQ intended function. Additionally, the applicant
 
described the process used to identify intended functions. Specifically, electrical systems were
 
identified based upon those defined in the MEL, UFSAR/USAR, and Maintenance Rule scoping
 
reports. The boundaries of each electrical system are based upon the components assigned to
 
the system as well as any descriptions in the UFSAR/USAR and/or other DBD. The MEL was
 
used as the design document/database that assigned components to a particular system. The
 
electrical systems and components defined in ME L were imported into the NMP license renewal database, ConRAD. The information contained in C onRAD for each electrical system included a system description, list of system functions, i dentification of which functions met any of the license renewal scoping criteria, a list of NMP documents from which this information was
 
derived, and any corresponding comments.
The staff found the above response acceptable because the applicant provided additional details regarding the process for identifying intended functions and those components
 
necessary to perform those functions. Therefore, the staff's concern described in RAI 2.1-6 is
 
resolved.On the basis of a review of information contained in the original LRA and ALRA, the applicant's detailed scoping implementation procedures, and a sampling review of electrical commodity
 
scoping results, the staff concludes that the applicant's methodology for identifying electrical
 
commodities within the scope of license renewal met the requirements of 10 CFR 54.4(a).2.1.3.2  Screening Methodology The staff reviewed the methodology used by the applicant to determine whether mechanical, structural, and electrical and I&C components within the scope of license renewal would be
 
subject to further aging management review. The applicant provided the staff with a detailed
 
discussion of the processes used for each disci pline and provided administrative documentation that described the screening methodology. The staff also reviewed the screening results reports 2-27 for the FW/HPCI system and reactor building. The staff noted that the applicant's screening process was performed in accordance with its written requirements and was consistent with the
 
guidance provided in the staff's SRP-LR and NEI 95-10, Revision 5. The staff determined that
 
the screening methodology was consistent with the requirements of 10 CFR Part 54, and that
 
the screening methodology will identify SCs that meet the screening criteria of
 
10 CFR 54.21(a)(1).
The staff reviewed the screening methodology used by the applicant to determine whether mechanical, structural, and electrical components within the scope of license renewal would be
 
subject to further aging management evaluation. The applicant described its screening process
 
in the original LRA and ALRA Section 2.1.5. In general, the applicant's screening approach
 
consisted of evaluations to determine which in-scope structures and components were passive
 
and long-lived. Passive, long-lived structures and components were then subject to further
 
AMR.The staff evaluated the applicant's screening methodology against the criteria contained in 10 CFR 54.21(a)(1) and (2), using the review guidance contained in SRP-LR Section 2.1.3.2, "Screening." According to 10 CFR 54.21(a)(1), the applicant's IPA must identify and list those
 
SCs subject to an AMR. Further, 10 CFR 54.21(a)(1) requires that SCs subject to an AMR shall
 
encompass those structures and components that (1) perform an intended function, as
 
described in 10 CFR 54.4, without moving parts or a change in configuration or properties, and
 
(2) are not subject to replacement based on a qualified life or specified time period. Per
 
10 CFR 54.21(a)(2), the applicant must describe and justify the methods used to meet the
 
requirements of 10 CFR 54.21(a)(1). In the original LRA and ALRA, the applicant described
 
screening methodologies that were unique to the mechanical, structural, and electrical
 
disciplines. The following sections describe the staff evaluation of the applicant's screening
 
approach for each of these disciplines.
2.1.3.2.1  Mechanical Component Screening
 
The staff reviewed the methodology used by the applicant to determine whether mechanical components within the scope of license renewal would be subject to further AMR. For
 
mechanical components, the applicant applied a screening process to each mechanical system
 
determined to be within the scope of license renewal in order to determine the types of
 
mechanical component commodities within the systems and the various materials and
 
environments to be considered in the AMR. The applicant then established evaluation
 
boundaries for the various plant mechanical systems, in order to further identify individual
 
mechanical components for review.
The listing of mechanical components was facilitated by combining these items into commodity groups from a review of each boundary drawing. The applicant placed these commodity groups
 
into the license renewal database and evaluated them in accordance with the screening criteria
 
described in LRG-02. The applicant provided the staff with a detailed discussion of the process
 
and provided screening report information from the license renewal database that described the
 
screening methodology, as well as a sample of the screening results reports for a selected
 
group of SR and NSR systems. The staff determined that the screening methodology was
 
consistent with the requirements of 10 CFR Part 54 and that implementation of the methodology
 
will identify SCs that meet the screening criteria of 10 CFR 54.21(a)(1).
2-28 During the audit, the staff reviewed the methodology used by the applicant to identify and list the mechanical components and commodities subject to an AMR, as well as the applicant's
 
technical justification for this methodology. The staff discussed the methodology and results
 
with the applicant's cognizant engineers and senior staff. The staff also examined the
 
applicant's results from the implementation of this methodology by reviewing the FW/HPCI system identified as within the scope of license renewal. The review included the evaluation
 
boundaries and resultant in-scope components, the corresponding component-level intended
 
functions, and the resulting list of mechanical components and commodity groups subject to an
 
AMR. The staff reviewed several summary screening reports that list a breakdown of the mechanical components within the scope of license renewal. Each report lists several categories, including
 
component type, whether an AMR was required, material, and an extensive comment section.
The staff also reviewed a sample of the mechanical drawing packages assembled by the
 
applicant and discussed the process and results with the cognizant engineers who performed
 
the review. The staff did not identify any discrepancies between the methodology documented
 
and the implementation results.
Conclusion. On the basis of a review of the original LRA and ALRA, the scoping and screening implementation procedures, and a sampling review of system and screening results, the staff determined that the applicant's mechanical component screening methodology was consistent
 
with the guidance contained in the SRP-LR and was capable of identifying those passive, long-lived components within the scope of license renewal that are subject to an AMR.
2.1.3.2.2  Structural Component Screening
 
The staff reviewed the methodology used by the applicant to determine whether structures within the scope of license renewal would be subject to further AMR. For structures, the
 
applicant determined the types of structural elements utilized and the various materials and
 
environments to be considered in the AMR. Gener ally, the boundary for a structure is the entire building including base slabs, foundations, walls, beams, slabs, and steel superstructure. A
 
listing of all the SCs that exist in each plant structure was developed identifying the various
 
types of structural elements, materials, and environments. The applicant created a database to
 
compile the results. The database identifies each individual SCs and indicates whether the SC
 
is subject to AMR. Each SC is identified as a component (e.g., door, gate, anchor support, strut, fastener, or siding) or as a material (e.g., concrete, polymer, or steel). From this review a
 
screening report for each plant structure was developed.
The listing of structural elements was facilitated by placing component supports, and fire stops and seals in separate commodity groups. The applicant provided the staff with a detailed
 
discussion describing the screening methodology, as well as the screening reports for a
 
selected group of structures. The staff determined that the screening methodology was
 
consistent with the requirements of 10 CFR Part 54 and that implementation of the methodology
 
will identify SCs that meet the screening criteria of 10 CFR 54.21(a)(1).
During the audit of the applicant's license renewal screening process, the staff reviewed the methodology used by the applicant to identify and list the SCs and structural commodities
 
subject to an AMR, as well as the applicant's technical justification for this methodology. The
 
staff discussed the methodology and results with the applicant's cognizant engineers and senior 2-29 staff. The staff also examined the applicant's results from the implementation of this methodology by reviewing a sample of NMP1 plant structures identified as being within the
 
scope of license renewal. The review included the evaluation of in-scope components, the
 
corresponding component-level intended functions, and the resulting list of SCs and structural
 
commodity groups subject to an AMR.
The staff reviewed several screening reports that list a breakdown of the SCs within the scope of license renewal. The reports reviewed by the staff included those for the NMP1 reactor
 
building and NMP1 materials handling/heavy loads. The staff also discussed the process and
 
results with the applicant. The staff did not identify any discrepancies between the methodology
 
documented and the implementation results.
Conclusion. On the basis of a review of the original LRA and ALRA, the scoping and screening implementation procedures, and a sampling review of structural screening results, the staff
 
determined that the applicant's SC screening methodology was consistent with the guidance
 
contained in the SRP-LR and was capable of identifying those passive, long-lived components
 
within the scope of license renewal that are subject to an AMR.
2.1.3.2.3  Electrical and I&C Component Screening
 
The staff reviewed the methodology used by the applicant to determine whether electrical components within the scope of license renewal would be subject to further AMR. For electrical
 
components, the applicant applied a screening process by identifying electrical commodities
 
within electrical systems. The LRA engineers i dentified all electrical and I&C component types in use at NMPNS based on the listing provided by Appendix B to NEI 95-10, NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Electric Power Research Institute (EPRI)
 
Electrical Handbook, and from a review of plant documents, controlled drawings, the plant
 
equipment database, and cable database. All passive, long-lived electrical components were
 
evaluated as commodities regardless of the system or structure in which they reside in the MEL.
As a result, the electrical systems only contain active components that are not subject to AMR.
 
An AMR was then conducted on a commodity basis for the entire population of passive, long-lived components. Identification of individual components that perform intended functions
 
was not performed. The passive electrical and I&C component commodity groups at NMPNS was based on a review of the UFSAR/USAR, the MEL, DBDs, previous LRAs, and NEI 95-10.
The applicant's list of electrical and I&C commodity groups included cables and connectors (including splices, connectors, terminal blocks, and fuse holders); non-segregated/switch yard
 
bus; containment electrical penetrations; and switchyard components.
The interface of electrical and I&C components with other types of components, and the assessments of these interfacing components, are provided in the appropriate mechanical or
 
civil structural sections. For example, the assessment of electrical racks, panels, frames, cabinets, cable trays, conduits, and their supports is provided in the civil/structural assessment section of the original LRA.
Components with unique identification numbers in the MEL that are identified as part of a system, but are defined as part of a commodity , are not addressed as part of the system. They do not appear on the list of components for that system in the system scoping and screening report. Commodities are treated generically, and a list of unique identification numbers from the 2-30 MEL that make up a commodity is not provided unless noted otherwise. In this way, components are moved from their act ual systems to commodity groups.
The staff discussed the methodology and results with the applicant's cognizant engineers and senior staff. The staff also examined the applicant
's results from the implementation of this methodology by reviewing several electrical
/I&C commodity reports and samples from the license renewal database. The review verified that the applicant's staff had consistently applied
 
the screening criteria to identify those electrical/I&C commodity groups subject to an AMR. The
 
staff determined that the NMPNS electrical screening process was consistent with criteria in
 
10 CFR 54.21(a)(1)(ii) and excluded those components or commodity groups that are subject to
 
equipment qualification requirements. The staff did not identify any discrepancies between the
 
methodology documented and the implementation results.
The staff also reviewed the applicant's approach to scoping and screening of electrical fuse holders. In license renewal ISG-5, "Identification and Treatment of Electrical Fuse Holders for
 
License Renewal," dated March 10, 2003, the staff stated that, consistent with the requirements
 
specified in 10 CFR 54.4(a), fuse holders (including fuse clips and fuse blocks) are considered
 
to be passive electrical components. Fuse holders would be scoped, screened, and included in
 
the AMR in the same manner as terminal blocks and other types of electrical connections that
 
are currently being treated in the process. This staff position applies only to fuse holders that
 
are not part of a larger assembly, but support SR and NSR functions in which the failure of a
 
fuse precludes a safety function from being accomplished (10 CFR Part 54.4(a)(1) and(2)). As
 
described in the original LRA and ALRA Section 2.1.6.5, "Identification and Treatment of
 
Electrical Fuse Holders for License Renewal," fuse holders (including fuse clips and fuse
 
blocks) are passive, long-lived electrical components that are within the scope of license
 
renewal and subject to an AMR as part of the cables and connections commodity. Additionally, NMPNS credits the Fuse Holder Inspection Program for identifying potential age-related
 
degradation for fuse holders. The staff determined that this was consistent with the ISG.
Conclusion. On the basis of a review of the original LRA and ALRA, the scoping and screening implementation procedures, and a sampling review of electrical system screening results, the staff determined that the applicant's electrical and I&C screening methodology was consistent
 
with the guidance contained in SRP-LR and was capable of identifying passive, long-lived
 
components within the scope of license renewal that are subject to an AMR.
2.1.3.2.4  Consumables
 
Paragraph 3.1.2.4 of procedure LRG-01, "License Renewal Project Guidance," Revision 2, discusses consumables. Paragraph 3.1.2.4.2 states that structural sealants should be identified
 
as subcomponents, and if they are determined to perform an intended function in support of a
 
larger structure, they must be within the scope of license renewal and subject to AMR. The staff
 
reviewed the screening report for the NMP1 reactor building and noted that structural sealants (e.g., neoprene, calking, and urethane) were identified as a component within the scope of
 
license renewal and subject to an AMR.
2.1.3.2.5  Plant Insulation 2-31 The staff's review of the original LRA Section 2.1 identified an area in which additional information was necessary regarding plant insulation 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 2.1-7, dated November 22, 2004, the staff stated that during the audit the applicant was unable to adequately describe the evaluation performed to determine whether any insulation
 
installed in the plant was required to support any system intended functions identified during the
 
scoping process. Therefore, the staff requested that the applicant describe any intended
 
functions performed by insulation or the basis for determining that insulation (e.g. piping
 
insulation) did not meet the scoping criteria described in 10 CFR 54.4(a)(1), (a)(2) or (a)(3).
In its response, by letter dated January 31, 2004, the applicant stated, in part, that an evaluation of thermal insulation used at NMP1 and NMP2 was performed to determine whether plant
 
insulation was credited for performing any license renewal functions per 10 CFR 54.4(a)(1), (2),
or (3). The applicant also provided a discussion of each scoping criteria and an evaluation of
 
plant insulation with respect to each. Based on this review, the only intended function to meet
 
the license renewal scoping criteria was fire wrap, used for fire protection, which meets
 
10 CFR 54.4(a)(3) and is included within the scope of license renewal. Specifically, these
 
structural steel fire protection coatings are within the scope of license renewal and subject to an
 
AMR. They are included as component type, "Fire Wrap in Air," in ALRA Table 2.4.C.2-1. The
 
AMR of the fire wrap is addressed in ALRA Section 3.5.2.C.2 and Table 3.5.2.C-2.
Conclusion. On the basis of the supplemental information provided by the applicant which describes the analysis of plant insulation in response to RAI 2.1-7, and the incorporation of that
 
information into the ALRA submittal, the staff found that the applicant has adequately addressed
 
the staff's concern.
 
====2.1.4 Evaluation====
Findings The staff's review of the information presented in the original LRA and ALRA Section 2.1, the supporting information in the scoping and screening implementation procedures, calculations
 
and reports, and the information presented during the scoping and screening audit formed the
 
basis of the staff's safety determination. The staff verified that the applicant's scoping and
 
screening methodology was consistent with the requirements of 10 CFR Part 54. On the basis
 
of this review, the staff concludes that there is reasonable assurance that the applicant's
 
methodology for identifying the SSCs within the scope of license renewal and the structures and
 
components requiring an AMR is consistent with the requirements of 10 CFR 54.4 and
 
10 CFR 54.21(a)(1).
2.2  Plant-Level Scoping Results
 
====2.2.1 Introduction====
In ALRA Section 2.1, the applicant described the methodology for identifying the NMPNS SSCs within the scope of license renewal. In ALRA Section 2.2, the applicant used the scoping
 
methodology to determine which of the SSCs are required to be included within the scope of
 
license renewal. The staff reviewed the plant-level scoping results to determine whether the
 
applicant had properly identified all plant-level systems and structures relied upon to mitigate
 
DBEs, as required by 10 CFR 54.4(a)(1), or whose failure could prevent satisfactory 2-32 accomplishment of any of the SR functions, as required by 10 CFR 54.4(a)(2), as well as the systems and structures relied on in safety analyses or plant evaluations to perform a function required by one of the regulations referenced in 10 CFR 54.4(a)(3).2.2.2  Summary of Technical Information in the Amended Application In ALRA Tables 2.2.-1 and 2.2-2, the applicant provided a list of the plant systems, structures, and commodities for NMP1 and NMP2, identifying those systems, structures, and commodities that are within the scope of license renewal. Based on the DBEs considered in the plant's CLB, other CLB information relating to NSR systems and structures, and certain regulated events, the
 
applicant identified those plant-level systems and structures that are within the scope of license
 
renewal, as defined by 10 CFR 54.4.
In the ALRA Section 2 tables that identify the component types requiring an AMR for the various systems, the applicant, on several occasions, listed "NSR Piping, Fittings, and Equipment" as a
 
component type. This component type was introduced to incorporate the results from
 
10 CFR 54.4(a)(2) scoping, and it was described in the system description sections as "NSR
 
Piping Fittings and Equipment Containing Liquid" in the buildings that were identified in each
 
ALRA section. The SSCs making up this component type thus varied from system to system.
In the ALRA, the applicant revised the methodology used to determine the NSR SSCs that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(2).
 
The applicant revised the LRA sections and tables where applicable to identify each NSR
 
system or NSR portion of an SR system that is within the scope of license renewal. In conjunction with this change, the applicant also identified the specific NSR component types
 
and intended function(s) and made them consistent with the standardized list of intended
 
functions in SRP-LR and NEI 95-10. The component type, "NSR Piping, Fittings, and
 
Equipment," and its associated intended function of, "Prevent Failure from Affecting SR
 
Equipment," is no longer used in the NMP original LRA, and this change is reflected in the
 
applicable ALRA sections.
In the ALRA, the applicant also revised LRA Section 2.1.4.2, "Non-Safety Related Criteria Pursuant to 10 CFR 54.4(a)(2)," to provide a detailed description of the NSR scoping criteria. As
 
a result of the staff screening and methodology audit, the applicant implemented a revised
 
spatial methodology in addressing systems meet ing 10 CFR 54.4(a)(2), 4 mechanical systems for NMP1 and 10 mechanical systems for NMP2, that were previously identified in the original LRA Tables 2.2-1 and 2.2-2 as not being within scope were brought within the scope of license
 
renewal. In addition, three mechanical systems for NMP2 that were previously identified in the original LRA Table 2.2-2 as within scope were deleted from the scope of license renewal.
 
====2.2.3 Staff====
Evaluation In ALRA Section  2.1, the applicant described its methodology for identifying the systems, structures, and commodities that are 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, as shown in ALRA Tables 2.2-1, "NMP1 Plant
 
Level Scoping Results," and 2.2-2, "NMP2 Plant Level Scoping Results," to confirm that there
 
were no omissions of plant-level systems and st ructures within the scope of license renewal.
2-33 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 falling within the scope of license
 
renewal to verify whether the systems and stru ctures have any intended functions that would require their inclusion within the scope of license renewal. The staff's review of the applicant's
 
implementation was conducted in accordance with the guidance described in SRP-LR
 
Section 2.2, "Plant-Level Scoping Results."
The staff sampled the contents of the UFSAR/USAR based on the systems, structures, and commodities listed in ALRA Tables 2.2-1 and 2.2-2 to determine whether there were 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 within the scope of license renewal.
In reviewing ALRA Section 2.2, the staff identified areas in which additional information was necessary to complete the evaluation of the applicant's plant-level scoping results. Therefore, the staff issued RAIs concerning each specific issue to determine whether the applicant
 
properly applied the scoping criteria of 10 CFR 54.4 and the screening criteria of
 
10 CFR 54.21(a)(1). The following paragraphs describe the staff's RAIs and the applicant's
 
related responses.
In RAI 2.2-1, dated November 19, 2004, the staff stated that during the original LRA review the staff identified license renewal drawings in multiple original LRA sections that all, or in part, appeared to conflict with the original LRA. The staff discussed the apparent discrepancies with
 
the applicant to determine whether they were intentional or editorial in nature. The applicant
 
identified a large number of the discrepancies as editorial and agreed that corrections to the
 
original LRA or LR drawings would be required to correct the discrepancies.
In order to complete its review, the staff requested that the applicant correct the LR drawings for the following original LRA sections in which the apparent discrepancies were identified: 2.3.3.A.42.3.3.A.82.3.3.A.162.3.3.A.172.3.3.A.202.3.3.A.212.3.3.A.232.3.3.B.12.3.3.B.132.3.3.B.142.3.3.B.152.3.3.B.21 2.3.3.B.252.3.3.B.272.3.3.B.292.3.3.B.302.3.3.B.312.3.4.A.5
 
2.3.4.B.2 The staff also requested that the applicant identify those LR drawings that have been corrected and the corrections made to the drawings.
In its response, by letter dated December 22, 2004, the applicant stated that for each of the original LRA sections identified in RAI 2.2-1 answers have been provided to each staff's specific
 
question from those original LRA sections that address drawing issues. The responses to those
 
specific RAIs identify where there are drawing anomalies and whether a change to the original
 
LRA was required. It is the applicant's understanding that the original LRA, the docketed LRA
 
supplemental letters, and the docketed responses to staff RAIs serve as the bases for the
 
results of the staff's review. The drawings that were submitted concurrent with, but separate
 
from, the original LRA were provided as information-only aids to assist the NRC reviewers with
 
their evaluations. The applicant did not intend them to be part of the formal application.
 
Therefore, the applicant does not intend to revise these drawings and resubmit them as part of
 
the original LRA review process.
2-34 The applicant further stated that it does plan, upon completion of the original LRA review and approval process, to update the LR drawings, the scoping and screening reports, the AMR
 
reports, and the program basis documents, to be consistent with the content of the final staff
 
safety evaluation. With the exception of the program basis documents, which will be controlled documents, the remaining documents, including the drawings, will not be controlled but will be
 
archival documents maintained within the NMPNS documentation and drawing system for historical reference purposes.
Based on its review, the staff found the applicant's response to RAI 2.2-1 acceptable because the applicant has adequately addressed discrepancies associated with the identified LRA
 
sections. The information to resolve these discrepancies were included in the response to
 
applicable RAIs. Therefore, the staff's concern described in RAI 2.2-1 is resolved.
In RAI 2.2-2, dated November 19, 2004, the staff stated that during the original LRA review, the staff identified in multiple LRA sections, apparent omissions of component types that were
 
described in the original LRA, from the LRA component type tables. The staff discussed the
 
apparent omissions of component types from t he LRA component type tables with the applicant to determine whether they were intentional or editorial in nature. The staff noted that during the
 
original LRA review the applicant agreed to describe where the following component types were
 
represented in the component type tables if they were intentionally omitted, and to include those component types in component type tables that had unintentionally omitted components.
Therefore, the staff requested in RAI 2.2-2 that the applicant explain how it represented the
 
following component types in the original LRA: flanges, bolting, orifices, tubing, vacuum
 
breakers, elbows, unions, tees, couplings, thermowells, compressors, reducers, caps, floor
 
drains, flexible hoses, expansion joints, vents, diffusers, manholes, and piping.
In its response, by letter dated December 22, 2004, the applicant provided the following summary of how each of the components identified in RAI 2.2-2, when subjected to AMR, were
 
represented in the AMR results sections of the original LRA:
* Flanges, tubing, elbows, unions, tees, couplings, reducers, caps, floor drains, vents, and piping were all included with the component type "Piping and Fittings."
* Bolting, where not specifically identifi ed as its own component type within a system, was included with the component for which it was a subcomponent. For example, it would be
 
included with component types "Piping and Fittings," "Pumps," "Valves," etc., as
 
applicable. In general, bolting was identified as its own component type within a system
 
when it was identified as a separate component type in the GALL Report for that
 
respective system. When not identified as its own component type, bolting was managed for aging based on its material in the applicable air environment.
* Orifices were identified as their own component type, as either "Orifices" or "Flow Elements." However, not all "Flow Elements" were orifices. The terms "Orifices" or "Flow
 
Elements" were used depending on how the components were called out in the plant
 
Mechanical Equipment List databases. The term "Flow Elements" was also used for
 
other types of flow measurement devices such as venturis.
* Vacuum breakers were included with the component type "Valves."
* Thermowells were included with "Piping and Fittings" when they were fabricated of the same material as the piping in which they were a subcomponent. If they were fabricated 2-35 of a different material than the piping in which they were a subcomponent, they were identified separately as a "Temperature Element."
* Compressors were identified as either "Pumps" or as a "Chiller" subcomponent.
* Expansion joints were included with the component type of "Bellows" or "Piping and Fittings."
* Flexible hoses were included with the component type of "Flexible Hoses," "Flex Hoses," or "Piping and Fittings."
* Diffusers were included with the component type of "Piping and Fittings" or "Structural Steel."
* Manways in large components such as tanks or heat exchangers are included with the component type in which they are a subcomponent, since consistent with that
 
component, they also serve as a pressure boundary and are typically fabricated of thesame material.
Based on its review, the staff found the applicant's response to RAI 2.2-2 acceptable because the applicant adequately explained how the component types in question are represented in the
 
AMR results sections of the original LRA. Therefore, the staff's concern described in RAI 2.2-2
 
is resolved.
The staff reviewed the changes described in the ALRA and evaluated them against the information in the original LRA, the RAIs stemming from the original LRA review, and their own
 
prior evaluation conclusions.
 
====2.2.4 Conclusion====
The staff reviewed ALRA Section 2.2, the applicant's responses to RAIs 2.2-1 and 2.2-2, and the supporting information in the UFSAR and USAR to determine whether any systems and structures within the scope of license renewal had not been identified by the applicant. The
 
staff's review did not identify any omissions. On the basis of this review, the staff concludes that
 
the applicant properly identified the systems and structures that are within the scope of license
 
renewal in accordance with 10 CFR 54.4.
 
===2.3 Scoping===
and Screening Results: Mechanical Systems This section documents the staff's review of the applicant's scoping and screening results for mechanical systems. Specifically, this secti on discusses the following mechanical systems for NMP1 and NMP2:
* reactor vessel, internals, and reactor coolant systems
* engineered safety features systems
* auxiliary systems
* steam and power conversion systems In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant identified and listed passive, long-lived system, structure, and com ponents (SSCs) that are within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its 2-36 methodology, the staff focused its review on the implementation results. This approach 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.
Staff Evaluation Methodology. The staff's evaluation of the information provided in the ALRA was performed in the same manner for all mechanical systems. The objective of the review was
 
to determine if the components and supporting structures for a specific mechanical system, that
 
appeared to meet the scoping criteria specified in 10 CFR Part 54, were identified by the
 
applicant as within the scope of license renewal, in accordance with 10 CFR 54.4. Similarly, the
 
staff evaluated the applicant's screening results to verify that all long-lived, passive components
 
were subject to an AMR in accordance with 10 CFR 54.21(a)(1).
Scoping. To perform its evaluation, the staff reviewed the applicable ALRA section and associated component drawings, focusing its review on components that had not been identified
 
as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the NMP1 UFSAR and NMP2 USAR, for each mechanical system to determine if the
 
applicant had omitted components with intended functions delineated under 10 CFR 54.4(a)
 
from the scope of license renewal. The staff also reviewed the licensing basis documents to
 
determine if all intended functions delineated under 10 CFR 54.4(a) were specified in the ALRA.
 
If omissions were identified, the staff requested additional information to resolve the
 
discrepancies.
Screening. Once the staff completed its review of the scoping results, the staff evaluated the applicant's screening results. For those systems and components with intended functions, the
 
staff sought to determine: (1) if the functions are performed with moving parts or a change in
 
configuration or properties, or (2) if they are subject to replacement based on a qualified life or
 
specified time period, as described in 10 CFR 54.21(a)(1). For those that did not meet either of
 
these criteria, the staff sought to confirm that these mechanical systems and components were
 
subject to an AMR as required by 10 CFR 54.21(a)(1). If discrepancies were identified, the staff
 
requested additional information to resolve them.
2.3A  NMP1 Scoping and Screening Results: Mechanical Systems2.3A.1  Reactor Vessel, Internals, and Reactor Coolant Systems In ALRA Section 2.3.1.A, the applicant identified the structures and components of the NMP1 reactor vessel, internals, and reactor coolant systems that are subject to an AMR for license
 
renewal.The applicant described the supporting structures and components of the reactor vessel, internals, and reactor coolant systems in the following sections of the ALRA:
* 2.3.1.A.1NMP1 reactor pressure vessel
* 2.3.1.A.2NMP1 reactor pressure vessel internals
* 2.3.1.A.3NMP1 reactor pressure vessel instrumentation system
* 2.3.1.A.4NMP1 reactor recirculation system
* 2.3.1.A.5NMP1 control rod drive system
* 2.3.1.A.6NMP1 reactor coolant pressure boundary components in other systems 2-37 The staff's review findings regarding ALRA Sections 2.3.1.A.1 through 2.3.1.A.6 are presented in SER Sections 2.3A.1.1 through 2.3A.1.6, respectively.2.3A.1.1  NMP1 Reactor Pressure Vessel 2.3A.1.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.A.1, the applicant described the reactor pressure vessel (RPV).
The NMP1 RPV contains and supports the reactor core, reactor internals, and the reactor
 
coolant/moderator. The RPV forms part of the reactor coolant pressure boundary (RCPB) and
 
serves as a barrier against leakage of radioactive materials to the drywell.
The RPV is a vertical, cylindrical pressure vessel with hemispherical heads. The cylindrical shell and hemispherical heads are fabricated from low alloy carbon steel that is clad on the interior
 
with weld overlay. The top head is secured to the vessel with studs and nuts and includes two
 
concentric sealings in the vessel head flange area to prevent reactor coolant leakage. The RPV
 
is supported by a steel skirt welded to the bottom head. The base of the skirt is continuously
 
supported by a ring girder and sole plate fastened to a concrete foundation, which carries the
 
load to the reactor building foundation slab.
The RPV contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RPV could potentially prevent the satisfactory
 
accomplishment of an SR function.
The RPV's intended functions within the scope of license renewal include the following:
* pressure boundary - maintains the integrity of the RCPB
* containment - provides a fission product containment barrier
* physical support - provides vertical and horizontal support for the core and other reactor vessel internals
* core cooling - together with the reactor vessel internals, provides a means to distribute coolant to the fuel assemblies located in the core and provides a floodable volume to at
 
least two-thirds core height following DBEs
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components In ALRA Table 2.3.1.A.1-1, the applicant identified the following RPV component types that are within the scope of license renewal and subject to an AMR:
* bottom head
* nozzles
* nozzle safe ends
* penetrations: core differential pressure, CRD stub tube, flux monitor, instrumentation, vessel drain
* support skirt and attachment welds
* thermal sleeves
* top head 2-38
* top head (closure studs and nuts)
* top head (flanges)
* top head (leak detection line)
* top head (nozzles)
* valves
* vessel shell (flange)
* vessel shells: beltline, lower shell, upper nozzle shell, upper RPV shell
* vessel shell welds (including attachment welds) 2.3A.1.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.A.1 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3, "Scoping and Screening Results: Mechanical Systems."
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
During the staff review it was noted that ALRA Table 2.3.1.A.1-1 does not list a thermal shield that provides shielding from gamma and neutron radiation for such SR SSCs as the reactor
 
vessel and the internals. Such shielding, which can reduce irradiation-induced embrittlement of
 
the vessel and/or the internals, is not a design feature of the NMP1 RPV nor of any boiling water
 
reactors (BWRs) manufactured by General Electr ic (GE); therefore, it is not appropriate to consider such a component in the NMP1 scoping evaluation.
The staff's review of original LRA Section 2.3.1.A.1 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
In RAI-2, dated November 17, 2004, the staff requested the applicant to provide additional information pertaining to the reactor recirculation nozzles, and thermal sleeves for core spray, feedwater, and CRD return line. In its response, by letter dated December 17, 2004, the
 
applicant stated that there are no low pressure coolant injection (LPCI) couplings installed in NMNP1. This response resolved the staff's concern described in RAI-2.
In RAI 2.3-1, dated October 11, 2005, the staff requested that the applicant indicate whether the liquid poison pressure nozzle is considered an RPV penetration requiring an AMR.
In its response, by letter dated October 28, 2005, the applicant indicated that the liquid poison pressure nozzle is part of the core differential pressure penetration. NMP1 utilizes a "pipe within
 
a pipe" design similar to many other older BWR designs. The liquid poison pressure nozzle is
 
considered a RPV penetration and is part of the license renewal scope, falling under the
 
"Penetrations: Core Differential Pressure" subset in ALRA Table 2.3.1.A.1-1. Therefore, the
 
staff's concern described in RAI 2.3-1 is resolved.
2-39 2.3A.1.1.3  Conclusion The staff reviewed the ALRA and the RAI responses to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that the applicant had
 
adequately identified the RPV components that are within the scope of license renewal, as
 
required by 10 CFR 54.4(a), and the RPV components that are subject to an AMR, as required
 
by 10 CFR 54.21(a)(1).2.3A.1.2  NMP1 Reactor Pressure Vessel Internals 2.3A.1.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.A.2, the applicant described the RPV internals. NMP1 RPV internals provide support for the core and other internal components, maintain fuel configuration (coolable geometry) during normal operation and accident conditions, and provide reactor
 
coolant flow distribution through the core.
The RPV internals consist of the components internal to the RPV. The main components are the reactor core (fuel, channels, control rods, and instrumentation), core shroud (including the
 
shroud support), core shroud stabilizers (shroud repair brackets and tie-rod assemblies), core
 
support, top grid, control rod guide tubes, feedwater sparger, core spray spargers, liquid poison
 
sparger and steam separator and dryer. All of the RPV internals, except the shroud support and
 
springs in the fuel assemblies, are fabricated from stainless steel. The shroud support plates, spaces, tie rods, head bolts, and associated welds are Inconel. The shroud support essentially
 
sustains all of the vertical weight of the core structure (except the fuel assembly weights
 
transmitted to the guide tube) and the steam separator assembly. Each guide tube, with its fuel
 
support casting, bears the weight of four fuel assemblies and rests on a control rod drive (CRD)
 
housing welded to the stub tube mounted on the vessel bottom head.
The RPV internals contain SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RPV internals could potentially prevent the
 
satisfactory accomplishment of an SR function.
RPV internals components subject to AMR are located inside the RPV and extend from the bottom head to the top guide (excluding the fuel assemblies and control rods). Additionally, the
 
steam dryer assembly is subject to an AMR.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* provides structural and/or functional support to SR equipment 2-40 In ALRA Table 2.3.1.A.2-1, the applicant identified the following RPV internals component types that are within the scope of license renewal and subject to an AMR:
* CRD assemblies (includes drive mechanism and housing)
* control rod guide tubes
* core plates and bolts
* core shroud
* core shroud head bolts and collars
* core shroud support structures: clamps, core plate spacers, support plates, support rings, support welds, tie rod assemblies
* core spray lines and spargers
* incore instrumentation dry tubes and guide tubes
* liquid poison spray line and sparger
* orificed fuel supports
* steam dryer assembly
* top guide 2.3A.1.2.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.A.2 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.1.A.2 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
In RAI-4, dated November 17, 2004, the staff noted that the steam separator assembly consists of a base into which are welded an array of standpipes, with a steam separator located at the
 
top of each standpipe. The staff requested that the applicant provide justification why these
 
standpipes and steam separators are not included within the scope of license renewal.
In its response, by letter dated December 17, 2004, the applicant stated that the steam separators and their standpipes are not included within the scope of license renewal, since they
 
are not SR components that perform a license renewal intended function, and referred to an
 
evaluation contained in Boiling Water Reactor Vessel Internals Project (BWRVIP)-06-A. Also, the staff was concerned about the possibility that failure of these components could prevent the
 
accomplishment of SR functions of nearby components (e.g., the creation of loose parts that
 
might hit and damage SR components). The staff noted that this consideration was also
 
addressed in BWRVIP-06-A, and the evaluation was accepted by the staff in letters dated 2-41 September 15, 1998, and September 16, 2003. Therefore, the staff's concern described in RAI-4 is resolved.
 
In RAI-5 dated November 17, 2004, the staff requested that the applicant indicate where the
 
feedwater sparger is identified as a vessel internal component requiring an AMR. In its
 
response, by letter dated December 17, 2004, the applicant indicated that this, too, was not
 
included within the scope of license renewal. The applicant stated that, per BWRVIP-06-A, "The
 
sole purpose of the feedwater spargers is to control thermal mixing and extend the life of the
 
vessel and internals. The failure of feedwater spargers or associated brackets would not
 
prevent injection of coolant makeup and are not required to safety shut down the reactor." On
 
this basis, the staff accepted the exclusion of the feedwater sparger from within the scope of
 
license renewal. Therefore, the staff's concern described in RAI-5 is resolved.
In RAI-7 dated November 17, 2004, the staff requested that the applicant indicate whether the core shroud stabilizers should be identified as reactor vessel internal components requiring
 
AMR. In its response, by letter dated December 17, 2004, the applicant stated that the core
 
shroud stabilizer components are part of the "Core Shroud Support Structures" (Tie Rod
 
Assemblies) listed in original LRA Table 2.3.1.A.2-1. The AMR for these components is
 
contained in original LRA Table 3.1.2.A-2. The staff reviewed the response and found that the
 
aging management of core shroud stabilizer is properly addressed. Therefore, the staff's
 
concern described in RAI-7 is resolved.
In RAI-8, dated November 17, 2004, the staff requested that the applicant indicate whether the core shroud vertical weld repair should be identified as a reactor vessel internal component
 
requiring AMR. In its response, by letter dated December 17, 2004, the applicant stated that the
 
core shroud vertical weld repair components are part of the "Core Shroud Support Structures" (Clamps) listed in original LRA Table 2.3.1.A.2-1. The AMR for these components is described
 
in original LRA Table 3.1.2.A-2. The staff reviewed the response and found that the aging
 
management of the core shroud vertical weld repair components are properly addressed;
 
therefore, the staff's concern described in RAI-8 is resolved.
In the RAI response, the applicant also verified that the liquid poison spray line and sparger are included in the scope of license renewal, and revised the original LRA Table 2.3.1.A.2-1
 
accordingly. The applicant also indicated that the core shroud stabilizer components (i.e., the tie
 
rod assemblies) and the core shroud vertical weld repair components are part of the core
 
shroud support structures.
2.3A.1.2.3  Conclusion
 
The staff reviewed the ALRA and RAI responses to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that the applicant had adequately
 
identified the RPV internals components that are within the scope of license renewal, as
 
required by 10 CFR 54.4(a), and the RPV internals components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3A.1.3  NMP1 Reactor Pressure Vessel Instrumentation System 2-42 2.3A.1.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.A.3, the applicant described the RPV instrumentation system. The NMP1 RPV instrumentation system monitors and transmits values for key reactor vessel operating
 
parameters during normal and emergency operations. This information is indicated on meters, chart recorders and hydraulic indicator units located in the control room, remote shutdown
 
panels and instrument rooms. The parameters monito red are reactor vessel temperature, water level and pressure, core differential pressure, core spray sparger differential pressure, and
 
reactor safety valve position. This system also provides control signals to various systems, such as the reactor protection, automatic depressurization, ATWS, feedwater/high pressure coolant
 
injection (FW/HPCI), and shutdown cooling systems.
The RPV instrumentation system consists of pi ping, valves, and excess flow check valves that provide a fluid path from the RPV to various instrumentation.
The RPV instrumentation system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the RPV instrumentation system performs
 
functions that support fire protection, EQ, ATWS, and SBO.
The intended function, within the scope of license renewal, is to provide pressure retaining boundary.In ALRA Table 2.3.1.A.3-1, the applicant identified the following RPV instrumentation system component types that are within the scope of license renewal and subject to an AMR:
* closure bolting
* condensing pots
* piping and fittings
* temperature equalizing columns
* valves 2.3A.1.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.A.3 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-43 2.3A.1.3.3  Conclusion The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the RPV instrumentation system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the RPV instrumentation system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.1.4  NMP1 Reactor Recirculation System 2.3A.1.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.A.4, the applicant described the reactor recirculation system. The NMP1 reactor recirculation system controls reactor pow er level by varying the reactor coolant flow. The reactor recirculation system is part of the RCPB and consists of five external loops. Each loop
 
draws suction from the downcomer annulus region of the RPV and discharges reactor coolant to
 
the RPV lower plenum. Each loop consists of a variable speed pump, blocking valves, bypass
 
line, and associated instrumentation. The reactor recirculation pumps are controlled by separate
 
variable frequency motor generator sets, each having associated controls and instrumentation.
 
Other systems that connect directly to the reac tor recirculation system piping are the emergency cooling system, shutdown cooling system, reactor water cleanup system and the samplingsystem.The reactor recirculation system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the reactor recirculation
 
system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the reactor recirculation system performs functions that support fire protection, ATWS, and
 
SBO.The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* provides structural support to attached SR piping and components In ALRA Table 2.3.1.A.4-1, the applicant identified the following reactor recirculation system component types that are within the scope of license renewal and subject to an AMR:
* closure bolting
* flow elements
* piping and fittings
* pumps
* pump seal flanges
* valves 2-44 2.3A.1.4.2  Staff Evaluation The staff reviewed ALRA Section 2.3.1.A.4 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.1.4.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the reactor recirculation system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the reactor recirculation system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.1.5  NMP1 Control Rod Drive System 2.3A.1.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.A.5, the applicant described the CRD system. The NMP1 CRD system changes core reactivity level by positioning the control rods within the reactor core in response
 
to manual control signals, and scrams the reactor in response to manual or automatic signals.
 
The system also provides high-pressure makeup to the RPV to compensate for leakage rates of
 
up to 25 gpm, or for break flows caused by certain small line breaks. The CRD system also provides water to the reactor vessel level instrumentation reference leg backfill system and to
 
the keep-full system for the emergency cooling system.
The CRD system consists of two redundant pumps, f ilters, strainers, control valves, hydraulic control units, CRD mechanisms, scram discharge volume, isolation valves and associated
 
piping, valves, controls and instrumentation. The normal water supply for the pumps is the
 
condensate system with backup supplies available from the condensate storage tanks and the
 
demineralized water storage tank. The discharge of each pump provides water directly to the
 
reactor level instrumentation reference leg ba ckfill system, emergency cooling system keep-full system and the CRD water filters. The CRD system also supplies cooling water to the CRD
 
mechanisms and charging water to the hydraulic control units. Drive water is provided to the
 
directional control valves, and the remaining water is provided directly to the RPV. Following a
 
reactor scram, the water discharged from the CRD mechanisms is collected in the scram
 
discharge volume.
2-45 The CRD system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the CRD system could potentially prevent the
 
satisfactory accomplishment of an SR function.
In addition, the CRD system performs functions that support fire protection, EQ, and ATWS.
The intended functions within the scope of license renewal include the following:
* provides filtration
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.1.A.5-1, the applicant identified the following CRD system component types that are within the scope of license renewal and subject to an AMR:
* accumulators
* closure bolting
* filters
* heat exchangers
* piping and fittings
* pumps
* tank
* valves 2.3A.1.5.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.A.5 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.1.A.5 identified an area in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAI as discussed below.
In RAI-16 dated November 17, 2004, the staff requested that the applicant indicate where CRD hydraulic control units, flow elements and indicators, pumps, and rupture discs should be
 
identified as control rod drive system component s requiring AMR. In its response, by letter 2-46 dated December 17, 2004, the applicant stated that each of the components listed in this RAI is within the scope of license renewal except flow indicators, which are considered active
 
components. The applicant further stated that original LRA Section 2.3.1.A.5 and
 
Table 2.3.1.A.5-1 address the CRD system for scoping and screening and for AMR, original
 
LRA Section 3.1.2.A.5 and Table 3.1.2.A.5 contains the hydraulic control units which are under
 
"Accumulators" component type. Furthermore, the applicant stated that flow elements and
 
pumps are included with the "NSR Piping, Fi ttings and Equipment" component type, and rupture disks are included with the "Valves" component type. The staff reviewed the applicant's
 
response and found that the components for CRD are properly addressed. Therefore, the staff's
 
concern described in RAI-16 is resolved
 
2.3A.1.5.3  Conclusion The staff reviewed the ALRA and RAI response to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the CRD system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the CRD system components that are
 
subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.1.6  NMP1 Reactor Coolant Pressure Boundary Components in Other Systems 2.3A.1.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.A.6, the applicant stated that the components requiring AMR that have RCPB functions have been maintained in the plant system to which they are normally assigned, rather than grouped with other RCPB components in the reactor vessel internals and reactor
 
coolant system. ALRA Table 2.3.1.A.6-1 pr esents a list of plant systems having RCPB components evaluated in the GALL Report as part of the reactor vessel, internals and reactor
 
coolant system.
For each of these systems, applicable system descriptions, USAR references, license renewal boundary diagram references, system intended functions, and complete listings of component
 
groups requiring an AMR are presented in the application section indicated in ALRA
 
Table 2.3.1.A.6-1. AMR results for RCPB components are presented in their sections as follows:
* NMP1 core spray system (ALRA Section 2.3.2.A.3)
* NMP1 emergency cooling system (ALRA Section 2.3.2.A.4)
* NMP1 feedwater/high pressure coolant injection system (ALRA Section 2.3.4.A.3)
* NMP1 liquid poison system (ALRA Section 2.3.3.A.11)
* NMP1 main steam system (ALRA Section 2.3.4.A.5)
* NMP1 reactor water cleanup system (ALRA Section 2.3.3.A.19)
* NMP1 sampling system (ALRA Section 2.3.3.A.20)
* NMP1 shutdown cooling system (ALRA Section 2.3.3.A.22) 2-47 2.3A.1.6.2  Staff Evaluation The staff reviewed ALRA Section 2.3.1.A.6 to determine whether there is reasonable assurance that the RCPB components in other systems components within the scope of license renewal and subject to an AMR have been identified in accordance with 10 CFR 54.4 and 54.21(a)(1).
 
The staff conducted its review in accordance with the guidance described in SRP-LR
 
Section 2.3 and is described below.
In conducting its review the staff selected system functions described in the UFSAR set forth in 10 CFR 54.4 to verify that components having intended functions were not omitted from the
 
scope of the rule. The staff also focused on components not identified as subject to an AMR to
 
determine if any components were omitted. As part of the evaluation, the staff determined
 
whether the applicant had properly identified the SSCs within the scope of license renewal and
 
subject to an AMR, pursuant to 10 CFR 54.4(a) and 10 CFR 54.21(a)(1). The staff reviewed the
 
relevant portions of the UFSAR for the RC PB components in other systems and associated components and compared the information in the UFSAR with the information in the original
 
LRA to identify those portions that the original LRA did not identify as within the scope of license
 
renewal and subject to an AMR. The staff then reviewed the SCs that were identified as not
 
being within the scope of license renewal to verify that (1) these SCs have none of the intended
 
functions delineated under 10 CFR 54.4(a), and (2) for those SCs that have an applicable
 
intended function(s), verify that they either perform this function(s) with moving parts or a
 
change in configuration or properties, or that they are subject to replacement based on a
 
qualified life or specified time period, as described in 10 CFR 54.21(a)(1).
The staff also reviewed the UFSAR for any functions delineated under 10 CFR 54.4(a) not identified as intended functions in the original LRA, to verify that the SSCs with such functions
 
will be adequately managed so that the functions will be maintained consistent with the CLB for
 
the extended period of operation.
2.3A.1.6.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the RCPB components in other systems components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the RCPB components in
 
other systems components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.2  Engineered Safety Features Systems In ALRA Section 2.3.2.A, the applicant identified the structures and components of the NMP1 engineered safety features (ESF) systems that are subject to an AMR for license renewal.
The applicant described the supporting structures and components of the ESF systems in the following sections of the ALRA:
* 2.3.2.A.1NMP1 automatic depressurization system 2-48
* 2.3.2.A.2NMP1 containment spray system
* 2.3.2.A.3NMP1 core spray system
* 2.3.2.A.4NMP1 emergency cooling system The staff's review findings regarding ALRA Sections 2.3.2.A.1 through 2.3.2.A.4 are presented in SER Sections 2.3A.2.1 through 2.3A.2.4, respectively.2.3A.2.1  NMP1 Automatic Depressurization System 2.3A.2.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.A.1, the applicant described the automatic depressurization system. The automatic depressurization system reduces RPV pr essure for small line breaks when there is no feedwater flow. When RPV pressure is reduced to the low pressure permissive setpoint of the
 
core spray system, sufficient inventory makeup is available to maintain adequate core cooling.
The automatic depressurization system consists of six solenoid-operated relief valves that discharge to the torus. Three relief valves are located on each main steam line. The discharge
 
piping also contains vacuum breakers.
The automatic depressurization system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the automatic depressurization system
 
performs functions that support fire protection and EQ.
The component types subject to an AMR that per form the system intended functions for the automatic depressurization system are part o f, and evaluated in, the main steam system. No additional components within the automatic depre ssurization system are subject to an AMR.
2.3A.2.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.A.1 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.2.1.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant 2-49 had adequately identified the automatic depressurization system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the automatic depressurization
 
system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.2.2  NMP1 Containment Spray System 2.3A.2.2.1  Summary of Technical Information in the Amended Application The purpose of the containment spray system is to prevent containment pressure and temperature from exceeding its design values following loss of coolant accidents. The
 
containment spray system consists of two redundant loops that take suction from the torus and
 
discharge to one of two drywell spargers and a torus sparger. Each loop consists of two
 
redundant trains. Each train consists of a suction header, pump, heat exchanger, common test
 
return line and associated piping and valves. The heat exchangers are cooled by a dedicated
 
containment spray raw water pump that takes suction from the circulating water intake tunnel
 
and discharges to the discharge tunnel. Each raw water train consists of a pump, strainer and
 
associated piping and valves. The containment spray system instrumentation and controls are
 
included within this system.
The containment spray system contains SR components relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the containment spray system could potentially
 
prevent the satisfactory accomplishment of an SR function. In addition, the containment spray
 
system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* provides pressure retaining boundary
* converts liquid into spray
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.2.A.2-1, the applicant identified the following containment spray system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow elements
* flow orifices
* heat exchangers
* nozzles
* piping and fittings
* pumps
* valves 2-50 2.3A.2.2.2  Staff Evaluation The staff reviewed ALRA Section 2.3.2.A.2 and UFSAR Section VII.B using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.2.2.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the containment spray system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the containment spray system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.2.3  NMP1 Core Spray System 2.3A.2.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.A.3, the applicant described the core spray system. The purpose of the core spray system is to prevent fuel dam age following any postulated LOCA. For small line breaks, the automatic depressurization system is used in conjunction with the core spray
 
system to prevent fuel damage.
The core spray system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the core spray system could potentially prevent
 
the satisfactory accomplishment of an SR function. In addition, the core spray system performs
 
functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary 2-51
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.2.A.3-1, the applicant identified the following core spray system component types that are within the scope of license renewal and subject to an AMR:
* accumulators
* bolting
* filters/strainers
* flow elements
* flow orifices
* heat exchangers
* level gauges
* piping and fittings
* pumps
* valves 2.3A.2.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.A.3 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.2.3.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the core spray system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the core spray system components that
 
are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-522.3A.2.4  NMP1 Emergency Cooling System 2.3A.2.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.A.4, the applicant described the emergency cooling system (ECS). The purpose of the ECS is to remove decay heat from the RPV fuel in the event that RPV feedwater
 
capability is lost and the main condenser is not available. This system serves as an alternate
 
heat sink when the RPV is isolated from its normal heat sink (i.e., the main condenser). The
 
emergency cooling system consists of two redundant loops connected to the RPV on the steam
 
supply side and to the reactor recirculation system on the condensate return side. Steam side
 
vents are connected to each loop that removes non-condensable gases to the main steam lines
 
or torus (for accident conditions). Drain lines are also provided on each loop's steam lines.
The ECS contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the ECS could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the ECS performs functions that support fire
 
protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.2.A.4-1, the applicant identified the following ECS component types that are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchangers
* level gauges
* piping and fittings
* tanks
* valves 2.3A.2.4.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.A.4 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
not omitted from the scope of license renewal any components with intended functions 2-53 delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.2.4.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the ECS components that are within the scope of license renewal, as
 
required by 10 CFR 54.4(a), and the ECS components that are subject to an AMR, as required
 
by 10 CFR 54.21(a)(1).2.3A.3  Auxiliary Systems In ALRA Section 2.3.3.A, the applicant identified the structures and components of the NMP1 auxiliary systems that are subjec t to an AMR for license renewal.
The applicant described the supporting structures and components of the auxiliary systems in the following sections of the ALRA:
* 2.3.3.A.1NMP1 administration building heating, ventilation, and air conditioning (HVAC) system
* 2.3.3.A.2NMP1 circulating water system
* 2.3.3.A.3NMP1 city water system
* 2.3.3.A.4NMP1 compressed air systems
* 2.3.3.A.5NMP1 containment systems
* 2.3.3.A.6NMP1 control room HVAC system
* 2.3.3.A.7NMP1 diesel generator building ventilation system
* 2.3.3.A.8NMP1 emergency diesel generator system
* 2.3.3.A.9NMP1 fire detection and protection system
* 2.3.3.A.10NMP1 hydrogen water chemistry system
* 2.3.3.A.11NMP1 liquid poison system
* 2.3.3.A.12NMP1 miscellaneous non-contaminated vents and drains system
* 2.3.3.A.13NMP1 neutron monitoring system
* 2.3.3.A.14NMP1 process radiation monitoring system
* 2.3.3.A.15NMP1 radioactive waste disposal building HVAC system
* 2.3.3.A.16NMP1 radioactive waste system 2-54
* 2.3.3.A.17NMP1 reactor building closed loop cooling water system
* 2.3.3.A.18NMP1 reactor building HVAC system
* 2.3.3.A.19NMP1 reactor water cleanup system
* 2.3.3.A.20NMP1 sampling system
* 2.3.3.A.21NMP1 service water system
* 2.3.3.A.22NMP1 shutdown cooling system
* 2.3.3.A.23NMP1 spent fuel pool filtering and cooling system
* 2.3.3.A.24NMP1 technical support center HVAC system
* 2.3.3.A.25NMP1 turbine building closed loop cooling water system
* 2.3.3.A.26NMP1 turbine building HVAC system
* 2.3.3.A.27NMP1 electric steam boiler system
* 2.3.3.A.28NMP1 makeup demineralizer system The staff's review findings regarding ALRA Sections 2.3.3.A.1 through 2.3.3.A.28 are presented in SER Sections 2.3A.3.1 through 2.3A.3.28, respectively.2.3A.3.1  NMP1 Administration Building Heating, Ventilation, and Air Conditioning (HVAC)
System 2.3A.3.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.1, the applicant described the administration building HVAC system.
The administration building HVAC system is designed to provide equipment ventilation and personnel comfort. The administration building HVAC system supplies air to the administration building and its extension. This system consists of a rooftop air conditioning unit, supply fans, exhaust fans, and associated ductwork. Individual heating and air conditioning units are
 
provided throughout the original administration building and the administration building
 
extension for personnel comfort. The administrat ion building HVAC system louvered penthouse damper assembly also provides outside ai r to the control room HVAC system.
The administration building HVAC system c ontains SR components that are relied upon to remain functional during and following DBEs.
The only components requiring an AMR for the admin istration building HVAC system are the louvered penthouse damper assembly and cooling coil tubes that are shared with the control
 
room HVAC system and are evaluated in that system. The remaining in-scope components for the administration building HVAC system ar e active components. Therefore, there are no components requiring an AMR for the admin istration building HVAC system.
2-55 2.3A.3.1.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.1 and UFSAR Section III.E.1.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.1.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the administration building HVAC system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the administration building
 
HVAC system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.2  NMP1 Circulating Water System 2.3A.3.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.2, the applicant described the circulating water system. The NMP1 circulating water system provides cooling water from Lake Ontario to the main condenser. Lake
 
water is drawn from the intake tunnel through two parallel gates, three trains of mechanical
 
rakes and traveling screens, to the suction of two redundant circulating water pumps. Each
 
pump discharges in a separate line to one side of the condenser divided water box. Fish
 
screens and sluice valves are installed in each line to prevent debris backwashing into the inlet
 
tunnel. After leaving the condenser, the circulating water is discharged back into the lake. The
 
circulating water system consists of the fo llowing subsystems: main condenser circulating water, screen washing, hydraulic fluid to tempering gate, and main condenser circulating water
 
box vents.
The circulating water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the circulating water system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the circulating water system performs functions that support fire protection.
2-56 The intended functions within the scope of license renewal include the following:
* provides filtration
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary In ALRA Table 2.3.3.A.2-1, the applicant identified the following circulating water system component types that are within the scope of license renewal and subject to an AMR:
* actuator
* bolting
* circulating water gates
* expansion joints
* filter
* piping and fittings
* pumps
* tank
* traveling screens and rakes
* valves 2.3A.3.2.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.2 and UFSAR Section XI.B.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.2 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.A.2-1, dated November 19, 2004, the staff stated that because of the unique interface between the circulating water system, the emergency service water pumps, and the
 
intake structure, the staff needed more information to complete its review to understand the
 
configuration of the components requiring an AMR. This information was not clearly depicted in
 
license renewal (LR) drawings LR-18022-C, sheet 1 and LR-26941-C. Therefore, the staff
 
requested that the applicant supply the following UFSAR figures: circulating water system;
 
circulating water channels under the screen and pump house - normal operation; circulating
 
water channels under the screen and pump house - special operations; and intake and
 
discharge tunnels plan and profile.
2-57 In its response, by letter dated December 22, 2004, the applicant provided copies of UFSARFigures III-19, III-20, III-21, and XI-4 for the staff to complete its review. The staff found the
 
applicant's response to RAI 2.3.3.A.2-1 acceptable because the UFSAR figures have been
 
reviewed. Therefore, the staff's concern described in RAI 2.3.3.A.2-1 is resolved.
In RAI 2.3.3.A.2-2, dated November 19, 2004, the staff requested that the applicant provide information on the intended function of "NSR Functional Support" listed in the original LRA
 
Table 2.3.3.A.2-1. The applicant response, by letter dated December 22, 2004, has been
 
subsequently incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant stated that this intended function is no longer used, instead, identified specific NSR intended functions and made them consistent with the
 
standardized list of intended functions in the SRP-LR and NEI 95-10. Based on the information
 
submitted in the ALRA, the staff's concern described in RAI 2.3.3.A.2-2 is resolved.
2.3A.3.2.3  Conclusion
 
The staff reviewed the ALRA and RAI responses to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the circulating water system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the circulating water system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.3  NMP1 City Water System 2.3A.3.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.3, the applicant described the city water system. The city water system provides hot and cold domestic water to various areas within the station. Cold water is
 
distributed to the lab, decontamination room, laundry, administration building, emergency
 
showers and two electric hotwater heaters. Hot water is supplied to the lab and administration
 
building. The system is supplied by the offsite water system. The city water system contains one SR breaker since a hot water circulating pump is powered from a SR powerboard.
The city water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in t he city water system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.A.3-1, the applicant identified the following city water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow orifice 2-58
* piping and fittings
* pumps
* tanks
* valves 2.3A.3.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.3 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
During the staff's review of original LRA Section 2.3.3.A.3, 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 2.3.3.A.3-1, dated November 19, 2004, the staff requested that the
 
applicant identify the portions of the city water system containing components subject to AMR.
 
The applicant response, by letter dated December 22, 2004, has been subsequently
 
incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant's ALRA Table 2.3.3.A.3-1 includes a list of the components subject to an AMR and a list of the new LR drawings. The applicant also provided
 
an LR drawing that accurately depicts all the components subject to an AMR, including those
 
subject to an AMR in accordance with 10 CFR 54.4(a)(2). Based on the information submitted in
 
the ALRA, the staff's concern described in RAI 2.3.3.A.3-1 is resolved.
2.3A.3.3.3  Conclusion
 
The staff reviewed the ALRA and RAI response to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the city water system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the city water system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.4  NMP1 Compressed Air Systems 2.3A.3.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.4, the applicant described the compressed air systems. The compressed air systems are designed to provide clean, filtered air to various areas of NMP1.
2-59 The compressed air systems consist of the house se rvice air system, the in strument air system, and the breathing air system. The house service air system is a NSR system designed to provide a reliable source of clean air for use in maintenance and as a backup to the instrument
 
air system. The instrument air system is designed to provide a source of clean, dry air for use in instruments, controls, and as a backup to the breathing air system. The breathing air system is a NSR system designed to provide a reliable supply of clean, filtered air fit for human breathing.
The compressed air systems contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the compressed air systems could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the
 
compressed air systems performs functions that support EQ and SBO.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.4-1, the applicant identified the following compressed air systems component types that are within the scope of license renewal and subject to an AMR:
* air dryers: couplings, flanges, heads, nozzles, piping
* air receivers
* bolting
* drain traps
* filters/strainers
* flow gauge
* heat exchangers
* orifices
* piping and fittings
* regulators
* separators
* tanks
* valves 2.3A.3.4.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.4 and UFSAR Section X.I using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had 2-60 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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.4 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.A.4-1, dated November 19, 2004, the staff indicated that the original LRA stated that the compressed air system provides air to inflate the reactor building track bay door seal.
 
The component type inflatable seals are not listed in the original LRA tables as subject to an
 
AMR. The original LRA tables list only the fire protection barrier penetration seals as subject to
 
an AMR. Therefore, the staff requested that the applicant provide the basis for excluding
 
inflatable seals as subject to an AMR.
In its response, by letter dated December 22, 2004, the applicant stated that the reactor building track bay door inflatable seal is within the scope of license renewal and subject to AMR. It is
 
part of the reactor building structure and is covered by the polymer in air component type in
 
original LRA Section 2.4.A.2.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.4-1 acceptable because the applicant stated that the inflatable seal is within the scope of license renewal and
 
subject to an AMR, and is part of reactor building structure. Therefore, the staff's concern
 
described in RAI 2.3.3.A.4-1 is resolved.
In RAI 2.3.3.A.4-2, dated November 19, 2004, the staff requested that the applicant identify which double acting actuators are included within the scope of license renewal and subject to
 
an AMR. The applicant response, by letter dated December 22, 2004, has been subsequently
 
incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided the information, including LR drawings requested by this RAI. Based on review of the information submitted in the ALRA, the staff's
 
concern described in RAI 2.3.3.A.4-2 is resolved.
In RAI 2.3.3.A.4-3, dated November 19, 2004, the staff stated that LR drawing LR-22108-0, sheet 34 shows that the air supply tubing and solenoid valves associated with a valve BV-60-13
 
are not subject to an AMR; however, LR draw ing LR-18017-C, sheet 1 shows the air supply piping and solenoid valves associated valve BV-60-13 are subject to an AMR. Therefore, the
 
staff requested that the applicant resolve this inconsistency and provide the basis for the
 
resolution.
In its response, by dated December 22, 2004, the applicant stated that LR drawing LR-18017-C, sheet 1 is incorrect. The applicant stated that, "The air supply piping to valve BV-60-13 is not
 
in-scope for LR. Valve BV-60-13 fails closed on loss of air and is not relied upon for any
 
licensing basis accident mitigation. As such the air supply piping does not perform any intended
 
function for LR."
2-61 Based on its review, the staff found the applicant's response to RAI 2.3.3.A.4-3 acceptable because the applicant adequately justified the exclusion of the component in question as not
 
within the scope of license renewal and not not subject to an AMR. Therefore, the staff's
 
concern described in RAI 2.3.3.A.4-3 is resolved.
In RAI 2.3.3.A.4-4, dated November 19, 2004, the staff stated that on several LR drawings (e.g.
LR-22111-0, sheet 5) for the compressed air system, the air supply and solenoid valves
 
associated with the SR valves are excluded as subject to an AMR; therefore, the staff requested
 
that the applicant provide the criteria used to exclude some of the compressed air system
 
auxiliaries to SR valves as subject to an AMR.
In its response, by letter dated December 22, 2004, the applicant stated that the SR air supply and solenoid valves identified in the RAI are normally closed fuel pool cooling system isolation
 
valves which fail safe (closed) on loss of air. None of the air system components to these loads
 
are required to be SR for instrument air system integrity or operation. The applicant concluded
 
that, based upon the scoping criteria for license renewal, the subject instrument air valves and
 
piping are not within the scope of license renewal and are not subject to an AMR. The applicant
 
also clarified that, since this system has no liquid-filled components, there are no NSR
 
components within the system that are within the scope of license renewal and subject to an
 
AMR in accordance with 10 CFR 54.4(a)(2).
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.4-4 acceptable because the applicant adequately justified the exclusion of the component types in question
 
from within the scope of license renewal and subject to an AMR. Therefore, the staff's concern
 
described in RAI 2.3.3.A.4-4 is resolved.
2.3A.3.4.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
compressed air systems components that are within the scope of license renewal, as required
 
by 10 CFR 54.4(a), and the compressed air systems components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.5  NMP1 Containment Systems 2.3A.3.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.5, the applicant described the containment systems. The containment systems are designed to control and monito r the primary containment environment. The containment systems consist of the combustibl e gas control system, primary containment area cooling system, containment atmospheric moni toring system, torus temperature monitoring system, torus drain system, and the integrated leak rate monitoring system. The combustible gas control system is designed to prevent a combustible hydrogen-oxygen concentration from accumulating in the primary containment atmosphere immediately following or during a LOCA.
2-62 The combustible gas control system consists of the containment inerting system and the containment atmosphere dilution system.
The containment inerting system is used to inert and deinert primary containment and to makeup nitrogen as required to maintain low oxygen concentration and containment pressure.
 
The containment atmosphere dilution system is designed to monitor and maintain the oxygen
 
concentration of the primary containment atmosphere to less than four percent during a LOCA.
The primary containment area cooling system is designed to remove and dissipate the primary containment area heat gain. The containment atmospheric monitoring system continuously monitors and provides control room indication of the containment airborne radioactivity level.
This provides for detection of leaks of the r eactor primary systems. The torus temperature monitoring system provides information on toru s temperature, water level and airspace pressure to ensure that the cooling capacity of water maintained in the suppression chamber is available
 
within the TS limits and to ensure that the containment structural integrity is maintained. The
 
torus drain system is used when the reactor is in cold shutdown or refueling condition. It allows
 
the torus to be dewatered to permit maintenance or other activities. The integrated leak rate
 
monitoring system is used to support periodic 10 CFR 50, Appendix J testing for overall leakage
 
from primary containment, which demonstrates the ability of containment to control the spread
 
of radioactivity in the event of an accident.
The containment systems contain SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the containment systems could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the
 
containment systems perform functions t hat support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.5-1, the applicant identified the following containment systems component types that are within the scope of license renewal and subject to an AMR:
* airborne activity monitor
* blower
* bolting
* ducting 2-63
* filters/strainers
* flame arresters
* flow elements
* heat exchangers
* piping and fittings
* pumps
* rupture discs
* tanks
* traps
* valves
* vaporizers 2.3A.3.5.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.5 and UFSAR Sections VI and VII.G using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of ALRA Section 2.3.3.A.5 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.A.5, dated December 8, 2004, the staff stated that original LRA Tables 2.3.3.A.5-1 and 3.3.2.A-4, and original LRA Section 2.3.3.A.5 for the containment system, do not include
 
piping/fittings and drywell air cooler units for NMP1; however, these items are shown as within
 
the scope of license renewal on LR drawings and are subject to an AMR. Therefore, the staff
 
requested that the applicant provide information on the associated AMR and AMPs in ALRA
 
Tables 2.3.3.A.5-1 and 3.3.2.A-4, if these components are within the scope of license renewal.
 
The staff requested the applicant to provide justification for the exclusion of these components if
 
they are not within the scope of license renewal.
In its response, by letter dated January 7, 2005, the applicant stated that the piping/fittings and drywell air cooler units in the NMP1 containm ent system are component types that are within the scope of the license renewal and subject to AMR. The piping and fittings component type is
 
included in the system description portion of ALRA Section 2.3.3.A.5, but was inadvertently
 
omitted from ALRA Tables 2.3.3.A.5-1 and 3.3.2.A-4. The applicant stated that the ALRA tables
 
have been revised to incorporate the requested information regarding the intended function, AMR, and AMPs for these components. With respect to drywell air cooler units, the applicant
 
stated that these are addressed under the component types "Ducting" and "Heat Exchanger,"
 
respectively, and are included in ALRA Tables 2.3.3.A.5-1 and 3.3.2.A-4.
2-64 Based on it's review, the staff found the applicant's response to RAI 2.3.3.A.5 acceptable because the applicant has included the piping/fittings and drywell air coolers units and
 
associated components within the scope of license renewal subjected to an AMR in accordance
 
with the requirements of 10 CFR 54.21(a)(1). Therefore, the staff's concern described in
 
RAI 2.3.3.A.5 is resolved.
2.3A.3.5.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
containment systems components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the containment systems components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.6  NMP1 Control Room HVAC System 2.3A.3.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.6, the applicant described the control room HVAC system. The control room HVAC system provides filtration, pre ssurization, heating and cooling to the control complex during normal and emergency conditions. The system is also equipped with an
 
independent smoke and heat removal system for the main and auxiliary control rooms and cable spreading room. The control room HVAC syst em is comprised of three functional systems which are the normal ventilation, emergency ventilation and smoke purge systems. The normal ventilation system provides fresh and recirculated air for heating and cooling the control
 
complex during normal operation. The emergency ventilation system provides clean, filtered
 
fresh air combined with recirculated air for heating and cooling the control complex during
 
emergency conditions. The smoke purge system is a fire protection ventilation system that removes smoke and heat from the main and auxilia ry control rooms and cable spreading room.
The control room HVAC system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the control room HVAC system performs functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides rated fire barrier
* provides heat transfer
* provides pressure retaining boundary In ALRA Table 2.3.3.A.6-1, the applicant identified the following control room HVAC system component types that are within the scope of license renewal and subject to an AMR:
* blowers 2-65
* bolting
* ducting
* expansion tank
* filters/strainers
* flow elements
* heat exchangers
* piping and fittings
* pumps
* seals and gaskets
* temperature elements
* valves and dampers 2.3A.3.6.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.6 and UFSAR Section III.B.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.6.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the control room HVAC system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the control room HVAC system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.7  NMP1 Diesel Generator Building Ventilation System 2.3A.3.7.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.7, the applicant described the diesel generator building (DGB) ventilation system. The DGB vent ilation system is designed to maintain the diesel room temperature below the allowed maximum for continuous operation of the emergency diesel
 
generator. Each diesel generator rooms is equi pped with its own ventilation system. The system consists of roof exhaust fans, a roll-up door, electric heaters, and associated controls. The
 
doors operate in conjunction with the room exhaust fan pairs to ensure that the diesel generator
 
room temperature remains below the allowed maximum. The heaters operate to maintain the diesel generator room ambient temperature at or above 50 °F.
2-66 The DGB ventilation system contains SR com ponents that are relied upon to remain functional during and following DBEs.
The intended function, within the scope of license renewal, is to provide pressure retaining boundary.In ALRA Table 2.3.3.A.7-1, the applicant identified the blowers component type of the DGB ventilation system as within the scope of license renewal and subject to an AMR.
2.3A.3.7.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.7 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance described in
 
SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.7.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the DGB ventilation system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the DGB ventilation system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.8  NMP1 Emergency Diesel Generator System 2.3A.3.8.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.8, the applicant described the emergency diesel generator (EDG) system. The EDG system provides the standby source of electric power for equipment required for mitigation of the consequences of an accident, for safe shutdown and for maintenance of the
 
station in a safe condition under postulated event and accident scenarios. This system consists
 
of two identical, physically separate, and el ectrically independent standby diesel generators.
Each diesel generator has associated subsystems which assist the unit in performing its safety
 
function. The diesel engine subsystem consists of a diesel engine which provides the mechanical power to run the electric generator. The fuel oil subsystem supplies fuel oil for
 
engine combustion and is comprised of the fuel oil storage and handling system and the engine
 
fuel oil system. The air start subsystem supplies high-pressure air to start the diesel engine. The
 
combustion air intake and exhaust subsystem supports the engine combustion process by 2-67 supplying filtered air to the diesel engine and then discharging the exhaust gases. The lube oil subsystem provides cooling and lubrication for major engine components. The cooling water
 
subsystem removes heat from the diesel engine via the engine cooling system and diesel
 
generator raw water cooling system. The electric generator subsystem provides the electrical
 
output of the diesel generator unit and includes the required controls.
The EDG system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in t he EDG system could potentially prevent the satisfactory accomplishment of an SR function.
In addition, the EDG system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.3.A.8-1, the applicant identified the following EDG system component types that are within the scope of license renewal and subject to an AMR:
* air intakes
* air start motors
* bolting
* compressors
* exhausts for EDG
* filters/strainers
* flow elements
* flow glasses
* heat exchangers
* level glasses
* mufflers and silencers
* orifices
* piping and fittings
* pumps
* tanks
* valves 2.3A.3.8.2  Staff Evaluation 2-68The staff reviewed ALRA Section 2.3.3.A.8 and UFSAR Section IX.B.4.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.8 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.A.8-1, dated November 19, 2004, the staff stated that LR drawing 18026-C, sheet 1 (B-1) for diesel #102 shows that the line leading to the fuel injectors is not subject to an AMR.
 
LR drawing LR-18026-C, sheet 2 (C-1) for diesel #103 shows that the line leading to the
 
injectors is highlighted as subject to an AMR. Therefore, the staff requested that the applicant
 
resolve the apparent discrepancy between the two LR drawings.
In its response by letter dated December 22, 2004, the applicant stated that LR drawing 18026-C sheet 1 is incorrect and does not properly show the components within the scope of
 
license renewal and subject to AMR. The components in question should have been highlighted
 
on the LR drawing showing that they are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to AMR under 10 CFR 54.21(a) but inadvertently were not
 
highlighted. The components in question have been included within the scope of license
 
renewal and are subject to AMR.
The staff's review found the applicant's response to RAI 2.3.3.A.8-1 acceptable because it adequately explained that the components in question are within the scope of license renewal
 
and subject to AMR but inadvertently were not highlighted on the LR drawing. Therefore, the
 
staff's concern described in RAI 2.3.3.A.8-1 has been resolved.
In RAI 2.3.3.A.8-2, dated November 19, 2004, the staff stated that LR drawing LR-18026-C, sheet 1 and sheet 2 does not show that the pipes and expansion joints leading to the air start
 
motor are subject to an AMR. The staff noted that the pipe and the expansion joints are not
 
shown on sheet 2 of the drawing. Original LRA Table 2.3.3.B.1-1 lists air start motors as subject
 
to an AMR for NMP2; therefore, the staff requested that the applicant provide the basis for not
 
requiring an AMR for these NMP1 components.
In its response, by letter dated December 22, 2004, the applicant stated that the LR drawing is incorrect. It should show the air start motor, associated piping, and expansion joints as subject
 
to AMR. These components have a pressure boundary intended function. The piping and
 
expansion joints are included with the piping and fittings component type. The applicant also
 
stated that the air start motors will be added to the original LRA Table 2.3.3.A.8-1. In addition, the applicant added the air intake silencer, filter, and exhaust muffler on LR drawing 2-69 LR-18026-C, sheets 1 and 2 should be shown in red to indicate that they are subject to AMR, consistent with original LRA Table 2.3.3.A.8-1.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.8-2 acceptable because it explained that: (1) the LR drawing depicts the air start motor, associated piping, and
 
expansion joints as not requiring an AMR, but should have been highlighted on the LR
 
drawings; (2) the air start motor is added to Table 2.3.3.A.8-1; and (3) the air intake silencer, filter, and exhaust muffler should be shown on the LR drawings as being subject to an AMR.
 
Therefore, the staff's concern described in RAI 2.3.3.A.8-2 is resolved.
In RAI 2.3.3.A.8-3, dated November 19, 2004, the staff stated that LR drawing 18026-C, sheets 1 and 2 shows that the tubing to the pressure gauges on the air receiver tanks is not highlighted
 
as subject to an AMR. This tubing has a passive pressure boundary function and meets the
 
criteria of 10 CFR 54.4(a)(1). Additionally, a note on the LR drawings indicates that there are
 
root valves for these pressure indicators; therefore, the staff requested that the applicant
 
provide the basis for not requiring an AMR for this tubing and associated root valves.
In its response, by letter dated December 22, 2004, the applicant stated that the LR drawing is incorrect and does not properly show the tubing between the air receiver tanks and the pressure
 
gauges as within the scope of license renewal and subject to an AMR. The components in
 
question should have been included within the scope of license renewal and subject to an AMR
 
but inadvertently were not highlighted. The applicant stated that the original LRA
 
Table 2.3.3.A.8-1 already represents tubing and instrument root valves under the "Piping and
 
Fittings" and "Valves" component types, respectively. The applicant further stated that pressure
 
gauges are active components and, therefore, are not highlighted on the LR drawing as subject
 
to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.8-3 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal and subject to an AMR but were inadvertently left un-highlighted on the LR drawing.
 
Therefore, the staff's concern described in RAI 2.3.3.A.8-3 is resolved.
In RAI 2.3.3.A.8-4, dated November 19, 2004, the staff stated that LR drawing 18026-C, sheets 1 and 2 do not clearly indicate whether two immersion heaters are subject to an AMR.
 
Depending on the heater design, these heaters can have a pressure boundary intended
 
function; therefore, the staff requested that the applicant clarify if the heat exchangers
 
component type original LRA Table 2.3.3.A.8-1 represents these heaters.
In its response, by letter dated December 22, 2004, the applicant stated that drawing LR-18026-C, sheets 1 and 2, are incorrect. Immersion heaters do have a pressure boundary
 
function. Additionally, sheet 2 should look like sheet 1, indicating that there is a chamber around
 
the heating coils. On both sheets, those chambers should be shown in red, indicating that they
 
are within the scope for license renewal and subject to an AMR. The chambers are treated as
 
part of the piping and fittings component type. The heaters themselves are also within the scope
 
of license renewal; however, since they are active components, per Appendix B of NEI 95-10, Revision 3, they are not subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.8-4 acceptable because it adequately explained that: (1) although the immersion heaters are within the scope 2-70 of license renewal, they are active components and do not perform a pressure boundary function, and therefore are not subject to an AMR; and (2) the chambers around the heating
 
coils are also within the scope of license renewal, subject to an AMR, and treated as the piping
 
and fittings component type. Therefore, the staff's concern described in RAI 2.3.3.A.8-4 is
 
resolved.2.3A.3.8.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
EDG system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the EDG system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).2.3A.3.9  NMP1 Fire Detection and Protection System 2.3A.3.9.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.9, the applicant described the fire detection and protection system. The fire detection and protection system is designed to achieve the following objectives:
* provide automatic fire detection in those areas where the danger of fire exists
* provide fire extinguishment by fixed equi pment activated automatically or manually for those areas where the danger of fire exists
* provide manually-operated fire extinguish ing equipment for use by station personnel at points throughout the property and station
* provide a backup cooling water source for the reactor emergency cooling system in the event of a complete loss of all other sources of condensing water
* provide an emergency source of water for containment and reactor vessel flooding
* provide an emergency source of water to the spent fuel storage pool (hose)
* provide a backup water source for the emergency service water system
* provide an emergency cooling water supply to either diesel generator These objectives are accomplished by the fire detection and control, fire water, halon suppression, and carbon dioxide (CO
: 2) suppression systems. The fire detection and control system provides for the identification of a fi re, annunciation locally and in the control room, and in certain zones, automatically initiates suppre ssion. The fire water system provides for the extinguishment of fires using water. The halon suppression system provides for the extinguishment of fires using Halon 1301. The CO 2 suppression system provides for the extinguishment of fires using CO
: 2. Portable fire extinguishers are also provided throughout the station to provide additional protection.
2-71 The fire detection and protection system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the fire detection and
 
protection system could potentially prevent the satisfactory accomplishment of an SR function.
In addition, the fire detection and protection system performs functions that support fire
 
protection and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* converts liquid into spray
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.9-1, the applicant identified the following fire detection and protection system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* fire hydrants
* flow elements
* gearbox
* heat-actuated devices
* heat exchangers
* orifices
* piping and fittings
* pumps
* silencers
* sluice gate for motor driven fire pump
* spray nozzles
* sprinklers
* tanks and air receivers
* valves 2.3A.3.9.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.9 and UFSAR Sections X.10A and X.10B using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not 2-72 omitted any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff also reviewed approved fire protection safety evaluation (SE) report dated July 26, 1979, and March 21, 1983, for Nine Miles Point Unit 1. This report is referenced directly in the
 
Nine Mile Point Unit 1 fire protection current licensing basis (CLB) and summarize the Fire
 
Protection Program and commitments to 10 CFR 50.48 using the guidance of Appendix A to
 
Branch Technical Position (BTP) Chemical and Mechanical Engineering Branch (CMEB) 9.5-1.
 
The staff then reviewed those components that the applicant identified as being within the
 
scope of license renewal to verify that the applicant did not omit any passive and long-lived
 
components that should be subject to an AMR in accordance with the requirements of
 
10 CFR 54.21(a)(1).
The staff's review of ALRA Section 2.3.3.A.9 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.A.9-2, dated November 17, 2004, the staff stated that drawing LR-18030-C, sheet 2 shows five foam water systems as within the scope of license renewal and subject to an AMR, including the foam solution supply piping; howev er, the LR drawing shows the foam tank and pumps as not within the scope of license renew al. Additionally, the foam tanks and pumps are shown disconnected from the foam water system supply piping. The UFSAR does not reference
 
these foam water systems; therefore, the staff requested that the applicant provide the basis for excluding the foam tank and pumps from the sc ope of license renewal and from being subject to an AMR, since they are necessary for the functi on of the foam water systems which are shown as within the scope of license renewal.
In its response, by letter dated December 17, 2004, the applicant stated that the ALRA correctly describes the NMP1 fire detection and protection system, as credited for 10 CFR 50.48 and, therefore, 10 CFR 54.4(a). The foam subsystem is not included in this section since it is retired
 
in-place and nonfunctional. The foam subsystem is not within the scope of license renewal for
 
NMP1. The applicant further stated that LR drawing LR-18030-C incorrectly identifies portions of
 
the foam subsystem identified as within the scope of license renewal and subject to an AMR.
 
The only portions that are within the scope of license renewal and subject to an AMR are the
 
connections from the fire water headers up to the closed valves to the foam subsystem.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-2 acceptable. The applicant explained that the foam subsystem components in question are not within the scope
 
of license renewal and not subject to an AMR becaus e the foam subsystem is retired in place.
The LR drawings inadvertently included highlighted portions of the foam subsystem in error. The
 
staff concludes that there is reasonable assurance that the components were correctly excluded
 
from the scope of license renewal and subject to an AMR. Therefore, the staff's concern
 
described in RAI 2.3.3.A.9-2 is resolved.
In RAI 2.3.3.A.9-3, dated November 17, 2004, the staff stated that LR drawing LR-18030-C, sheet 6 shows that a sprinkler system is within the scope of license renewal and subject to an
 
AMR, except for a portion that services the women's locker room. Areas within the scope of license renewal include administration building, lunch room and wash area, and new locker
 
room and shops. Therefore, the staff requested that the applicant identify the basis for excluding 2-73 a portion of the sprinkler system from within the scope of license renewal, since the rest of the system is within the scope of license renewal and subject to an AMR.
In its response, by letter dated December 17, 2004, the applicant stated that the portions of the fire water system in the administration building, as depicted on LR drawing LR-18030-C, sheet
 
6, as within scope and subject to an AMR, are incorrect.
The applicant further stated that original LRA Section 2.3.3.A.9 properly describes the portion of the fire water system as within the scope of license renewal and subject to AMR as "-the
 
connecting fire water supply piping and valves from the pump discharge header to the Reactor
 
Building and Turbine Building fire zones [excluding supplies to non-critical areas, (e.g., storage
 
areas, changing rooms, locker rooms)]." The fire wa ter system in the administration building is provided for commercial purposes and is not credited for compliance with 10 CFR 50.48. As
 
described in UFSAR Section 10A.3.10, the only SR equipment located in the administration
 
building is a DC power board located in the foam room. This area is protected by detection and
 
alarm. There is no fire water suppression to this room. This UFSAR section further states that a
 
fire in the administration building will not result in the loss of capability to achieve safe shutdown
 
and that there are no sources of radioactivity in the building. Therefore, the portion of the fire
 
water system located in the administration building is not within the scope of license renewal is
 
not subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-3 acceptable because it adequately explained that the administration building fire detection and protection
 
system in the administration building is not cr edited to meet the requirements of 10 CFR 50.48 and is not part of the plant's license. Therefore, the staff's concern described in RAI 2.3.3.A.9-3
 
is resolved.
In RAI 2.3.3.A.9-6, dated November 17, 2004, the staff stated that the UFSAR requires at least 1000 gallons of fuel in the fire pump diesel fuel oil storage tank. LR drawing LR-18040-C, sheet 2 shows level instrumentation consisting of air tubing and other components supplying the
 
level indicating instrumentation for a fuel oil storage tank, as excluded from within the scope of
 
license renewal and subject to an AMR. Therefore, the staff asked that the applicant explain the
 
apparent exclusion of these components from within the scope of license renewal and subject to
 
an AMR. In its response, by letter dated December 17, 2004, the applicant stated that LR drawing LR-18040-C, sheet 2 incorrectly reflects the current plant configuration. The drawing does not
 
reflect the installation of a replacement tank (TANK-82-116) in place of the tank (TANK-88-20)
 
shown on the drawing. TANK-82-116 has new fuel oil level instrumentation (LR-82-113)
 
installed that does not require instrument air as a support system. Instrument LR-82-113 is now used in place of LI-82-28 to verify that the fuel oil supply for the NMP1 diesel fire pump is
 
maintained at greater than or equal to 1000 gallons in compliance with UFSAR Appendix 10A, Section 2.5.2.3.2. Tank level verification is performed on a weekly basis.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-6 acceptable because it adequately explained that the components in question are not within the scope of
 
license renewal and subject to an AMR, but were inadvertently left on the LR drawing that does
 
not reflect the current plant configuration. The staff concludes that there is reasonable 2-74 assurance that the components were correctly excluded from the scope of license renewal and not subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.A.9-6 is resolved.
In RAI 2.3.3.A.9-7, dated November 17, 2004, the staff stated that ALRA Table 2.3.3.A.9-1 includes the following component types as subject to an AMR: filters/strainers, flow elements, and orifices; however, the intended function assigned to these components is NSR functional
 
support. ALRA Table 2.0-1 identifies intended functions that are applicable to these component
 
types that are not identified in the ALRA Table 2.3.3.A.9-1. Aging management to ensure that
 
the component level intended functions can be performed is necessary to ensure that the
 
system level intended functions can be maintained. The intended functions include filtration and
 
flow restriction. Therefore, the staff requested that the applicant describe how the intended
 
functions for these components were assigned and evaluated.
In its response, by letter dated December 17, 2004, the applicant stated that a component function would be considered an intended function for license renewal only if failure of that
 
component would cause the failure of a system intended function. Failure of the filtration or flow
 
restriction functions for the above mentioned components would not prevent the NMP1 fire detection and protection system from performi ng its intended functions. Therefore, the only intended function credited for these components is NSR functional support, as identified in
 
ALRA Table 2.3.3.A.9-1.
In evaluating the applicant's response to RAI 2.3.3.A.9-7, the staff found that it was incomplete and that review of ALRA Section 2.3.3.A.9 could not be completed. The applicant did not
 
explain how the intended function, NSR functional support is applied to the component types in
 
the fire detection and protection system, including piping, valves, strainers, pumps, and orifices, as requested in RAI 2.3.3.A.9-7. Therefore, the staff held a teleconference with the applicant on
 
January 25, 2005, to discuss information necessary to resolve the staff's concern described in
 
RAI 2.3.3.A.9-7. The product of the teleconference was an agreement by the applicant to
 
transmit the required information in a follow-up letter.
By letter dated February 11, 2005, the applicant stated that NSR functional support is a "catch-all" function for NSR components. The applicant also provided a table identifying each
 
component to its intended function, further explaining the use of NSR functional support.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-7, including additional information from the letter dated February 11, 2005, acceptable because they
 
adequately explained what intended functions NSR functional support represent and how it is
 
applied to all the component types in the fire detection and protection system, including piping, valves, strainers, pumps, and orifices. Additi onally, the applicant provided a table identifying each component to its intended function, which further explains the use of NSR functional
 
support. Therefore, the staff's concern described in RAI 2.3.3.A.9-7 is resolved.
2.3A.3.9.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff 2-75 concludes that there is reasonable assurance that the applicant had adequately identified the fire detection and protection system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the fire detection and protection system components that
 
are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.10  NMP1 Hydrogen Water Chemistry System 2.3A.3.10.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.10, the applicant described the hydrogen water chemistry system. The hydrogen water chemistry system and noble meta l chemical addition systems are designed to mitigate intergranular stress corrosion cracking of the reactor recirculation piping and the RPV
 
internals. The hydrogen water chemistry system injects hydrogen into the FW/HPCI system to suppress the radiolytic generated oxidant concentration in the reactor core regions. This
 
significantly reduces the electrochemical potential of the reactor components and greatly
 
reduces crack initiation and growth. The noble metal chemical addition system includes
 
permanent monitoring equipment as well as connections for periodically injecting a noble metal
 
solution. The hydrogen water chemistry system does not perform any intended functions for license renewal purposes and, therefore, is not described further. The monitoring portion of the
 
noble metal chemical injection system does , however, perform an intended function. The monitoring portion draws a sample from the reactor water cleanup (RWCU) system, analyzes the effectiveness of the noble metal treatment in the durability monitor, and returns the sample
 
to the RWCU system.
The failure of NSR SSCs in the hydrogen water c hemistry system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.A.10-1, the applicant identified the following hydrogen water chemistry system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow element
* piping and fittings
* valves 2.3A.3.10.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.10 and UFSAR Section X.M using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not 2-76 omitted any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.10.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the hydrogen water chemistry system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the hydrogen water chemistry
 
system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.11  NMP1 Liquid Poison System 2.3A.3.11.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.11, the applicant described the liquid poison system. The liquid poison system is a standby, redundant, independent control system that is designed to bring the reactor to a cold shutdown condition in the unlikely event that the control rod system fails to shut
 
down and hold the reactor sub-critical as the reactor cools and xenon decays.
The liquid poison system consists of an ambient pressure tank with immersion heater for low-temperature sodium pentaborate solution stor age, two high-pressure positive displacement pumps for injecting the solution into the reactor core, two explosive actuated shear plug valves
 
for isolating the liquid poison from the RPV until required, an in-vessel sparger ring, a test tank, two reactor coolant isolation check valves, pressure relief valves and associated piping, valves, instrumentation and controls.
The liquid poison system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the liquid poison system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the liquid
 
poison system performs functions that support fire protection, EQ, and ATWS.
The component types subject to an AMR include the liquid poison tank, the liquid poison accumulators, liquid poison pumps, and the connecting piping, fittings and valves. It also
 
includes the NSR portions starting at the test tank suction lines to the pumps and return lines to
 
the test tank. The demin water makeup to the test tank and flush for the pumps is also subject
 
to an AMR, as are the drains lines from the test tank, pumps, poison tank, and discharge line to
 
the reactor.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary 2-77
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.11-1, the applicant identified the following liquid poison system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* pumps
* tanks
* valves 2.3A.3.11.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.11 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.11 identified an area in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
In RAI 2.3-3, dated October 11, 2005, the staff stated that the liquid poison system contains two elements that monitor the liquid poison storage tank temperature. One of these components is within the scope of license renewal since it is an SR component. The other component is NSR
 
and has no license renewal intended function. The in-scope temperature element itself is an
 
active component and, therefore, not subject to AMR. However, the temperature sensor is
 
housed in a thermowell that is subject to AMR. Therefore, the staff requested that the applicant
 
identify which is the in-scope temperature element, TE 41-35 or TE 41-28.
In its response, by letter dated October 28, 2005, the applicant indicated that the thermowell for temperature element 41-28 is SR and is within the scope of license renewal. Temperature
 
element 41-28 is SR because it monitors the sodium pentaborate solution in the liquid poison
 
storage tank and provides input to the temperature controller that drives the heater that
 
maintains the temperature in the solution within the proper range. Therefore, the staff's concern
 
described in RAI 2.3-3 is resolved.
2.3A.3.11.3  Conclusion
 
The staff reviewed the ALRA and RAI response to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were 2-78 identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the liquid poison system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the liquid poison system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.12  NMP1 Miscellaneous Non-Contaminated Vents and Drains System 2.3A.3.12.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.12, the applicant described the miscellaneous non-contaminated vents and drains system. The miscellaneous non-contami nated vents and drains system is designed to route the non-contaminated effluents to floor drains, building sumps, the discharge tunnel, and the turbine building equipment drain tank.
The failure of NSR SSCs in the miscellaneous non-contaminated vents and drains system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.A.12-1, the applicant identified that the piping and fittings component type of the miscellaneous non-contaminated vents and drains system is within the scope of license
 
renewal and subject to an AMR.
2.3A.3.12.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.12 and UFSAR Section XII.A.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.12.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the miscellaneous non-contaminated vents and drains system
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and 2-79 the miscellaneous non-contaminated vents and drai ns system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.13  NMP1 Neutron Monitoring System 2.3A.3.13.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.13, the applicant described the neutron monitoring system. The neutron monitoring system monitors neutron flux le vel, in the reactor, in three separate ranges:
source range, intermediate range, and power range. This system also includes the capability to
 
calibrate the local power range monitors during normal operation.
The source range monitoring and intermediat e range monitoring systems are equipped with mechanically retractable detector assemblies which allow the operator to insert the detectors
 
into the reactor core, and then retract the detectors to a low neutron flux region below the core
 
when the proper point in reactor operation is reached. The local power range monitoring
 
detectors are installed at fixed locations in the reactor core. The average power range
 
monitoring system utilizes the signals from the local power range monitoring detectors to provide average power range signals for monitoring.
The neutron monitoring system also includes the traversing in-core probe system which provides the capability to calibrate the local power range monitors during normal operation. The
 
traversing in-core probe system consists of four identical trains, each containing ionization
 
chamber detectors, indexing mechanism, ball va lve, shear valve, chamber shield, drive mechanism and drive control unit. The drive mec hanism drives the traversing in-core probe detector through the ball and shear valves and indexing mechanism into calibration tubes and
 
then guide tubes located in the reactor core. The ball and shear valves function as reactor
 
coolant isolation valves if a leak were to occur in a calibration or guide tube. The drive
 
mechanisms, indexer mechanisms and calibration and guide tubes are purged continuously with
 
nitrogen gas.
The neutron monitoring system contains SR components that are relied upon to remain functional during and following DBEs.
The components subject to an AMR include the four traversing in-core probe system ball valves and their associated guide tubes from the shear valves to the containment penetration. The dry
 
tubes for source range monitoring and intermediate range monitoring detectors are not included
 
in the system boundary. The dry tubes are included in the RPV internals (Section 2.3.1.A.2).
The intended function, within the scope of license renewal, is to provide pressure retaining boundary.In ALRA Table 2.3.3.A.13-1, the applicant identified the following neutron monitoring system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping
* valves 2-80 2.3A.3.13.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.13 and the UFSAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.13.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the neutron monitoring system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the neutron monitoring system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.14  NMP1 Process Radiation Monitoring System 2.3A.3.14.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.14, the applicant described the process radiation monitoring system.
The process radiation monitoring system is designed to monitor radiation levels of liquid and
 
gaseous processes throughout the plant, assist in controlling the release of radioactive
 
byproducts, and provide for personnel safety by warning of abnormal radiation levels. The
 
process radiation monitoring system consists of the following independent subsystems: main
 
steam line radiation monitoring, air-ejector off-gas radiation monitoring, stack effluent radiation
 
monitoring, process liquid radiation monitoring, reactor building ventilation radiation monitoring, emergency cooling condenser vent monitor, and refueling bridge high radiation monitor. Each of
 
these subsystems consists of an appropriate detector and monitor and provide readouts, alarms and computer points to aide the operator. Only the air-ejector off-gas, stack effluent and
 
process liquid radiation monitors draw a sample from their respective process streams. These
 
subsystems were evaluated and determined to not be within the scope of license renewal. The
 
remaining subsystems measure radiation levels directly on the process piping or local area.
The process radiation monitoring system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the process radiation monitoring
 
system performs functions that support EQ.
2-81 The in-scope components for the process radiati on monitoring system are active components.
Therefore, there are no components requiring an AMR for the process radiation monitoring system.2.3A.3.14.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.14 and UFSAR Section VIII.C.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.14.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the process radiation monitoring system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the process radiation
 
monitoring system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.15  NMP1 Radioactive Waste Disposal Building HVAC System 2.3A.3.15.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.15, the applicant described the radioactive waste disposal building HVAC system. The radioactive waste disposal building HVAC system provides heating and ventilation for personnel comfort, equipment protection and for controlling possible radioactivity
 
release to the atmosphere. Air is drawn into the system through an inlet louver, filter and heater
 
by two supply fans and distributed throughout the waste building and waste building extension.
 
An air outlet is located in each room and at each piece of equipment where radioactive
 
contamination could be released. The exhaust ductwork leads to two trains of inlet and outlet
 
dampers, roughing and high efficiency filters, and exhaust fans. The discharge from all of the
 
exhaust fans travels through one of three backd raft dampers and exits the station through thevent stack.
The radioactive waste disposal building HVAC system contains SR components that are relied upon to remain functional during and following DBEs.
The intended function, within the scope of license renewal, is to provide pressure retaining boundary.
2-82 In ALRA Table 2.3.3.A.15-1, the applicant identified that the dampers component type of the radioactive waste disposal building HVAC system is within the scope of license renewal and
 
subject to an AMR.
2.3A.3.15.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.15 and UFSAR Section III.C.1.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.15.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the radioactive waste disposal building HVAC system components
 
that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the radioactive
 
waste disposal building HVAC system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.16  NMP1 Radioactive Waste System 2.3A.3.16.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.16, the applicant described the radioactive waste system. The radioactive waste system is designed to meet the following objectives:
* collect and process all radioactive waste generated without limiting normal station operation
* collect and process radioactive wastes for disposal, or transfer to a vendor for processing and disposal
* release radioactive material to the environment in a controlled manner so that all releases are within the limits of 10 CFR 20 and the TSs
* retain radioactive wastes, if they accidenta lly leak from the systems, so that they can be recovered and reprocessed 2-83 The radioactive waste system consists of t he gaseous waste system, liquid waste system, and solid waste system. Gaseous radioactive wastes include airborne particulates as well as gases
 
vented from process equipment. Sources of gas eous waste activity are the offgas system effluent, steam-packing exhauster system effl uent, and building ventilation exhausts. The liquid waste system processes the liquids collected in equipment drains and floor drains in areas that
 
are potentially contaminated with radioactive materials. The wastes are collected in the floor
 
drain sumps located within the drywell, the reactor building (RB), the turbine building (TB), the
 
radioactive waste solidification and storage building, the offgas building, and the waste disposal
 
building (WDB). The liquids in these floor drain sumps are pumped into the floor drain collector, waste neutralizer tank, or utility collector tank, which are located in the WDB. The solid waste
 
system processes spent resins, filter sludge, and concentrated waste. It also is designed for
 
collection and shipment of lowlevel solids. Wastes may be processed or solidified onsite, or
 
transferred to a vendor for processing.
The radioactive waste system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the radioactive waste system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the
 
radioactive waste system performs functions that support EQ.
The intended functions within the scope of license renewal include the following:
* provides flood protection barrier
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.16-1, the applicant identified the following radioactive waste system
 
component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow element
* heat exchangers
* piping and fittings
* pumps
* separator
* tanks
* valves 2.3A.3.16.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.16 and UFSAR Section XII.A using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
2-84 In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.16 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 RAIs 2.3.3.A.16-1 through 2.3.3.A.16-3, dated November 19, 2004, the staff requested that the applicant clarify inconsistencies between the original LRA and LR drawings that the staff
 
encountered in its review. The applicant's response, by letter dated December 22, 2004, has
 
been subsequently incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawings correcting the inconsistencies and accurately depicting all the components subject to AMR, including those subject under 10 CFR 54.4(a)(2). Therefore, the staff's concerns described in
 
RAIs 2.3.3.A.16-1 through 2.3.3.A.16-3 are resolved.
In RAI 2.3.3.A.16-4, dated November 19, 2004, the staff stated that LR drawing LR-18006-C, sheet 3 shows piping sleeves for two pipelines as within the scope of license renewal and
 
subject to an AMR. The piping sleeves are passive and long-lived components. Therefore, the
 
staff requested that the applicant clarify if these components are included with a component
 
type which is listed in original LRA Table 2.3.3.A.16-1 or justify the exclusion of these
 
components from subject to an AMR in accordance with the requirements of
 
10 CFR 54.21(a)(1).
The staff further stated that LR drawing LR-18006-C, sheet 3 shows two pipelines from the N 2 leak test on another LR drawing to the above-mentioned sleeve pipes as subject to an AMR.
The AMR boundary flag for one pipeline indicates that this pipeline is included in the
 
containment system. No boundary flag is shown for the other pipeline. Therefore, the staff
 
requested that the applicant clarify whether these pipelines are included in the NMP1
 
radioactive waste system, or, if not, show the location of the radioactive waste AMR boundary
 
interface with other license renewal systems.
In its response, by letter dated December 22, 2004, the applicant stated that the sleeve pipesrepresent primary containment penetrations X-25 and X-26, respectively. These penetrations
 
are subject to AMR and are addressed in original LRA Section 2.4.A.1. In addition, the applicant
 
clarified that both these lines should have a containment boundary flag. However, the boundary
 
flag for the latter pipeline was inadvertently omitted.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.16-4 acceptable because it adequately clarified that the sleeve pipes are part of the primary containment
 
structure penetration and are addressed in original LRA Section 2.4.A.1. Therefore, the staff's
 
concern described in RAI 2.3.3.A.16-4 is resolved.
2-85 In RAI 2.3.3.A.16-5, dated November 19, 2004, the staff stated that LR drawing LR 18018-C, sheet 1 shows the pipeline from two shutdown cooling heat exchangers as being subject to an
 
AMR. However, the pipeline from the shutdown cooling heat exchanger is shown as excluded
 
as subject to an AMR, although an AMR boundary flag indicates that this line should be within
 
the scope of the radioactive waste system. Therefore, the staff requested that the applicant
 
clarify whether this is an inadvertent error in highlighting the LR drawing, or, if not, explain how
 
the latter pipeline differs from the former pipelines.
In addition, the staff stated that LR drawing LR 18045-C, sheet 7 shows the shutdown cooling system drains line, which appears to be the continuation of the above-mentioned pipelines to
 
the reactor building equipment drain tank (RBEDT). However, an AMR boundary flag indicates
 
that the portion of this line that is shown on this drawing is within the scope of the compressed
 
air system (CAS). Therefore, the staff requested that the applicant to explain why this line is
 
included in the compressed air system.
In its response, by letter dated, December 22, 2004, the applicant stated that LR drawing LR-18018-C is incorrect for the pipeline from the shutdown cooling heat exchanger to the
 
RBEDT and should have been highlighted in red. The applicant provided corrections to the
 
boundary flag locations and locations on the LR drawings.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.16-5 acceptable because it stated that the LR drawings are incorrect and identified the required corrections to
 
the drawings. Therefore, the staff's concern described in RAI 2.3.3.A.16-5 is resolved.
In RAI 2.3.3.A.16-6, dated November 19, 2004, the staff stated that LR drawings show the pressure and level instruments' drain lines and their associated components (fittings and
 
valves) tie in to the pipeline which runs to the RBEDT. That pipeline is shown on these drawings
 
as within the scope of license renewal and subject to an AMR. Also, another LR drawing shows
 
a pipeline which connects fuel pool cooling system drains to the reactor building drain tanks as
 
subject to an AMR. However, one of the previous LR drawings shows that pipeline as being
 
excluded as subject to an AMR. Also, this pipeline is not highlighted in red on that LR drawing, although an AMR boundary flag shows it as being within the scope of the RWS. Further, this
 
AMR boundary flag indicates that a portion of the pipeline from the fuel pool cooling drains on
 
an LR drawing is within the scope of the CAS.
Therefore, to resolve the above discrepancies, the staff requested that the applicant:
  (a)Provide drawings or descriptive information that shows how the instrumentation drains header connects to the fuel pool cooling system drains pipeline.  (b)Provide drawings or descriptive information that clearly identify portions of the radioactive waste system to RBEDT which are within the scope of license renewal and
 
subject to an AMR, and eliminate inconsistencies between the above-mentioned
 
drawings.In its response to RAI 2.3.3.A.16-6a, by letter dated December 22, 2004, the applicant stated:
The instrument drain headers identified in the RAI do not connect to the fuel pool cooling system drains pipeline. For NMP1, the line identification (i.e., 89-2-C) is not a unique 2-86 piping component number. Using the line identification legend shown on drawing LR-18000-C, Sheet 1 (location E3), the line identifier "89-2-C" indicates a pipe in
 
system 89 (RWS) that is 2 inches in diam eter and made of carbon steel. Therefore, this identification applies to every 2-inch, carbon steel line in system 89 (RWS) regardless of
 
its function. This identification does not, therefore, imply a connection between the
 
identically designated piping segments described in this RAI.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.16-6a acceptable because the applicant adequately explained why there is no connection between the pipelines
 
in question. Therefore, the staff's concern described in RAI 2.3.3.A.16-6a is resolved.
In its response to RAI 2.3.3.A.16-6b, by letter dated December 22, 2004, the applicant stated:
The depiction of the input lines to the RBEDT on drawing LR-18045-C, Sheets 7 and 7A, that are contrary to the above-referenced description are drafting errors. AMR boundary
 
flag designators contrary to this description, including the ones referencing the CAS, are
 
also drafting errors.
As stated in the response to RAI 2.3.3.A.16-1, drawing LR-18045-C, Sheet 7A, provides no additional information to that shown on Sheet 7 and should, therefore, be
 
disregarded.
Based on it review of the applicant's response, the staff found that it was incomplete and that its review of original LRA Section 2.3.3.A.16 could not be completed. Although the applicant stated
 
that the depiction of the input lines to the RBEDT on drawing LR-18045-C, sheets 7 and 7A, are
 
contrary to the above-referenced description due to drafting errors, it did not adequately identify
 
which of the LR drawings are correct. In addition, the applicant stated that LR drawing
 
LR-18045-C, sheet 7A does not add any information to LR-18045-C, sheet 7 and should be
 
disregarded; however, the applicant did not explain the inconsistency between these two
 
sheets. As a result, the staff held a teleconference with the applicant on January 27, 2005, to
 
discuss information necessary to resolve its concern described in RAI 2.3.3.A.16-6b. The
 
product of the teleconference was an agreement by the applicant to transmit the required
 
information in a follow-up letter.
In its follow-up response, by letter dated February 11, 2005, the applicant provided detailed descriptive information that resolved RAIs 2.3.3.A.16-1 through 2.3.3.A.16-3. That response is
 
also applicable to the concern in 2.3.3.A.16-6b and provides complete resolution.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.16-6b, including the information in the letter dated February 11, 2005, acceptable because it adequately described
 
all of the portions of the NMP1 radioactive wast e system. Additionally, this information described the impact on the original LRA. Therefore, the staff's concern described in RAI 2.3.3.A.16-6b is
 
resolved.2.3A.3.16.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a 2-87 review to determine whether any components that should be subject to an AMR had not been identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
radioactive waste system components that are within the scope of license renewal, as required
 
by 10 CFR 54.4(a), and the radioactive waste system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.17  NMP1 Reactor Building Closed Loop Cooling Water System 2.3A.3.17.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.17, the applicant described the reactor building closed loop cooling (RBCLC) water system. The RBCLC water system is designed to provide demineralized water to cool reactor auxiliary equipment located in the primary containment, RB, TB, and WDB. The closed loop permits isolation of systems containi ng radioactive liquids from the service water.
The RBCLC water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RBCLC water system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the RBCLC
 
water system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.3.A.17-1, the applicant identified the following RBCLC water system component types that are within the scope of license renewal and subject to an AMR:
* actuator
* bolting
* filters/strainers
* flow elements
* heat exchangers
* orifices
* piping and fittings
* pumps
* temperature elements 2-88
* valves 2.3A.3.17.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.17 and UFSAR Section X.D using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.17 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 RAIs 2.3.3.A.17-1 and 2.3.3.A.17-2, dated November 19, 2004, the staff requested that the applicant clarify information given on a license renewal boundary drawing concerning SSC's
 
that are within scope of license renewal in accordance with 10 CFR 54.4(a). The applicant
 
response, by letter dated December 22, 2004, has been subsequently incorporated in the ALRA
 
as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided revised LR drawings which identify SSC's in scope and subject to AMR under 10 CFR 54.4(a)(2). Based on its review of the
 
information submitted in the ALRA, the staff's concerns described in RAIs 2.3.3.A.17-1 and
 
2.3.3.A.17-2 are resolved.
2.3A.3.17.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
RBCLC water system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the RBCLC water system components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3A.3.18  NMP1 Reactor Building HVAC System 2.3A.3.18.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.18, the applicant described the reactor building HVAC system. The reactor building HVAC system is designed to control the RB atmosphere within limits during 2-89 normal and emergency operating conditions. Additiona lly, the system is an alternative system for venting the primary containment to the atmosphere, if necessary. The reactor building HVAC
 
system consists of the reactor building nor mal ventilation system and the reactor building emergency ventilation system. The reactor buildi ng normal ventilation system provides clean fresh air to the RB, removes air from areas where excessive heat concentration and potential
 
airborn contamination exist, and maintains a negative pressure in the RB relative to the
 
atmosphere by regulating the amount of outside air introduced into the building. The clean air is
 
required to remove air from areas where excessive heat concentration exists. The normal
 
ventilation system automatically isolated upon in itiation of the emergency ventilation system.
The reactor building emergency ventilation system removes air from areas where excessive heat concentration and potential airborne contamination exists, maintains a negative pressure in
 
the RB relative to atmosphere, and removes and filters contaminated air during accident
 
conditions. The reactor building emergency ventilati on system is a standby system consisting of redundant filter trains, which operates in the event of an accident or normal ventilation failure.
 
This system can also be used to process the drywell and torus atmospheres when venting.
The reactor building HVAC system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the reactor building HVAC system performs
 
functions that support EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides rated fire barrier
* provides pressure retaining boundary In ALRA Table 2.3.3.A.18-1, the applicant identified the following reactor building HVAC system component types that are within the scope of license renewal and subject to an AMR:
* blowers
* bolting
* ducting
* filters
* flow elements
* piping and fittings
* temperature elements
* valves and dampers 2.3A.3.18.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.18 and UFSAR Sections VI.E.2 and VII.H using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not 2-90 omitted any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.18.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the reactor building HVAC system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the reactor building HVAC system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.19  NMP1 Reactor Water Cleanup System 2.3A.3.19.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.19, the applicant described the RWCU system. The RWCU system is designed to maintain high reactor water purity in order to: minimize deposits on fuel clad
 
surfaces by reducing the amount of water-borne impurities in the primary system and reduce the secondary sources of beta and gamma radiation resulting from the deposition of corrosion
 
products, fission products, and impurities in the primary system. The RWCU system continuously purifies a portion of the reactor recirculation flow and reactor bottom head drain
 
flow with a minimum of heat loss from the cycle. Water is normally removed at reactor pressure
 
from one of the reactor recirculation loops and the reactor bottom head drain line, cooled in
 
regenerative and non-regenerative heat exchangers, reduced in pressure, filtered, demineralized, and pumped through the shell side of the regenerative heat exchanger to the
 
RPV through the FW/HPCI system. Whenever reactor pressure is insufficient to maintain
 
suction pressure at the main cleanup pumps, an auxiliary pump is used.
The RWCU system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RWCU system could potentially prevent
 
the satisfactory accomplishment of an SR function. In addition, the RWCU system performs
 
functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.19-1, the applicant identified the following RWCU system component types that are within the scope of license renewal and subject to an AMR:
* bolting 2-91
* heat exchangers
* filters
* flow elements
* flow gauges
* piping and fittings
* pumps
* tanks
* valves 2.3A.3.19.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.19 and UFSAR Section X.B using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.19 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.A.19-1, dated November 19, 2004, the staff stated that drawing LR-1809-C, sheet 1 shows oil coolers for the clean-up pumps to be within the "CU" system boundary and requiring
 
an AMR. The original LRA Table 2.3.3.A-19-1 lists heat exchangers as a component type;
 
however, original LRA Table 3.3.2.A-17-1 does not include heat exchangers with a lubricating
 
oil environment and original LRA Section 3.3.2.A.17 does not list lubricating oil as an
 
environment to which the RWCU system is exposed. Therefore, the staff requested that the
 
applicant confirm that the clean-up pump oil coolers have been properly evaluated within the
 
original LRA or justify their exclusion from requiring an AMR.
In its response, by letter dated December 22, 2004, the applicant stated that the LR drawing LR-18009-C, sheet 1, shows the cooling water side of the heat exchangers as being subject to
 
AMR. This is because of the "Pressure Boundary" intended function for the RBCLC system. The
 
shell side of the heat exchanger is not SR so it is not shown as within the scope of license
 
renewal (depicted in black on the drawing), and the heat exchanger itself does not have an LR
 
intended function of heat transfer. Therefore, the drawing boundary flags are incorrect. The "LR-CU" side of each of those flags should be solid blue. Consistent with original LRA
 
Section 2.3.3.A.19, the pump oil coolers are within the scope of license renewal and subject to
 
AMR to meet 10 CFR 54.4(a)(2), since they are NSR equipment containing liquid in the vicinity
 
of SR components. Per LR drawing convention, components within the scope of license renewal and subject to an AMR for criterion 10 CFR 54.4(a)(2) only are not identified in red. The only
 
heat exchanger within the RWCU system that is subject to AMR for criterion 10 CFR 54.4(a)(1)
 
is the non-regenerative heat exchanger, whic h does not have a lube oil environment.
2-92 Based on its review, the staff found that the applicant's response was incomplete and that its review of original LRA Section 2.3.3.A.19 could not be completed because:
* Although the applicant explained that the pump oil cooler is within the scope of license renewal and subject to an AMR in accordance with 10 CFR 54.4(a)(2), original LRA
 
Tables 2.3.3.A.19-1 and 3.3.3.A-17-1 do not include heat exchangers with the intended
 
function to prevent failure from affecting SR equipment in a lubricating oil environment.
* In its response, the applicant stated that the drawing boundary flags are incorrect and the "LR-CU" side of each of those flags should be solid blue. This does not appear to be
 
correct since the oil cooler tubes are within the scope of license renewal with the
 
pressure boundary intended function for the reactor building closed loop cooling system.
As a result, the staff held a teleconference with the applicant on January 27, 2005 to discuss information necessary to resolve the staff's concern described in RAI 2.3.3.A.19-1. The product
 
of this teleconference was an agreement by the applicant to transmit the required information in
 
a follow-up letter.
In its follow-up response, by letter dated February 11, 2005, the applicant stated that the RWCU pump oil coolers are within the scope of license renewal since they are a pressure boundary for
 
the reactor building closed RBCLC system. As such, only the end covers, tube sheets and tubes
 
exposed to RBCLC water are within the scope of license renewal. The external surface of the
 
tubes exposed to the lubricating oil are within the scope of license renewal, but have no aging
 
effects requiring management.
In the ALRA, submitted by the applicant on July 14, 2005, ALRA Tables 2.3.3.A.19-1 and 3.3.3.A-17-1 are revised and now include the heat exchangers with the intended function to
 
prevent failure from affecting SR equi pment in a lubricating oil environment.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.19-1 acceptable because the applicant stated that the pump oil cooler is within the scope of license renewal and
 
subject to an AMR and the applicant clarified that the drawing boundary flags are incorrect and
 
that the tubes of the RWCU heat exchanger should have been shown within the scope of
 
license renewal and subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.A.19-1 is resolved.
In RAI 2.3.3.A.19-2, dated November 19, 2004, the staff requested that the applicant clarify the inconsistencies between the original LRA and LR drawings that the staff encountered in its
 
review. The applicant response, by letter dated December 22, 2004, has been subsequently
 
incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawing correcting the inconsistencies and accurately depicting all the components subject to AMR, including those subject under criterion 10 CFR 54.4(a)(2). Therefore, the staff's concern
 
described in RAI 2.3.3.A.19-2 is resolved In RAI 2.3.3.A.19-3, dated November 19, 2004, the staff stated that drawing LR-18009-C, sheet 1 shows piping and penetration downstream of a check valve as not subject to an AMR;
 
however, drawing LR-18006, sheet 2 shows this same piping as subject to an AMR. Therefore, 2-93 the staff requested that the applicant explain the apparent discrepancy between these drawings and confirm that the piping downstream of the check valve and penetration on the first drawing
 
received an AMR.
In its response, by letter dated December 22, 2004, the applicant stated that drawing LR-18009-C, sheet 1 is incorrect. The applicant explained that the piping and penetration
 
downstream of valve CU-37 (CKV-63.1-02) are subject to an AMR. The penetration itself is part
 
of the primary containment structure, which is addressed in original LRA Sections 2.4.A.1 and
 
3.5.2.A.1. The penetration piping is covered in the RWCU system, which is covered in original
 
LRA Sections 2.3.3.A.19 and 3.3.2.A.17. In addition, the applicant stated that drawing
 
LR-18006-C, sheet 2, is incorrect at the referenced location. In its response, the applicant
 
provided corrections to the locations of the boundary flags on this drawing and also provided
 
revisions to original LRA Section 2.3.3.A.19.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.19-3 acceptable because it adequately explained that the LR drawings in question are incorrect, provided
 
corrections to the locations of boundary flags on LR drawings, and provided the revisions
 
required to original LRA 2.3.3.A.19-3. Therefore, the staff's concern described in
 
RAI 2.3.3.A.19-3 is resolved.
In RAI 2.3.3.A.19-4, dated November 19, 2004, the staff stated that drawing LR-18009-C, sheet 1 shows piping upstream of a valve as not subject to an AMR; however, drawing LR-18006-C, sheet 1 shows this same piping as subject to an AMR. Therefore, the staff
 
requested that the applicant explain the apparent discrepancy between these drawings and
 
confirm that the identified piping does not require an AMR, as indicated on drawing
 
LR-18009-C, sheet 1.
In its response, by letter dated December 22, 2004, the applicant stated that with respect to the inconsistency between drawings LR-18009-C, sheet 1 and LR-18006-C, sheet 1, the former
 
drawing is correct. However, as stated in original LRA Section 2.3.3.A.19, the NSR portions of
 
the RWCU system are within the scope of license renewal per 10 CFR 54.4(a)(2) and subject to
 
AMR. Per the convention adopted for the LR drawings, components within the scope of license
 
renewal and subject to an AMR for the 10 CFR 54.4(a)(2) criterion only are not identified in red.
 
Therefore, on LR drawing LR-18009-C, sheet 1, the components shown in red and black are
 
actually in-scope and subject to AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.19-4 acceptable because the applicant adequately clarified the inconsistency between the two LR drawings.
 
Therefore, the staff's concern described in RAI 2.3.3.A.19-4 is resolved.
2.3A.3.19.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
RWCU system components that are within the scope of license renewal, as required by 2-94 10 CFR 54.4(a), and the RWCU system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.20  NMP1 Sampling System 2.3A.3.20.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.20, the applicant described the sampling system. The sampling system provides for the sampling of liquid, steam and gas es from various systems in the plant under all operating modes. Liquid samples can be obtained from the RPV, spent fuel pool, RWCU, core
 
spray, torus, liquid poison, condensate, feedwater, RBCLC, turbine building closed loop cooling (TBCLC), circulating water, radioactive waste disposal and make-up systems. Steam samples
 
from the main steam system are obtainable.
Gaseous samples can be obtained from primary containment, vent stack and off gas systems.
The sampling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the sampling system could potentially prevent
 
the satisfactory accomplishment of an SR func tion. In addition, the sampling system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.20-1, the applicant identified the following sampling system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchangers
* piping and fittings
* pumps
* rupture disc
* valves 2.3A.3.20.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.20 and UFSAR Section VIII.C.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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 2-95 had identified as being within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.20 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.A.20-1, dated November 19, 2004, the staff requested that the applicant clarify drawing inconsistencies that the staff encountered in its review. The applicant response, by
 
letter dated December 22, 2004, has been subsequently incorporated in the ALRA as discussed
 
below.In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawings correcting the inconsistencies and accurately depicting all the components subject to AMR, including those subject under criterion 10 CFR 54.4(a)(2). Therefore, the staff's concern
 
described in RAI 2.3.3.A.20-1 is resolved.
In RAI 2.3.3.A.20-2, dated November 19, 2004, the staff stated that drawing LR-18041-C, sheet 1 shows condensate sampling points at BV 110-72 and BV 110-73 as not subject to an
 
AMR. The LR drawing for the condensate system indicates that the condensate line leading to
 
CS 50-233 is within the condensate system AMR boundary flags and subject to an AMR.
 
Therefore, the staff requested that the applicant identify where the AMR boundary exists
 
between the condensate system and the sampling points at BV 110-72 and BV 110-73 and
 
explain the basis for excluding these blocking valves as subject to an AMR.
In its response, by letter dated December 22,2004, the applicant stated that drawing LR-18041-C, sheet 1 is incorrect. The AMR boundary on this drawing should include
 
valves 110-251, 110-252, and 110-598, and all associated piping up to and including the
 
condensate pumps and the main condenser. The applicant also noted that the component
 
referenced in the RAI should read "CE 50-233" not "CS 50-233."
In addition, the applicant further clarified that per original LRA Section 2.3.4.A.20, the sampling system liquid-filled piping, fittings, equipment on LR drawing LR-18041-C, sheet 1, that are shown in black are also in-scope for LR and subject to AMR for criterion 10 CFR 54.4(a)(2)
 
since they are liquid-filled components in the vicinity of SR components. Per LR drawing convention, only components in-scope for LR and subject to AMR for 10 CFR 54.4(a)(2) are not
 
to be shown in red on LR drawings.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.20-2 acceptable because it concurred with the applicant that the sampling LR drawing AMR boundary should
 
include valves and all associated piping up to and including condensate pumps, back to the
 
main condensers, but were inadvertently left un-highlighted on the LR drawing. The staff
 
concludes that there is reasonable assurance that the components were correctly included
 
within the scope of license renewal and subject to an AMR. Therefore, the staff's concern
 
described in RAI 2.3.3.A.20-2 is resolved.
In RAIs 2.3.3.A.20-3, 2.3.3.A.20-4, and 2.3.3.A.20-5, dated November 19, 2005, the staff requested that the applicant clarify information given on LR drawings concerning SSC's within 2-96 the scope of license renewal per 10 CFR 54.4(a). The applicant response, by letter dated December 22, 2004, has been subsequently incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant revised the LR drawing which identifies all SSC's within the scope of license renewal and subject to AMR including those in scope under criterion
 
10 CFR 54.4(a)(2). Therefore, the staff's concerns described in RAIs 2.3.3.A.20-3, 2.3.3.A.20-4, and 2.3.3.A.20-5 are resolved.
In RAI 2.3.3.A.20-6, dated November 19, 2004, the staff indicated that 10 CFR 54.4(a)(2) states that all NSR SSC's whose failure could prevent the satisfactory accomplishment of any of the
 
functions described in 10 CFR 54.4(a)(1) is within the scope of license renewal. Drawing
 
LR-18041-C, sheet 7 shows heat exchangers 122-44 and 122-45 outside the AMR boundary
 
flags of the reactor building closed loop cooling water system and the sampling system.
 
However, these heat exchangers are shown within the reactor building closed loop cooling
 
water system and sampling system AMR boundar y on drawing LR-18022-C, sheet 2. Since failure of either the tube side or shell side of these heat exchangers could affect the integrity of
 
the reactor building closed loop cooling water system, the staff requested that the applicant
 
explain the basis for excluding these heat exchangers as subject to an AMR as indicated on
 
drawing LR-18041-C, sheet 7.
In its response, by letter dated December 22, 2004, the applicant stated that the post accident sample system is NSR and therefore, supplying reactor building closed loop cooling water to
 
post accident sample coolers is an NSR function. The reactor building closed loop cooling water
 
system line supplying the post accident sample system includes an excess flow check valve to prevent high flow rates from a downstream br eak and the return line includes a check valve which prevents back flow from the reactor building closed loop cooling water system.
The applicant further stated that drawing LR-18041-C, sheet 7 correctly shows the boundary at the check valves based on the above evaluation. However, drawing LR-18022-C, sheet 2
 
incorrectly shows the sample coolers as subject to an AMR. Based on the function of the
 
excess flow check valve and the return line check valve, the NSR portion of the reactor building
 
closed loop cooling water system cannot affect the performance of the required SR function.
 
The boundary at the check valves meets the requirement of 10 CFR 54.4(a)(2). Therefore, drawing LR-18022-C, sheet 2 should be corrected by removing the AMR boundary from the
 
sample coolers and associated piping and placing the reactor building closed loop cooling water
 
system scope boundary flag at the drawing continuation flags. However, the applicant further
 
explained that even though the subject heat exchanger shells should be shown in black, per
 
original LRA Section 2.3.3.A.20, they are still within the scope of license renewal and subject to
 
an AMR in accordance with 10 CFR 54.4(a)(2) since they are liquid-filled components in the
 
vicinity of SR components.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.20-6 acceptable because it adequately explained that the NSR sample coolers are within the scope of license
 
renewal in accordance with the 10 CFR 54.4(a)(2) only and, as such, were highlighted (red
 
colored) on the LR drawing in error. The applicant also clarified that the AMR boundary on the
 
LR drawing at the check valves meets the requirement of 10 CFR 54.4(a)(2) and the boundary
 
flag on the LR drawing should be moved from the sample coolers to the drawing continuation
 
flag. The staff concludes that there is reasonable assurance that the components were correctly 2-97 included within the scope of license renewal and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.A.20-6 is resolved.
In RAI 2.3.3.A.20-7, dated November 19, 2004, the staff stated that drawing LR-18041-C, sheet 2 shows the air supply to AOV 110-83A as subject to an AMR for the NMP1 sampling
 
system. The staff believed that this valve shoul d be evaluated as part of the instrument air system. Therefore, the staff requested that the applicant confirm that this valve and its
 
environment are within the sampling syst em or explain this apparent discrepancy.
In its response, by letter dated December 22, 2004, the applicant confirmed that the valve operator is not subject to AMR because it is not liquid-filled. Therefore, it is not within the scope
 
of license renewal. The applicant stated that the LR drawing is incorrect and improperly shows the air supply valve as subject to an AMR. The components in question should not have been
 
highlighted on the LR drawing as being subject to an AMR in accordance with 10 CFR 54.21(a)
 
but were highlighted inadvertently.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.20-7 acceptable because it adequately explained that the air supply valve in question was highlighted (in red
 
color) on the LR drawing in error. This air valve is not necessary for its associated air operated
 
block valve to perform its intended function. Therefore, the air valve in question is not within the
 
scope of license renewal and not subject to an AMR. The staff concludes that there is
 
reasonable assurance that the components were correctly excluded from within the scope of
 
license renewal and from requiring an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.A.20-7 is resolved.
2.3A.3.20.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
sampling system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the sampling system components that are subject to an AMR, as required
 
by 10 CFR 54.21(a)(1).2.3A.3.21  NMP1 Service Water System 2.3A.3.21.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.21, the applicant described the service water system. The service water system is designed to provide a reliable supply of cooling water to various safety and
 
NSR components and systems. Systems cooled by the service water system include the RBCLC water system, TBCLC water system, RB HVAC system, TB HVAC system, and radioactive WDB HVAC system. Service water also is supplied to the screenwash pumps, the radwaste solidification and storage building, and the makeup demineralizer. The service water
 
system is injected with chemicals to control biol ogical growth by the chemical injection system.
2-98 The service water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the service water system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the service water system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.21-1, the applicant identified the following service water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow elements
* piping and fittings
* pumps
* valves 2.3A.3.21.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.21 and UFSAR Section X.F using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.21 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.A.21-1, dated November 19, 2004, the staff requested that the applicant clarify information given on a license renewal boundary drawing concerning SSC's within the scope of 2-99 license renewal in accordance with 10 CFR 54.4(a). The applicant response, by letter dated December 22, 2004, has been subsequently incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawing which identifies all SSC's in scope and subject to AMR including those under criterion
 
10 CFR 54.4(a)(2). Based on review of the information submitted in the ALRA the staff's
 
concern described in RAI 2.3.3.A.21-1 is resolved.
In RAI 2.3.3.A.21-2, dated November 19, 2004, the staff requested that the applicant clarify drawing inconsistencies that the staff encountered in its review. The applicant response, by
 
letter dated December 22, 2004, has been subsequently incorporated in the ALRA as discussed
 
below.In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawings correcting the inconsistencies and accurately depicting all components subject to AMR including
 
those subject under criterion 10 CFR 54.4(a)(2). Based on review of the information submitted
 
in the ALRA the staff's concern described in RAI 2.3.3.A.21-2 is resolved.
2.3A.3.21.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
service water system components that are with in the scope of license renewal, as required by 10 CFR 54.4(a), and the service water system components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3A.3.22  NMP1 Shutdown Cooling System 2.3A.3.22.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.22, the applicant described the shutdown cooling system. The shutdown cooling system is designed to cool reactor water below temperatures and pressures
 
at which the main condenser may be used as a heat sink following reactor shutdown. This
 
system provides the capability to achieve and ma intain a cold shutdown condition by removal of reactor fission product decay heat. The shutdown cooling system consists of reactor coolant
 
isolation valves, three redundant loops each having a pump, heat exchanger and flow control
 
valve, and associated piping, valves, instrumentation and controls. The heater exchangers are
 
cooled by the RBCLC water system.
The shutdown cooling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the shutdown cooling system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the shutdown cooling system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
2-100
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.3.A.22-1, the applicant identified the following shutdown cooling system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow elements
* heat exchangers
* orifices
* piping and fittings
* pumps
* valves 2.3A.3.22.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.22 and the UFSAR Section X.A using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.22 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.A.22-1, dated November 19, 2004, the staff requested that the applicant clarify information given on LR drawing 18018-C, sheet 1 concerning SSC's in scope of license
 
renewal per 10 CFR 54.4(a). The applicant response, by letter dated December 22, 2004, has
 
been subsequently incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided the revised LR drawing which identifies all SSC's in scope of license renewal and subject to AMR including those subject under criterion
 
10 CFR 54.4(a)(2). Based on review of the information submitted in the ALRA, the staff's
 
concern described in RAI 2.3.3.A.22-1 is resolved.
2-101 In RAI 2.3.3.A.22-2, dated November 19, 2004, the staff stated that original LRA Table 2.3.3.A.22-1 does not list temperature elements or thermowells as component types
 
within the shutdown cooling system. Drawi ng LR-18018-C, sheet 1 shows a temperature element within the AMR boundary of the shutdown cooling system. A general note number on
 
the LR drawing states that all temperatur e devices including temperature elements have thermowells. Therefore, the staff requested that the applicant explain the basis for excluding
 
temperature elements and/or thermowells (pressure boundary function) as component types in
 
original LRA Table 2.3.3.A.22-1 as subject to an AMR.
In addition the staff stated that the original LRA Table 2.3.3.A.22-1 does not list bolting as a component type within the shutdown cooling system. Bolted connections appear to be used on
 
a number of flow elements within the shutdow n cooling system. Therefore, the staff also requested that the applicant explain the basis for excluding bolting as a component type in the
 
original LRA Table 2.3.3.A.22-1 as subject to an AMR.
In its response, by letter dated December 22, 2004, the applicant stated:
The thermowell for TE-38-115, "Temperature Primary Element - Water To Reactor Recirc Loop," is constructed of the same material as the piping;
 
therefore, there is no reason to create a thermowell subcomponent for TE-38-115
 
or to list thermowells as a separate component type in [original] LRA
 
Tables 2.3.3.A.22-1 and 3.3.2.A-20. The convention adopted for the [original]
 
LRA was that thermowells made of the same material as the piping were
 
included under the component type of "Piping and Fittings" as being a portion of
 
the pressure boundary of the pipe. Drawing LR-18018-C, Sheet 1, incorrectly
 
highlighted temperature element TE-38-115 as being subject to AMR. It is
 
actually not in-scope for LR. The following additional instruments are also
 
incorrectly shown as being subject to AMR on drawing LR-18018-C, Sheet 1:
 
PT-38-141, PT-38-153, PT-38-148, TE-38-130, and TE-38-136. Pressure
 
transmitters PT-38-141, PT-38-153, and PT-38-148 are in-scope for LR, but are
 
not subject to AMR.
In regard to bolting, the applicant in its ALRA, submitted July 14, 2005, now includes bolting as a component type requiring an AMR in original LRA tables 2.3.3.A.22-1 and 3.3.2.A-20.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.22-2 acceptable.
The applicant adequately clarified that thermowells and bolting are included in the component
 
type of "Piping and Fittings." Additionally, the applicant added carbon steel, "Piping and
 
Fittings," in an air environment with a pressure boundary function to represent the thermowells, and has added bolting to the component types requiring an AMR. The staff agreed that
 
temperature element TE-38-115 is not within the scope of license renewal, and that is because
 
they are active components, the instruments (TEs and PTs) identified in the applicant's
 
response are not subject to AMRs. Therefore, the staff's concern described in RAI 2.3.3.A.22-2
 
is resolved.
2.3A.3.22.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been 2-102 identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
shutdown cooling system components that are wi thin the scope of license renewal, as required by 10 CFR 54.4(a), and the shutdown cooling sy stem components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.23  NMP1 Spent Fuel Pool Filtering and Cooling System 2.3A.3.23.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.23, the applicant described the spent fuel pool filtering and cooling system. The spent fuel pool filtering and cooling system is designed to remove decay heat from
 
the spent fuel assemblies and the impurities from the pool water. This system maintains the
 
temperature and purity of the spent fuel pool water at acceptable levels. Cooling water is
 
supplied to the heat exchangers from the RBCLC water system. Makeup water to the spent fuel
 
storage pool is provided by the condensate and condensate transfer system. The spent fuel
 
pool filtering and cooling system is also used after reactor refueling to drain the reactor internals
 
storage pit and head cavity. Alternate lines allow transport of the water to either the main
 
condenser or to the waste disposal system for processing.
The spent fuel pool filtering and cooling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the spent fuel pool
 
filtering and cooling system could potentially pr event the satisfactory accomplishment of an SR function. In addition, the spent fuel pool filtering and cooling system performs functions that
 
support EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.23-1, the applicant identified the following spent fuel pool filtering and cooling system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers 2-103
* flow elements
* flow gauge
* heat exchangers
* piping and fittings
* pumps
* tanks
* valves 2.3A.3.23.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.23 and UFSAR Section X.H using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.A.23 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
In RAIs 2.3.3.A.23-1 and -2, dated November 19, 2004, the staff requested that the applicant clarify information given on an LR drawing concerning SSC's in scope of license renewal per
 
10 CFR 54.4(a). The applicant's response, by letter dated December 22, 2004, has been
 
subsequently incorporated in the ALRA as discussed below.
In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawings which identify all SSC's within the scope of license renewal and subject to AMR including those
 
subject under criterion 10 CFR 54.4(a)(2). Based on review of the information submitted in the
 
amended LRA the staff's concern described in RAI 2.3.3.A.23-1 and RAI 2.3.3.A.23-2 are
 
resolved.2.3A.3.23.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
spent fuel pool filtering and cooling system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the spent fuel pool filtering and cooling system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-1042.3A.3.24  NMP1 Technical Support Center HVAC System 2.3A.3.24.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.24, the applicant described the technical support center HVAC system.
The technical support center HVAC system is designed to maintain the technical support center
 
temperature and supply tempered, recirculated, and outside air to maintain a suitable
 
environment for emergency response personnel. During the normal mode of operation, air is
 
drawn into the system through a louvered intake, electric heater, filter and cooling coil to the
 
circulating fan. This fan discharges air to the technical support center. Air is exhausted through
 
the exhaust fan to the environment. In the emer gency mode, the normal mode flow path isolates and the supply fan draws air through a separate louvered intake. The air is then directed
 
through a prefilter, HEPA filter, charcoal filter and a second HEPA filter to the suction of the
 
circulating fan. There is no direct exhaust path in the emergency mode as the technical support
 
center is maintained at a positive pressure.
The HVAC system also has a separate exhaust path for the removal of smoke.
The technical support center HVAC system c ontains SR components that are relied upon to remain functional during and following DBEs. In addition, the technical support center HVAC
 
system performs functions that support EQ.
The applicant stated that the in-scope components for the technical support center HVAC system are active components. Therefore, t here are no components requiring an AMR for the technical support center HVAC system.
2.3A.3.24.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.24 and UFSAR Section III.E.1.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.24.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the technical support center HVAC system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the technical support center
 
HVAC system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-1052.3A.3.25  NMP1 Turbine Building Closed Loop Cooling Water System 2.3A.3.25.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.25, the applicant described the TBCLC water system. The TBCLC water system provides demineralized water to c ool various NSR auxiliary equipment in the TB in support of power generation. The closed loop provides isolation of systems containing
 
radioactive liquids from the service water, which returns to the lake.
The failure of NSR SSCs in the TBCLC water system could potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.A.25-1, the applicant identified the following TBCLC water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* heat exchangers
* piping and fittings
* pumps
* tank
* valves 2.3A.3.25.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.25 and UFSAR Section X.E using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-106 2.3A.3.25.3  Conclusion The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the TBCLC water system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the TBCLC water system components that
 
are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.26  NMP1 Turbine Building HVAC System 2.3A.3.26.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.26, the applicant described the turbine building HVAC system. The turbine building HVAC system is designed to pr ovide a continuous flow of fresh tempered air throughout the building, while maintaining a negative atmospheric pressure. This system also
 
has heat and smoke removal capability for three smoke zones and the upper elevation of the
 
TB. The turbine building HVAC system consists of air intakes, filters, electric heating units, flow
 
control dampers, dampers, and ductwork to distribute air to various areas in the TB. Outside air
 
is taken in through louvered, screened penthouses, which supply air to the turbine building
 
HVAC supply fans. The air then passes through filters and heating coils. Exhaust air is directed
 
through a plenum to the stack for discharge and is monitored for radiation. The exhaust system
 
discharges into the plenum, which also receives air from the containment and other buildings.
 
The smoke removal function of the turbine building HVAC system consists of three independent
 
air make-up fans, dampers and ductwork (one for each smoke zone) and automatic isolation
 
dampers and exhaust fans of the normal ventilation system. In addition, there are twelve motor operated roof vents and five sidewall vents.
The turbine building HVAC system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the turbine building HVAC system performs
 
functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides path for release of filtered and unfiltered gaseous discharge
* provides pressure retaining boundary In ALRA Table 2.3.3.A.26-1, the applicant identified the following turbine building HVAC system component types that are within the scope of license renewal and subject to an AMR:
* blowers
* bolting
* ducting
* muffler
* valves and dampers
* vents 2-107 2.3A.3.26.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.26 and UFSAR Section III.A.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.26.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the turbine building HVAC system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the turbine building HVAC system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.27  NMP1 Electric Steam Boiler System 2.3A.3.27.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.27, the applicant described the electric steam boiler system. The electric steam boiler system is designed to supply saturated steam to the radwaste concentrator
 
#12 heat exchanger to support the processing of radioactive waste, the nitrogen vaporizer to
 
support drywell inerting, and the TB decontamination area to support decontamination activities.
 
The system includes a condensate receiver which supplies the condensate to the boiler for
 
generation of saturated steam. The steam is routed through steam piping to the above loads.
The failure of NSR SSCs in the electric steam boiler system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.A.27-1, the applicant identified the following electric steam boiler system component types that are within the scope of license renewal and subject to an AMR:
* boiler
* bolting
* drain trap
* level gauge 2-108
* piping and fittings
* strainer
* valves 2.3A.3.27.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.A.27 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance described in
 
SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.27.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the electric steam boiler system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the electric steam boiler system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.3.28  NMP1 Makeup Demineralizer System 2.3A.3.28.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.A.28, the applicant described the makeup demineralizer system. The makeup demineralizer system is designed to supply batches of demineralized water to fill the
 
demineralized water makeup tank, the condensate storage tanks, and other reservoirs as
 
necessary. It also provides water directly to the liquid poison system, laboratories and sample sinks, and the stator winding liquid cooling syst em. Demineralized water from this system can be used as an alternate source for several plant systems, including the RWCU and CRD
 
systems. The makeup demineralizer system utilizes a portable skid- or truck-mounted demineralized water unit to process service water or city water for use in the station. Water is
 
processed through several components acting as tanks (i.e., precipitator, clearwell, filter and
 
purifier) while pumped to the portable demineralized water unit. The discharge of the portable
 
unit is directed to the demineralized water storage tank and then to the condensate storage
 
tanks and/or other system loads.
The failure of NSR SSCs in the makeup deminera lizer system could potentially prevent the satisfactory accomplishment of an SR function.
2-109 The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity of NSR components to prevent spatial interactions with SR components.
In ALRA Table 2.3.3.A.28-1, the applicant identified the following makeup demineralizer system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* level gauge
* piping and fittings
* pumps
* tanks
* valves 2.3A.3.28.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.A.28 and UFSAR Section X.G.1.0 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.3.28.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the makeup demineralizer system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the makeup demineralizer system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.4  Steam and Power Conversion Systems In ALRA Section 2.3.4.A, the applicant identified the structures and components of the NMP1 steam and power conversion systems that ar e subject to an AMR for license renewal.
The applicant described the supporting structures and components of the steam and power conversion systems in the following sections of the ALRA:
* 2.3.4.A.1NMP1 condensate and condensate transfer system
* 2.3.4.A.2NMP1 condenser air removal and off-gas system
* 2.3.4.A.3NMP1 feedwater/high pressure coolant injection system 2-110
* 2.3.4.A.4NMP1 main generator and auxiliary system
* 2.3.4.A.5NMP1 main steam system
* 2.3.4.A.6NMP1 main turbine and auxiliary systems
* 2.3.4.A.7NMP1 moisture separator reheater steam system The staff's review findings regarding ALRA Sections 2.3.4.A.1 - 2.3.4.A.7 are presented in SER Sections 2.3A.4.1 - 2.3A.4.7, respectively.2.3A.4.1  NMP1 Condensate and Condensate Transfer System 2.3A.4.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.A.1, the applicant described the condensate and condensate transfer system. The condensate system condenses steam exhausted from the lowpressure turbines and the turbine bypass valves. This condensate then becomes the primary water supply to the
 
FW/HPCI system. The main condenser also acts as a collecting basin for various leakage, drains, and relief valve discharges from balance of plant systems. The condensate system also removes impurities from the condensed liquid for re-use as reactor water. The condensate
 
serves as a cooling medium for the off gas system steam jet air ejector condensers, steam entering the condenser when the turbine bypass valves are open, and the turbine exhaust hood
 
spray. Additionally, under emergency conditions such as a small break LOCA, the condensate
 
system supplies water from the main condenser to support the HPCI mode of operation to
 
supply makeup water to the reactor. For license renewal purposes, the condensate system also
 
includes the condensate transfer system. The condensate transfer system supplies various
 
systems and equipment throughout the plant with clean demineralized water. The condensate
 
transfer system takes condensate from the condensate storage tanks (CSTs), which are
 
cross-connected, and delivers the water through one of two redundant pumps.
The condensate and condensate transfer system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the condensate and
 
condensate transfer system could potentially prev ent the satisfactory accomplishment of an SR function. In addition, the condensate and condensate transfer system performs functions that
 
support, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.4.A.1-1, the applicant identified the following condensate and condensate transfer system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* condensate demineralizers 2-111
* filters/strainers
* flow elements
* flow gauges
* flow indicators
* flow orifices
* level observation glasses
* main condenser
* piping and fittings
* pumps
* tanks
* valves 2.3A.4.1.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.A.1 and UFSAR Section XI.B using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.4.A.1 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 2.3.4.A.1-1, dated November 19, 2004, the staff stated that LR drawing 18003, shows an inter-condenser and after-condenser within the scope of license renewal and subject to an
 
AMR. Additionally, two re-combiner condensers are also shown within scope and subject to an
 
AMR; however, original LRA Table 2.3.4.A.1-1 does not include these heat exchangers
 
individually among the list of components subject to an AMR, nor is the generic component type "Heat Exchanger" included in the table. The applicant was asked to justify exclusion of the heat
 
exchangers from original LRA Table 2.3.4.A.1-1.
In its response, dated December 22, 2004, the applicant stated that original LRA Section 2.3.4.A.1 states that the AMR includes the main flow path from the main condenser to
 
the boundary with the feedwater system. This includes the tube side of the recombiner
 
condensers and the inter-condenser (the after-condenser is retired in place and isolated from
 
the condensate system). The tube sides of these condensers are included in the "Piping and
 
Fittings" component type listed in original LRA Table 2.3.4.A.1-1. The recombiner condensers
 
and inter-condenser are evaluated in the within the scope of license renewal for criteria
 
10 CFR 54.4(a)(1) or (3). The subject LR drawing incorrectly shows the shell sides of the
 
recombiner condensers and inter-condenser, as well as the entire after-condenser, as within the
 
scope of license renewal and subject to an AMR.
2-112 The applicant further stated for clarification that all of the liquid-filled components on the subject LR drawing shown in black are within the scope of license renewal and subject to AMR to meet
 
10 CFR 54.4(a)(2), since they are in the turbine building and in the vicinity of SR components;
 
however, per the LR drawing convention, co mponents within the scope of license renewal and subject to AMR for 10 CFR 54.4(a)(2) only, are not shown in red on the LR drawings.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.1-1 acceptable because it adequately explained that the subject LR drawing incorrectly shows the shell sides of
 
the recombiner condensers and inter-condenser, as well as the entire after-condenser, as
 
in-scope for license renewal and subject to AMR. Only the tube side of the recombiner
 
condensers and the inter-condenser are within the scope of license renewal in accordance with
 
10 CFR 54.4(a) and are subject to an AMR in accordance with 10 CFR 54.21(a). The
 
components in question are included in the "Piping and Fittings" component type listed in
 
original LRA Table 2.3.4.A.1-1. The staff concludes that there is reasonable assurance that the
 
components were correctly included within the scope of license renewal and subject to an AMR.
 
Therefore, the staff's concern described in RAI 2.3.4.A.1-1 is resolved.
In RAI 2.3.4.A.1-2, dated November 19, 2004, the staff stated that LR drawing 18008, sheet 1 shows that a valve labeled CT-38, on line 57-3/4 -B, is outside the scope of license renewal and
 
excluded from requiring an AMR. To ensure that the valve has the capability of isolating this
 
line, the staff believed that it should be within scope of license renewal and subject to an AMR.
 
The applicant was asked to justify exclusion of valve CT-38 from the scope of license renewal
 
and from being subject to an AMR.
In its response, by letter dated December 22, 2004, the applicant stated that the LR drawing is incorrect and does not properly show the component within the scope of license renewal and
 
subject to an AMR. The component in question should have been highlighted on the LR drawing
 
showing that it is within the scope of license renewal and is subject to an AMR. However, the
 
component was inadvertently not highlighted. The component in question has been included
 
within the scope of license renewal and is subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.1-2 acceptable because it adequately explained that the component in question is within the scope of license
 
renewal and subject to an AMR but was inadvertently left un-highlighted on the LR drawing. The
 
staff concludes that there is reasonable assurance that the component was correctly included
 
within the scope of license renewal and subject to an AMR. Therefore, the staff's concern
 
described in RAI 2.3.4.A.1-2 is resolved.
In RAI 2.3.4.A.1-3, dated November 19, 2004, the staff requested that the applicant clarify drawing inconsistencies that the staff encountered in its review. The applicant response, by
 
letter dated December 22, 2004, has been subsequently incorporated in the ALRA as discussed
 
below.In its ALRA, dated July 14, 2005, the applicant provided the staff with revised LR drawings correcting the inconsistencies and accurately depicting the components subject to AMR under
 
criterion 10 CFR 54.4. Therefore, the staff's concern described in RAI 2.3.4.A.1-3 is resolved.
In RAI 2.3.4.A.1-4, dated November 19, 2004, the staff stated that LR drawing 18048, shows line 57-4 -B within the scope of license renewal and ending in a continuation flag labeled "relief 2-113 to condensate surge and storage tank." This flag shows a continuation to drawing 18003, location G1; however, at this location on drawing 18003, the continuation of line 57-4-B is
 
shown outside the scope of license renewal. There is no license renewal boundary flag on
 
either of these drawings marking this change in classification, nor any valve present that could
 
isolate the in-scope portion from the out-of-scope portion of the line. Therefore, the staff
 
requested that the applicant explain the absence of a boundary flag and an isolation valve
 
separating the in-scope and out-of-scope portions of the abovementioned line.
In its response, dated December 22, 2004, the applicant stated that the LR drawing is incorrect and does not properly show the license renewal boundary for the components within the scope
 
of license renewal and subject to an AMR. The drawing incorrectly shows line 57-4-B beyond valve PSV-57-57 as within the scope of license renewal. There should be a boundary flag on
 
the discharge side of the valve showing solid blue pointing away from the valve and "LR-CS" pointing toward the valve. Line 57-4-B beyond the relief valve should be shown in black.
For clarification the applicant stated, to be consistent with the description in original LRA Section 2.3.4.A.1, all of the liquid-filled components on the subject drawing that are not
 
highlighted are within the scope of license renewal and subject to AMR, since they are in the
 
turbine building and in the vicinity of SR components. Per the LR drawing convention, components within the scope of license renewal and subject to AMR under 10 CFR 54.4(a)(2)
 
only, are not shown in red on the LR drawings.
 
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.1-4 acceptable
 
because it adequately explained that the components in question beyond the subject valve are
 
not within the scope of license renewal and subject to an AMR but inadvertently were
 
highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the
 
components beyond the valve representing the license renewal boundary were correctly not
 
included within the scope of license renewal and not subject to an AMR. Therefore, the staff's
 
concern described in RAI 2.3.4.A.1-4 is resolved.
In RAI 2.3.4.A.1-5, dated November 19, 2004, the staff stated that the two condensate surge and storage tanks are shown within the scope of license renewal on LR drawing 18003. Original
 
LRA Table 2.3.4.A.1-1 lists "Tanks" as a component type subject to an AMR. Therefore, the
 
staff requested that the applicant confirm that the condensate surge and storage tanks are
 
included in the component type "Tanks" and identify other tanks (if any) belonging to the
 
condensate and condensate transfer system that are within the scope of license renewal and
 
included in the component type "Tanks."
In its response, by letter dated December 22, 2004, the applicant stated that both tanks are within the scope of license renewal, subject to an AMR, and included in the component type "Tanks" in original LRA Table 2.3.4.A.1-1. There are no other tanks within NMP1 condensate
 
and condensate transfer system that are SR and subject to AMR. There are, however, other tanks in the system that are within the scope of license renewal and subject to AMR to meet
 
10 CFR 54.4(a)(2). These are among the other liquid-filled NSR equipment identified in original
 
LRA Section 2.3.4.A.1 that are located in the reactor building, radwaste solidification and
 
storage building, screen and pump house building, turbine building, or waste disposal building
 
as being in the vicinity of SR components. Per the LR drawing convention, only components
 
within the scope of license renewal and subject to AMR under 10 CFR 54.4(a)(2) are not to be
 
shown in red on the LR drawings.
2-114 Based on its review, the staff found the applicant's response acceptable because it adequately explained that the subject tanks in question 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). In
 
addition, the response explained that the subject tanks are included in the component type
 
"tanks" in original LRA Table 2.3.4.A.1-1 and that there are no other tanks within NMP1
 
condensate and condensate transfer system that are SR and subject to AMR. The response
 
noted, however, that other tanks in the system that are within the scope of license renewal and subject to an AMR under 10 CFR 54.4(a)(2). Therefore, the staff's concern described in
 
RAI 2.3.4.A.1-5 is resolved.
In RAI 2.3.4.A.1-6, dated November 19, 2004, the staff requested information on the intended function of "NSR Functional Support" listed in the original LRA Table 2.3.4.A.1-1. The
 
applicant's response, by letter dated December 22, 2004, is reflected in the ALRA as discussed
 
below.In its ALRA, dated July 14, 2005, the applicant stated that this intended function is no longer used. Instead, the applicant identified specific NSR intended functions and made them
 
consistent with the standardized list of intended functions in SRP-LR and NEI-95-10. Based on
 
the information submitted in the ALRA the staff's concern described in RAI 2.3.4.A.1-6 is
 
resolved.
In RAI 2.3.4.A.1-7, November 19, 2004, the staff stated that LR drawing 18009, sheet 1 shows that the only component located between valve CT-53 and valves BV 57-103/104 is flow
 
indicator FI 57-168. However, LR drawing 18048 shows that flow gauge FG 57-175 is the only
 
component located between these same valves. The applicant was asked to explain this
 
apparent discrepancy.
In its response, dated December 22, 2004, the applicant stated that it agrees that LR drawing LR-18009-C, sheet 1 (location G5), identifies FI-57-168, a flow indicator for the clean-up
 
demineralizer, as in-scope for license renewal and subject to AMR.
In addition, drawing LR-18048-C (location A6), identifies FG-57-175, a flow gauge for the clean-up demineralizer, as also being within the scope of license renewal and subject to an
 
AMR.The applicant stated that a review of NMP1 plant drawings C-18009-C, sheet 1, and C-18048-C, revealed the same discrepancy between these drawings as identified in the RAI. The
 
discrepancy is corrected by replacing FG-57-175 on drawing LR-18048-C with FI-57-168, consistent with drawing LR-18009-C, sheet 1, and with the as-built configuration of the plant.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.1-7 acceptable because it adequately explained that the discrepancy between the two LR drawings was carried
 
over from a discrepancy on two NMP1 P&ID drawings. The as-built configuration of the plant
 
shows FI-57-168 between valve CT-53 and valve BV 57-103/104. LR drawing LR-18009-C, sheet 1 is correct as shown and LR-18048-C should have agreed with it to match the plant
 
as-built configuration. Therefore, the staff's concern described in RAI 2.3.4.A.1-7 is resolved.
2-115 2.3A.4.1.3  Conclusion The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
condensate and condensate transfer system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the condensate and condensate transfer system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.4.2  NMP1 Condenser Air Removal and Off-Gas System 2.3A.4.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.A.2, the applicant described the condenser air removal and off-gas system. The condenser air removal and off-gas system remove noncondensable radioactive
 
gases that accumulate in the main condenser during plant startup and normal operation. The
 
gases evacuated by this system are mainly c oncentrated in the condenser, but steam, air, and other gases evacuated by the steam packing exhauster are also discharged to the condenser
 
air removal and off-gas system. The condenser air removal and off-gas system draws a suction
 
from the air volume in the main condenser, processes the gases and exhausts the gases to the
 
main stack. The processing of the non-condensable radioactive gases includes recombining the
 
hydrogen and oxygen gases to form water, removing the moisture content of the gases and
 
providing for radioactive decay so as to minimize the level of radiation exhausted to the main
 
stack. This system also includes equipment to draw the initial vacuum on the main condenser
 
during plant startup. The water removed by the processing of the condenser air is returned to
 
the main condenser.
The condenser air removal and off-gas system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the condenser air
 
removal and off-gas system could potentially prev ent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.A.2-1, the applicant identified the following condenser air removal and off-gas system component types that are within the scope of license renewal and subject to an AMR:
* air ejectors
* bolting
* heat exchanger
* piping and fittings
* valves 2-116 2.3A.4.2.2  Staff EvaluationThe staff reviewed ALRA Section 2.3.4.A.2 and UFSAR Section XI.B.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.4.A.2 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.A.2-1, dated November 19, 2004, the staff noted that original LRA Section 2.3.4.A.2 states that the condenser air removal and off-gas system removes and processes
 
non-condensable radioactive gases that accumulate in the main condenser during startup and
 
normal operation. The processing of the radioactive gases includes recombining the hydrogen
 
and oxygen to form water. The original LRA further states that this system is in-scope for
 
performing SR functions per 10 CFR 54.4(a)(1) and that because components within this
 
system are either active or subject to replacement based on qualified life or specified time
 
period no AMR is required. NMP1 UFSAR Section XI, Steam-to-Power Conversion System, B.3.0 (Condenser Air Removal and Offgas System), describes the operation and components of
 
this system. Major components for the system are listed including many which appear to be passive and long-lived. Those components that are described as performing the process
 
include: preheater, recombiner, condenser, drain tank, vent cooler, and 30-min holdup pipe.
 
Therefore, in order for the staff to complete its review, the applicant was requested to confirm
 
that the aforementioned components are not passive or long-lived or otherwise do not perform
 
an intended function identified in original LRA Section 2.3.4.A.2. If found to require an AMR, then the applicant was to identify them on drawing(s) and include them in original LRA
 
Table 2.3.4.A.2.
In its response, by letter dated December 22, 2004, the applicant stated that the intended function of the condenser air removal and off-gas systems is to provide fault protection and
 
isolation for the SR reactor protection system distribution system. This system intended function is performed by active electrical components which are within the scope of license renewal but
 
not subject to an AMR. The functions performed by passive components of the system, such as removing and processing non-condensable radioactive gases that accumulate in the main
 
condenser during startup and normal operation, are not within the scope of license renewal. The
 
information in the response has been subsequently incorporated in the ALRA.
In its ALRA, dated July 14, 2005, the applicant provided the staff with a revised LR drawing which identifies SSC's in scope and subject to an AMR under 10 CFR 54.4(a)(2).
2-117 Based on its review, the staff found the applicant's response to RAI 2.3.4.A.2-1 acceptable because it adequately explained that the SR function it performs is accomplished by electrical
 
components that are active and not subject to an AMR in accordance with 10 CFR 54.21(a).
 
Therefore, the staff's concern described in RAI 2.3.4.A.2-1 is resolved 2.3A.4.2.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and accompanying scoping boundary drawing to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
condenser air removal and off-gas system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the condenser air removal and off-gas system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.4.3  NMP1 Feedwater/High Pressure Coolant Injection System 2.3A.4.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.A.3, the applicant described the FW/HPCI system. The FW/HPCI system is the main source of processed water to the reactor during normal operation and also is
 
designed to ensure that the core is adequately cooled under small break LOCA conditions, which do not result in a rapid depressurization of the RPV. The primary function of the FW
 
system is to transfer the water from the c ondensate system to the RPV. The FW system also preheats the feedwater prior to entering the RPV. The HPCI system is an operating mode of the
 
FW system. The purpose of the HPCI system is to provide adequate cooling of the reactor core under abnormal and accident conditions, remove the heat from radioactive decay and residual
 
heat from the reactor core at such a rate that fuel clad melting would be prevented, and provide
 
for continuity of core cooling over the complete range of postulated break sizes in the primary
 
system process barrier. Upon initiation, the HP CI system provides the control functions to deliver water from the condensate storage tanks to the RPV. However, the HPCI system is not
 
an engineered safeguards system and is not considered in any LOCA analyses.
The FW/HPCI system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the FW/HPCI system could potentially prevent the satisfactory accomplishment of an SR func tion. In addition, the FW/HPCI system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides removal and/or holdup of fission products 2-118
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.4.A.3-1, the applicant identified the following FW/HPCI system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* feedwater heaters
* filters/strainers
* flow elements
* flow indicators
* flow orifices
* oil coolers
* piping and fittings
* pumps
* valves 2.3A.4.3.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.A.3 and UFSAR Sections VII.I and XI.B using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.4.A.3 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 2.3.4.A.3-1, dated November 19, 2004, the staff stated that original LRA Table 2.3.4.A.3-1 includes "oil coolers" as a component type subject to an AMR. However, the
 
staff has been unable to locate oil coolers on the LR drawings referenced in original LRA
 
Section 2.3.4.A.3. Drain coolers, on the other hand, are shown within the scope of license
 
renewal on these drawings and are subject to an AMR, yet have not been included in the table.
 
Therefore, the staff requested the applicant to confirm that "oil coolers" were mistakenly entered
 
in place of "drain coolers" in the table and, if so, make the appropriate corrections. Otherwise, add the component type "drain coolers" to the table and provide drawings showing the subject
 
oil coolers as well as the components they serve.
In its response, by letter dated December 22, 2004, the applicant stated that the subject table is correct and provided the following explanation:
2-119 LR drawing LR-18004-C identifies three drain coolers. They are Drain Cooler 11 (51-04) at location GI; Drain Cooler 12 (51-05) at location G3; and Drain Cooler
 
13 (51-06) at location G5. These drain coolers are actually the first stage of the
 
feedwater heaters. The shells for these coolers are not safety-related and not
 
subject to AMR; however, the tube sides of these coolers are in-scope for LR and
 
subject to AMR for a feedwater pressure boundary function. Per LRA
 
Section 2.3.4.A.3, as liquid-filled components in the Turbine Building, the shell
 
sides of these coolers are in-scope for LR and subject to AMR for criterion
 
10 CFR 54.4(a)(2). Consistent with LR drawing convention, the components
 
in-scope for LR and subject to AMR for criterion (a)(2) only are not shown in red
 
on the LR drawings.
LR drawing LR-18023-C, Sheet 2, which is listed in LRA Section 2.3.4.A.3,identifies two oil coolers, 29-02 and 29-03. HTX-29-02 is the oil cooler for motor-driven Reactor Fedwater Pump 11 and HTX-29-03 is the oil cooler for
 
motor-driven Reactor Feedwater Pump 12. As for the drain coolers above, the
 
shells for these coolers are not safety-related and not subject to AMR for criteria
 
10 CFR 54.4(a)(1) or (a)(3); however, the tube sides are in-scope for LR and
 
subject to AMR for a lube oil pressure boundary function. As with the drain
 
coolers/feedwater heaters above, since t hey are liquid-filled components in the Turbine Building, they are in-scope for LR and subject to AMR for criterion
 
10 CFR 54.4(a)(2).
As noted in the RAI, LRA Table 2.3.4.A.3-1 includes "Oil Coolers." Since the drain coolers are actually the first stage feedwater heaters, they are included in
 
Table 2.3.4.A.3-1 under the component type "Feedwater Heaters." Based on its review, the staff found the applicant's response to RAI 2.3.4.A.3-1 acceptable because it adequately explained that the subject drain cooler and oil cooler shell sides as
 
liquid-filled components in the turbine building, are within the scope of license renewal and
 
subject to AMR for criterion 10 CFR 54.4(a)(2). Also, the tube sides are in-scope for license
 
renewal and subject to AMR for a feedwater and lube oil pressure boundary function per criteria
 
10 CFR 54.4(a)(1). The applicant explains that the drain coolers are the first stage feedwater
 
heater and are included in original LRA Table 2.3.4.A.3-1 under the component type "feedwater
 
heaters." Therefore, the staff's concern described in RAI 2.3.4.A.3-1 is resolved.
In RAI 2.3.4.A.3-2 dated November 19, 2004, the staff stated that original LRA Table 2.3.4.A.3-1 includes the following component types as subject to AMR: filters/strainers, flow elements, flow
 
indicators, and flow orifices; however, the intended function assigned to these components is
 
"NSR Functional Support." original LRA Table 2.0-1 identifies intended functions applicable to
 
these components not identified in original LRA Table 2.3.4.A.3-1. Aging management to ensure
 
that the component level intended functions can be performed is necessary to ensure that the
 
system level intended functions can be maintained. The intended functions include "filtration"
 
and "flow restriction." The applicant was asked to describe how the intended functions for these
 
components are assigned and evaluated.
In its response by letter dated December 22, 2004, the applicant stated that a component's particular function of filtration for a filter or flow restriction for a flow orifice is not an intended
 
function for license renewal but that a component function would be considered an intended 2-120 function only if failure of that component would cause the failure of a system intended function and failure of the "filtration" or "flow restriction" functions for the components would not prevent
 
the NMP1 FW/HPCI system from performing it s intended function; therefore, the only intended function for these components is "NSR Functional Support" as identified in original LRA
 
Table 2.3.4.A.3-1.
In evaluating this response the staff found it incomplete and review of original LRA Section 2.3.4.A.3 could not be completed because the applicant did not explain adequately
 
what intended functions "NSR Functional Support" represents and how that intended function
 
applies to all the component types in the feedwater/high pressure coolant injection system
 
including filters/strainers, flow elements, flow indicators, and flow orifices. The staff held a
 
teleconference with the applicant on January 27, 2005, to discuss information necessary to
 
resolve the concern in RAI 2.3.4.A.3-2. The result of the teleconference was an agreement by
 
the applicant to transmit the required information by a follow-up letter.
By letter dated February 11, 2005, the applicant defined the "NSR Functional Support" function for NSR components. Tables containing clarifying information regarding the intended functions
 
for components in the FW/HPCI system were provided. The tables identify all the functions
 
accomplished by each of the listed component types.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.3-2 including the information in the letter dated February 11, 2005, acceptable because it adequately explained
 
what intended functions, "NSR Functional Support" represent and how it is applied to all the
 
component types in the feedwater/high pressure coolant injection system including
 
filters/strainers, flow elements, flow indicators, and flow orifices. Therefore, the staff's concern
 
described in RAI 2.3.4.A.3-2 is resolved.
In RAI 2.3.4.A.3-3, dated November 19, 2004, the staff stated that original LRA Table 2.3.4.A.3-1 includes the following component types as being subject to an AMR: flow
 
elements, flow indicators, and flow orifices. However, the drawing legend does not clearly define
 
or distinguish between these components. For example, under "Flow Devices" in the legend, one of the symbols shown is denoted "FE" and defined as "flow element orifice" while another is
 
denoted "FI" and defined as "in-line flow device." The distinction between these three
 
component types and where each appears on the boundary drawings was not clear to the staff.
 
With respect to the LR drawings the staff asked the applicant to provide examples that clarify
 
the distinction between the above mentioned three component types.
In its response, by letter December 22, 2004, the applicant stated that as an example, drawing LR-18005-C, sheet 1 (location F5), identifies FE-29-113, a flow element in the feedwater pump
 
13 discharge piping. The component identification is consistent with the drawing legend for flow
 
devices as shown on license drawing LR-18000-C, sheet 1. This component is within the scope
 
of license renewal and subject to AMR.
Another example is drawing LR-18005-C, sheet 1 (location G3), which identifies FI-51-106, a 1-inch flow indicator for feedwater pump 12 seal water. The component identification is
 
consistent with the drawing legend for flow devices as shown on LR drawing LR-18000-C, sheet
: 1. This component is within the scope of license renewal and subject to AMR.
2-121 The last example is drawing LR-18005-C, sheet 1 (location F4), which identifies FOR-29-45, a restricting flow orifice for feedwater pump 12 recirculation. The component identification is
 
consistent with the drawing legend for flow devices as shown on drawing LR-18000-C, sheet 1.
 
This component is within the scope of license renewal and subject to AMR.
The applicant also stated that drawing LR-18000-C, sheet 1 (location A1 to E3 inclusive), provides a comprehensive matrix table that lists numerous component ID prefixes. In the matrix table for these instrument component types, "Flow" is the Measured Variable and the instrument
 
functions are "primary element" (FE), "indicating" (FI), and "orifice restricting" (FOR),
respectively. The drawing legend (location G5) is informational only and not meant to be all
 
inclusive.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.3-3 acceptable because it adequately provided examples of component types flow elements, flow indicators, and flow orifices on license renewal drawings and explains the distinction between the subject
 
three component types. Therefore, the staff's concern described in RAI 2.3.4.A.3-3 is resolved.
In RAI 2.3.4.A.3-4, dated November 19, 2004, the staff stated that LR drawing 18003 shows the symbol "boxed letter B" on the suction side of each of the three feedwater booster pumps. This
 
symbol is not defined in the legend nor is the staff able to determine what it represents.
 
Therefore, the staff requested that the applicant define the above described symbol.
In its response, by letter December 22, 2004, t he applicant stated that the symbol "boxed letter B" represents the start-up strainer shell for feedwater booster pumps 11, 12, and 13. The details
 
can be found on license renewal drawing LR-18003-C (location H4). The element has been
 
removed from the strainer.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.3-4 acceptable because the applicant adequately explained what the "boxed letter B" on the subject LR drawing
 
stands for and how it is not relevant to license renewal. Therefore, the staff's concern described
 
in RAI 2.3.4.A.3-4 is resolved.
2.3A.4.3.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
FW/HPCI system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the FW/HPCI system components that are subject to an AMR, as required
 
by 10 CFR 54.21(a)(1).2.3A.4.4  NMP1 Main Generator and Auxiliary System 2.3A.4.4.1  Summary of Technical Information in the Amended Application 2-122 In ALRA Section 2.3.4.A.4, the applicant described the main generator and auxiliary system.
The main generator and auxiliary system consists of the main generator, generator stator
 
cooling water system, hydrogen seal oil sy stem and hydrogen cooling system. The hydrogen cooling system fills the main generator with high-purity hydrogen gas to cool the generator
 
during plant operation. The main generator is filled with hydrogen gas by first purging air with
 
carbon dioxide and then purging the carbon dioxide with hydrogen. The equipment used to
 
supply carbon dioxide to the main generator is the only equipment of the main generator and
 
auxiliary system that is in scope for license renewal.
The main generator and auxiliary system perform s functions that support fire protection.
The intended function, within the scope of license renewal, is to provide pressure retaining boundary.In ALRA Table 2.3.4.A.4-1, the applicant identified the following main generator and auxiliary system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* tanks
* valves 2.3A.4.4.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.A.4 and UFSAR Section XI.B.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.4.4.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the main generator and auxiliary system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the main generator and
 
auxiliary system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.4.5  NMP1 Main Steam System 2-123 2.3A.4.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.A.5, the applicant described the main steam system. The main steam system supplies dry steam from the RPV to t he main turbine and to various support systems.
The main steam system consists of two main steam lines, four main steam isolation valves, six electromatic relief valves, four turbine stop valves, four turbine control valves, nine turbine
 
bypass valves, controls, instrumentation, pi ping, valves and associated equipment. The system extends from the RPV main steam nozzles to the turbine stop, control and bypass valves and to the inlet of the various components to which it supplies steam. The discharge piping and valves
 
from the electromatic relief valves to the torus, including the Y-quenchers, are also included
 
within this system. The electromatic relie f valves are also used by the automatic depressurization system to depressurize the RPV during accident conditions.
The main steam system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the main steam system could potentially
 
prevent the satisfactory accomplishment of an SR function. In addition, the main steam system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.4.A.5-1, the applicant identified the following main steam system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* condensing pots
* flow elements
* piping and fittings
* regulator
* valves
* Y-quenchers 2.3A.4.5.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.A.5 and UFSAR Sections V.B.1, V.B.5, and XI.B.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
not omitted from the scope of license renewal any components with intended functions 2-124 delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.4.A.1 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 2.3.4.A.5-1 dated November 19, 2004, the staff stated that LR Note #1 on drawing LR-18000-C, "License Renewal Boundary Drawing Sy mbols, Notes, and Acronyms," states that portions of the system subject to AMR are highlighted in red with boundaries indicated by blue
 
flags. The blue flags are described on drawing LR-18000-C as "AMR Boundary Flags." Portions
 
of a license renewal system indicated with solid blue flags may perform intended functions and
 
are within scope of license renewal but are not subject to AMR; however, when an LR drawing is composed of a system diagram that has a continuation on another system diagram not provided by the applicant, the staff is unable to complete its review of whether the license
 
renewal system incorporates all portions necessa ry to satisfy its plant level system intended functions.
LR-18002-C for the NMP1 main steam system is composed of system diagram C-18002 sheet
: 1. A portion of the main steam system is depicted on C-18002 sheet 2, which has not been
 
provided. Therefore, the staff requested that the applicant confirm that no portion of the main
 
steam system on C-18002 sheet 2 has SR co mponents or otherwise meets criteria of 10 CFR 54.4(a)(1), (2), or (3), or, if such components exist, identify them and ensure that their
 
component types and intended functions are represented in Table 2.3.4.A.5-1.
In its response dated December 22, 2004, the applicant stated that there are no components subject to AMR under 10 CFR 54.21(a)(1) on the subject system diagram for the main steam
 
system. Therefore, this diagram was not included in the original LRA. The applicant further
 
stated that the main steam system components within the scope of license renewal for
 
10 CFR 50.54(a)(2) and subject to an AMR are not highlighted on the LR drawings.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.5-1 acceptable because it adequately explained that there are no components subject to an AMR in
 
accordance with 10 CFR 54.21(a)(1) existing on other system diagrams for the main steam
 
system that are not used as license renewal dr awings. Therefore, the staff's concern described in RAI 2.3.4.A.5-1 is resolved.
In RAI 2.3.4.A.5-2 dated November 19, 2004, the staff stated that original LRA Section 2.3.4.A.5 identifies LR drawings depicting components requi ring AMR for the NMP1 main steam system.
During the review of the original LRA, however, the staff found other LR drawings that have
 
main steam components shown to require AMR not identified in original LRA Section 2.3.4.A.5.
 
These include LR-18006-C, "Drywell and Torus Isolation Valves." For the staff to complete its
 
review of the main steam system the applicant was asked to identify other drawings depicting
 
main steam components requiring AMR.
In its response by letter dated December 22, 2004, the applicant stated that LR drawing LR-18002-C sheet 1 identifies the main steam system components within the scope of license 2-125 renewal and subject to AMR for 10 CFR 50.54 (a)(1) and (a)(3), that although drawing LR-18006-C sheet 1 also shows main steam sy stem components within the scope of license renewal they are the same as those shown on LR-18002-C, that as such drawing LR-18006-C
 
should have been referenced in original LRA Section 2.3.4.A.5, that LR drawing LR-18006
 
sheet 1 should have been referenced for the containment spray, liquid poison, emergency
 
cooling, and feedwater systems because com ponents from those systems also appear on the drawing, and that main steam components within scope of license renewal subject to an AMR
 
for 10 CFR 50.54(a)(2) are not redlined on LR drawings; therefore, there are no additional LR
 
drawings that show main steam components subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.5-2 acceptable because it adequately explained that although there are some main steam components subject
 
to an AMR in accordance with 10 CFR 54.21(a)(1) that are duplicated on other license renewal
 
drawings, they are highlighted as well in accordance with the license renewal guidance.
 
Therefore, the staff's concern described in RAI 2.3.4.A.5-2 is resolved.
In RAI 2.3.4.A.5-3 dated November 19, 2004, the staff stated that LR drawing 18002 sheet 1 shows the branch line connecting the discharge line of safety relief valve MSER V-2 to
 
temperature element 01-17 omitted from AMR. Thi s branch line forms part of the reactor coolant pressure boundary, and is passive, and long-lived; therefore, it should require an AMR. (Note
 
that the corresponding branch lines for the remaining five safety relief valves are shown
 
correctly as requiring AMR). The staff requested that the applicant justify omission of the branch
 
line from AMR.
In its response by letter dated December 22, 2004, the applicant stated that the LR drawing is incorrect and does not properly show the line within the scope of license renewal and subject to
 
AMR. The line in question should have been highlighted on the LR drawing showing it within the
 
scope of license renewal and subject to AMR but inadvertently was not highlighted.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.5-3 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal and subject to an AMR but were inadvertently left un-highlighted on the license renewal
 
drawing. The staff concludes that there is reasonable assurance that the components were
 
correctly included within the scope of license renewal and subject to an AMR. Therefore, the
 
staff's concern described in RAI 2.3.4.A.5-3 is resolved.
In RAI 2.3.4.A.5-4 dated November 19, 2004, the staff stated that LR drawing 18002, sheet 1 (locations A2, A3, D2, D3) shows the discharge line from each of the six safety-relief valves (MSER V-1, 2, 3, 4, 5, and 6) ending at a continuation flag labeled "To Torus" with no
 
continuation drawing specified. At that point there is also a boundary flag showing an interface
 
between the main steam system and the primary c ontainment system. For the staff to determine if all components in this SR system within the scope of license renewal and subject to an AMR have been identified, it must review of the continuation drawing. The applicant was asked to
 
provide a drawing showing the continuation of the safety-relief valve discharge lines to the torus
 
or, if already provided in the original LRA as an LR drawing, identify the drawing number.
In its response by letter dated December 22, 2004, the applicant stated that the safety-relief valve discharge lines are routed through the drywell-to-torus vent lines and terminate in the
 
torus below the water line. The applicant also stated that the continuation of the safety-relief 2-126 valve discharge lines is as shown on the referenced license renewal drawing to signify that the safety-relief valve discharge line piping continues to the torus, and that there are no other
 
components in those lines.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.5-4 acceptable because it adequately explained that although the safety relief valve discharge line is routed
 
through the drywell to the torus vent, there are no continuation drawings depicting this piping
 
that contain components other than the piping that is already subject to an AMR. Therefore, the
 
staff's concern described in RAI 2.3.4.A.5-4 is resolved.
In RAI 2.3.4.A.5-5, dated November 19, 2004, the staff requested information on the intended function of "NSR Functional Support" listed in Table 2.3.4.A.5-1 of the original original LRA. The
 
applicant's December 22, 2004, response information to this RAI is reflected in the ALRA as
 
described below.
In its ALRA dated July 14, 2005, the applicant stated that this intended function is no longer used, instead, the applicant identified specific NSR intended functions and made them
 
consistent with the standardized list of intended functions in SRP-LR and NEI-95-10. Based on
 
the information submitted in the ALRA, the staff's concern described in RAI 2.3.4.A.5-5 is
 
resolved.In RAI 2.3.4.A.5-6, dated November 19, 2004, the staff stated that LR drawing LR-18002-C indicates that bellows expansion joints 66-01R, -02R, -03R, -04R, -05R, and -06R are subject to an AMR in the main steam system. original LRA Table 2.3.4.A.5-1 does not include bellows
 
expansion joints as a "component type" with an intended function; therefore, the staff requested
 
that the applicant justify the omission of the bellows expansion joints from original LRA
 
Table 2.3.4.A.5-1 or revise the table to include this component type.
In its response, dated December 22, 2004, the applicant stated that expansion joints are included under the component type "Piping and Fittings" in the original LRA Table 2.3.4.A.5-1.
Based on its review, the staff found the applicant's response to RAI 2.3.4.A.5-6 acceptable because it adequately explained that the bellows expansion joints in question are within the
 
scope of license renewal and subject to an AMR. Further, the applicant stated that the bellows
 
expansion joints are represented in the original LRA Table. Therefore, the staff's concern
 
described in RAI 2.3.4.A.5-6 is resolved.
2.3A.4.5.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings accompanying scoping boundary drawings to determine whether any SSCs that should be
 
within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the main steam system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the main steam system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-1272.3A.4.6  NMP1 Main Turbine and Auxiliary Systems 2.3A.4.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.A.6, the applicant described the main turbine and auxiliary systems. The main turbine and auxiliary systems converts the thermal energy contained in the steam supplied by the reactor into electrical energy. The turbine is a tandem-compound, 1800 RPM unit with a
 
single admission, double-flow high pressure section and a six-flow low pressure section. A
 
bypass system is provided that allows bypassing excess steam flow to the condenser when the turbine cannot absorb all the generated steam.
The main turbine and auxiliary systems consist of multiple subsystems including the main turbine system, turbine-generator controls syst em, turbine gland sealing system, turbine oil storage and purification system, turbine protecti on system and turbine supervisory instruments system. Of these systems, the turbine gland s ealing system, turbine oil storage and purification system and the turbine protection system, specif ically the turbine overspeed system, contain components that are within the scope of license renewal. The turbine gland sealing system
 
functions to seal the shaft of the main turbine against leakage of steam from the turbine shell to
 
atmosphere as well as leakage of air from atmosphere to the main condenser. The turbine oil
 
storage and purification system supplies purified lubricating and cooling oil to the
 
turbine-generator bearings, shaft-driven feedwater pump and the turbine-generator controls
 
system. The turbine protection system monito rs selected parameters, including turbine overspeed, and provides various trips and alarms designed to protect the turbine from damage.
The failure of NSR SSCs in the main turbine and auxiliary systems could potentially prevent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.A.6-1, the applicant identified the following main turbine and auxiliary systems component types that are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchanger
* piping and fittings
* regulator
* valves 2.3A.4.6.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.A.6 and UFSAR Sections XI.B.1 and VIII.B.2.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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 2-128 had identified as being within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.4.6.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the main turbine and auxiliary systems components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the main turbine and auxiliary
 
systems components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3A.4.7  NMP1 Moisture Separator Reheater Steam System 2.3A.4.7.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.A.7, the applicant described the moisture separator reheater steam system. The moisture separator reheater steam system removes entrained moisture from the high pressure turbine exhaust and reheats the dried steam to superheated conditions before it
 
passes on to the low pressure turbine.
The failure of NSR SSCs in the moisture separator reheater steam system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function, within the scope of license renewal, is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.A.7-1, the applicant identified the following moisture separator reheater steam system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow element
* flow orifices
* heat exchanger
* piping and fittings
* separator
* strainer
* tanks
* valves 2.3A.4.7.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.A.7 and UFSAR Section XI.B.1.0 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
2-129 In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3A.4.7.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the moisture separator reheater steam system components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the moisture separator
 
reheater steam system components that ar e subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.3B  NMP2 Scoping and Screening Results: Mechanical Systems2.3B.1  Reactor Vessel, Internals, and Reactor Coolant Systems In ALRA Section 2.3.1.B, the applicant identified the structures and components of the NMP2 reactor vessel, internals, and reactor coolant systems that are subject to an AMR for license
 
renewal.The applicant described the supporting structures and components of the reactor vessel, internals, and reactor coolant systems in the following sections of the ALRA:
* 2.3.1.B.1NMP2 reactor pressure vessel
* 2.3.1.B.2NMP2 reactor pressure vessel internals
* 2.3.1.B.3NMP2 reactor pressure vessel instrumentation system
* 2.3.1.B.4NMP2 reactor recirculation system
* 2.3.1.B.5NMP2 control rod drive system
* 2.3.1.B.6NMP2 reactor coolant pressure boundary components in other systems The staff's review findings regarding ALRA Sections 2.3.1.B.1 through 2.3.1.B.6 are presented in SER Sections 2.3B.1.1 through 2.3B.1.6, respectively.2.3B.1.1  NMP2 Reactor Pressure Vessel 2.3B.1.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.B.1, the applicant described the RPV. The RPV contains and supports the reactor core, reactor internals, and the reactor coolant/moderator. The RPV forms part of the
 
RCPB and serves as a barrier against leakage of radioactive materials to the drywell. The RPV
 
is a vertical cylindrical pressure vessel of welded construction with hemispherical bottom and 2-130 top heads. The cylindrical shell and top and bottom heads of the RPV are fabricated of low-alloy steel, the interior of which is clad with stainless steel weld overlay, except for the top head and
 
nozzle and nozzle weld zones. The RPV top head is secured to the RPV by studs and nuts. The
 
RPV flanges are sealed with two concentric metal seal rings designed to permit no detectable
 
leakage through the inner or outer seal at any operating condition. The top head leak detection
 
lines tap off of the vessel head between the seal rings to detect leakage should the inner
 
seal-ring fail. The RPV is penetrated by various nozzles and penetrations. The CRD housings
 
and in-core instrumentation thimbles are welded to the bottom head of the RPV. The concrete
 
and steel vessel support pedestal is constructed as an integral part of the building foundation.
 
Steel anchor bolts, set in the concrete, extend through the bearing plate and secure the flange
 
of the reactor vessel support skirt to the bearing plate, and thus to the support pedestal.
The RPV contains SR components that are relied upon to remain functional during and following DBEs. The intended functions within the scope of license renewal include the following:
* provides pressure retaining boundary
* provides structural and/or functional support to SR equipment In ALRA Table 2.3.1.B.1-1, the applicant identified the following RPV component types that are within the scope of license renewal and subject to an AMR:
* bottom head
* nozzles
* nozzle safe ends
* nozzle thermal sleeves
* penetrations: core differential pressure and liquid control, CRD stub tubes, drain lines, in-core instruments, instrumentation
* support skirt
* top head and nozzles
* top head (closure studs and nuts)
* top head (flanges)
* top head (leak detection lines)
* valves
* vessel shells (flange)
* vessel shells: lower intermediate shell, lower shell, upper intermediate shell, upper shell
* vessel welds (including attachment welds) 2.3B.1.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.B.1 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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 2-131 had identified as being within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.1.1.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the RPV components that are within the scope of license renewal, as
 
required by 10 CFR 54.4(a), and the RPV components that are subject to an AMR, as required
 
by 10 CFR 54.21(a)(1).2.3B.1.2  NMP2 Reactor Pressure Vessel Internals 2.3B.1.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.B.2, the applicant described the reactor pressure vessel internals. The reactor pressure vessel internals provide support for the core and other internal components, maintain fuel configuration (coolable geometry) during normal operation and accident
 
conditions, and provide reactor coolant flow distribution through the core. The reactor pressure
 
vessel internals consists of the components internal to the RPV. The main structures within the
 
RPV are the core (fuel, channels, control rods and instrumentation), the core support structure (including the shroud, top guide and core plate), the shroud head and steam separator
 
assembly, the steam dryer assembly, the feedwater spargers, the core spray spargers, and the
 
jet pumps. Except for the Zircaloy used in the fuel assemblies, reactor internals are stainless
 
steel or other corrosion-resistant alloys. The fuel assemblies (which include fuel rods and
 
channel), control rods, in-core instrumentation, shroud head and steam separator assembly, and steam dryers are removable when the reactor vessel is opened for refueling or
 
maintenance.
The reactor pressure vessel internals contain SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the reactor pressure vessel
 
internals could potentially prevent the satisf actory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* provides structural and/or functional support to SR equipment In ALRA Table 2.3.1.B.2-1, the applicant identified the following reactor pressure vessel internals component types that are within the scope of license renewal and subject to an AMR:
2-132
* access hole covers
* CRD assemblies (includes drive mechanism and housing)
* control rod guide tubes
* core plate, bolts, and supports
* core shroud
* core shroud head bolts
* core/shroud support structures: bolts, brackets, clamps, keepers, supports
* core spray lines and spargers
* differential pressure liquid control line
* flanges
* incore housings
* incore instrumentation dry tubes
* jet pump assemblies
* low pressure coolant injection (LPCI) couplings
* orificed fuel supports
* peripheral fuel supports
* power range detector assemblies
* spray nozzles
* steam dryer assembly
* top guide and supports 2.3B.1.2.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.B.2 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.1.B.2 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
In RAI-4, dated November 17, 2004, the staff noted that the steam separator assembly consists of a base into which are welded an array of standpipes with a steam separator located at the
 
top of each standpipe. Therefore, the staff requested that the applicant provide justification why
 
these standpipes and steam separators were not included within the scope of license renewal.
In its response by letter dated December 17, 2004, the applicant stated that the steam separators and their standpipes are not included within the scope of license renewal because
 
they are not SR components that perform a license renewal intended function and referred to an
 
evaluation contained in BWRVIP-06-A. Also, the staff's concern about the possibility that failure
 
of these components could prevent the accomplis hment of SR functions of nearby components 2-133 (e.g., the creation of loose parts that might hit and damage SR components). The staff noted that this consideration was also addressed in BWRVIP-06-A and the evaluation was accepted
 
by the staff in letters dated September 15, 1998, and September 16, 2003. Therefore, the staff's
 
concern described in RAI-4 is resolved.
In RAI-5 dated November 17, 2004, the staff requested that the applicant indicate where the feedwater sparger is identified as a vessel internal component requiring an AMR. In its
 
response by letter dated December 17, 2004, the applicant indicated that this sparger also was
 
not included within the scope of license renewal. The applicant stated that, per BWRVIP-06-A, "The sole purpose of the feedwater spargers is to control thermal mixing and extend the life of
 
the vessel and internals. The failure of feedwater spargers or associated brackets would not
 
prevent injection of coolant makeup and are not required to safety shut down the reactor." On
 
this basis the staff found exclusion of the feedwater sparger from within the scope of license
 
renewal acceptable. Therefore, the staff's concern described in RAI-5 is resolved.
In RAI 2.3-4, dated October 11, 2005, the staff requested that the applicant indicate whether the diffuser seal ring and shroud support plate should be identified as an RPV internal component
 
requiring an AMR. In its response, by letter dated October 28, 2005, the applicant indicated that
 
the diffuser seal ring and the shroud support plate are reactor pressure vessel internal
 
components subject to aging management review, that the diffuser seal ring is included under
 
"Jet Pump Assemblies" identified in ALRA Table 2.3.1.B.2-1, and that the shroud support plate
 
is included under "Core Shroud Support Structures" in ALRA Table 2.3.1.B.2-1. Therefore, the
 
staff's concern described in RAI 2.3-4 is resolved.
2.3B.1.2.3  Conclusion
 
The staff reviewed the ALRA and RAI responses to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the reactor pressure vessel internals components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the reactor
 
pressure vessel internals components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).2.3B.1.3  NMP2 Reactor Pressure Vessel Instrumentation System 2.3B.1.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.B.3, the applicant described the reactor pressure vessel instrumentation system. The reactor pressure vessel instrumentat ion system provides a means of monitoring and transmitting information concerning key reactor vessel operating parameters during normal
 
and emergency operations. Instrumentation is installed to monitor reactor parameters and
 
indicate these on meters and chart recorders in the control room and remote shutdown panels.
 
The parameters monitored are reactor vessel temperature, water level and pressure, core flow
 
and core plate differential pressure. This system also provides control signals to various
 
systems which, in turn, initiate the appropria te actions required if the monitored parameter exceeds its desired setpoint. Systems receiving c ontrol signals from the reactor pressure vessel 2-134 instrumentation system include reactor protecti on, primary containment isolation, automatic depressurization, feedwater control, reactor recirculation flow control, redundant reactivity
 
control and residual heat removal (shutdown cooling mode) systems.
The reactor pressure vessel instrumentation sy stem contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the reactor
 
pressure vessel instrumentation system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the reactor pressure vessel instrumentation
 
system performs functions that support fire protection, EQ, ATWS, and SBO.
The intended functions within the scope of license renewal include the following:
* provides pressure retaining boundary
* provides shielding against radiation
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.1.B.3-1, the applicant identified the following reactor pressure vessel instrumentation system component types that are within the scope of license renewal and subject to an AMR:
* closure bolting
* condensing chambers
* piping and fittings
* radiation collars
* restriction orifices
* vacuum breakers
* valves 2.3B.1.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.B.3 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.1.B.3 identified an area in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
2-135 In RAI 2.3-2 dated October 11, 2005, the staff requested that the applicant indicate whether temperature equalizing columns should be identified as RPV instrumentation system
 
components requiring an AMR.
In its response by letter dated October 28, 2005, the applicant indicated that the NMP2 RPV instrumentation system does not utilize temper ature equalizing columns. For NMP2 the type of level measurement system makes no correction for changes in reactor vessel or reference leg
 
water temperature or density and is termed "non-compensated." Each instrument is calibrated at
 
the vessel pressure and drywell temperature at which the instrument is normally used.
 
Therefore, there are no temperature equalizing columns listed for review in the rector vessel
 
instrumentation system section.
Based on this review, the staff found the applicant's assessment acceptable. Therefore, the staff's concern described in RAI 2.3-2 is resolved.
2.3B.1.3.3  Conclusion
 
The staff reviewed the ALRA and RAI response to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were
 
identified. In addition, the staff performed a review to determine whether any components that
 
should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the reactor pressure vessel instrumentation system
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the reactor pressure vessel instrumentation sy stem components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.1.4  NMP2 Reactor Recirculation System 2.3B.1.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.B.4, the applicant described the reactor recirculation system. The reactor recirculation system is designed to provide a variable reactor coolant flow in order to control
 
reactor power levels. The reactor recirculation system is part of the RCPB and consists of two
 
external loops. Each loop contains a pump, flow control valve, two blocking valves, piping and
 
associated controls and instrumentation. Coolant flow is from the RPV annulus region, through
 
a recirculation pump and flow control valve, in to an external manifold from which individual recirculation inlet lines are routed to the jet pump risers within the RPV. The jet pumps are
 
evaluated as part of the reactor pressure vessel internals. The recirculation pumps operate at
 
two speeds with power coming from either the low frequency motor generator set (25 percent)
 
or a 60-Hz power source (100 percent). The flow control valves are controlled by two separate
 
sets of control system components, one for each valve.
The reactor recirculation system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the reactor recirculation
 
system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the reactor recirculation system performs functions that support fire protection, EQ, ATWS, and
 
SBO.
2-136 The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* provides shielding against radiation
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.1.B.4-1, the applicant identified the following reactor recirculation system component types that are within the scope of license renewal and subject to an AMR:
* closure bolting
* piping and fittings
* pumps
* radiation collars
* restriction orifices
* seal coolers
* valves 2.3B.1.4.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.B.4 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.1.4.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the reactor recirculation system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the reactor recirculation system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-1372.3B.1.5  NMP2 Control Rod Drive System 2.3B.1.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.1.B.5, the applicant described the CRD system. The CRD system is designed to change core reactivity by changing the position of control rods within the reactor
 
core in response to manual control signals and to scram the reactor in response to manual or
 
automatic signals. The system also provides wate r to the nuclear boiler instrumentation system reference leg backfill injection lines and the reactor water cleanup (RWCU) and reactor
 
recirculation pump seals. The control rod drive system consists of two redundant pumps, filters, control valves, hydraulic control units, contro l rod drive mechanisms, scram discharge volume and associated piping, valves, controls and instrumentation. The normal water supply for the
 
pumps is the condensate system with a backup supply from the condensate storage tank (CST).
 
The discharge of each pump provides water to the nuclear boiler instrumentation system
 
reference leg backfill injection lines, RWCU and reactor recirculation pump seals and through
 
filters and pressure and control valves to several portions of the system. These portions are
 
cooling water to the control rod drive mechanisms, charging water to the hydraulic control units, and drive water to the directional control valves. Following a reactor scram the exhaust water
 
from the control rod drive mechanisms is collected in the scram discharge volume.
The CRD system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the CRD system could potentially prevent the
 
satisfactory accomplishment of an SR function.
In addition, the CRD system performs functions that support fire protection, EQ, ATWS, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.1.B.5-1, the applicant identified the following CRD system component types that are within the scope of license renewal and subject to an AMR:
* accumulators
* closure bolting
* CRD hydraulic control units
* filters
* flow elements
* flow indicators
* flow orifices
* piping and fittings
* pumps 2-138
* rupture discs
* valves 2.3B.1.5.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.1.B.5 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.1.5.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the CRD system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the CRD system components that are subject to
 
an AMR, as required by 10 CFR 54.21(a)(1).2.3B.1.6  NMP2 Reactor Coolant Pressure Boundary Components in Other Systems 2.3B.1.6.1  Summary of Technical Information in the Amended Application RCPB components in other systems are evaluated in the GALL Report as part of the reactor vessel, internals, and reactor coolant system. In ALRA Section 2.3 RCPB components requiring
 
an AMR have been maintained in the plant system to which they are normally assigned rather than grouped with other RCPB components in the reactor vessel, internals, and reactor coolant
 
system. These NMP2 plant systems are listed below:NMP2 feedwater system (SER Section 2.3B.4.3)NMP2 floor and equipment drains system (SER Section 2.3B.3.14)NMP2 high-pressure core spray system (SER Section 2.3B.2.3)NMP2 low-pressure core spray system (SER Section 2.3B.2.4)NMP2 main steam system (SER Section 2.3B.4.4)NMP2 reactor core isolation cooling system (SER Section 2.3B.2.6)NMP2 reactor water cleanup system (SER Section 2.3B.3.25)NMP2 residual heat removal system (SER Section 2.3B.2.7)NMP2 standby liquid control system (SER Section 2.3B.3.31) 2.3B.1.6.2  Staff Evaluation 2-139 The staff's evaluations of each plant system is contained in the SER sections listed above.
2.3B.1.6.3  Conclusion
 
The staff's conclusions for each plant system are provided in the SER sections listed above.2.3B.2  Engineered Safety Features Systems In ALRA Section 2.3.2.B, the applicant identified the structures and components of the NMP2 ESF systems that are subject to an AMR for license renewal.
The applicant described the supporting structures and components of the ESF systems in the following sections of the ALRA:
* 2.3.2.B.1NMP2 automatic depressurization system
* 2.3.2.B.2NMP2 hydrogen recombiner system
* 2.3.2.B.3NMP2 high pressure core spray system
* 2.3.2.B.4NMP2 low pressure core spray system
* 2.3.2.B.5NMP2 primary containment isolation system
* 2.3.2.B.6NMP2 reactor core isolation cooling system
* 2.3.2.B.7NMP2 residual heat removal system
* 2.3.2.B.8NMP2 standby gas treatment system The staff's review findings regarding ALRA Sections 2.3.2.B.1 through 2.3.2.B.8 are presented in SER Sections 2.3B.2.1 through 2.3B.2.8, respectively.2.3B.2.1  NMP2 Automatic Depressurization System 2.3B.2.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.1, the applicant described the automatic depressurization system. The purpose of the automatic depressurization system is to reduce reactor pressure following small line breaks in the event of high-pressure core spray (HPCS) failure. When reactor vessel
 
pressure is reduced to within the capacity of the low-pressure systems [LPCI (described in the
 
residual heat removal (RHR) system) and low pressure core spray (LPCS) systems] these
 
systems provide inventory makeup to mainta in acceptable post-accident temperatures.
The automatic depressurization system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the automatic depressurization system
 
performs functions that support fire protection and EQ.
The component types subject to an AMR that per form the system intended functions for the automatic depressurization system are part of and evaluated in the main steam system (SER Section 2.3B4.4). No additional components within the automatic depressurization system are
 
subject to aging management review.
2-140 2.3B.2.1.2  Staff Evaluation The staff reviewed ALRA Section 2.3.2.B.1 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.1.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the automatic depressurization system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the automatic depressurization
 
system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.2.2  NMP2 Hydrogen Recombiner System 2.3B.2.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.2, the applicant described the hydrogen recombiner system. The purpose of the hydrogen recombiner system is to process the hydrogen and oxygen released to the primary containment during a LOCA. The hy drogen recombiner system takes suction from the drywell and suppression pool, recombines the hydrogen and oxygen gases, and returns the
 
resulting water vapor and other gases to the suppression pool.
The hydrogen recombiner system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the hydrogen recombiner
 
system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the hydrogen recombiner system performs functions that support EQ.
The intended functions within the scope of license renewal include the following:
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components 2-141 In ALRA Table 2.3.2.B.2-1, the applicant identified the following hydrogen recombiner system component types that are within the scope of license renewal and subject to an AMR:
* blowers
* bolting
* filters/strainers
* flow elements
* hydrogen recombiners
* piping and fittings
* valves
 
2.3B.2.2.2  Staff Evaluation The staff reviewed ALRA Section 2.3.2.B.2 and USAR Section 6.2.5.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.2.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the hydrogen recombiner system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the hydrogen recombiner system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.2.3  NMP2 High Pressure Core Spray System 2.3B.2.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.3, the applicant described the HPCS system. The purpose of the HPCS system is to maintain RPV coolant inventory after small breaks that do not depressurize
 
the RPV. The HPCS system also provides spray cooling heat transfer during breaks in which
 
core uncovery is calculated.
The HPCS system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the HPCS system could potentially prevent the satisfactory accomplishment of an SR functi on. In addition, the HPCS system performs functions that support fire protection, EQ, and ATWS.
2-142 The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.2.B.3-1, the applicant identified the following HPCS system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow elements
* piping and fittings
* pumps
* restriction orifices
* valves 2.3B.2.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.B.3 and USAR Sections 6.3.1.2.1 and 6.3.2.2.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.3.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the HPCS system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the HPCS system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-1432.3B.2.4  NMP2 Low Pressure Core Spray System 2.3B.2.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.4, the applicant described the low pressure core spray (LPCS) system.
The purpose of the LPCS system is to provide RPV coolant inventory makeup and spray cooling
 
during large breaks in which the core is calculated to uncover. Also, following a small break and
 
automatic depressurization system initiation, t he LPCS system provides coolant inventory makeup.The LPCS system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the LPCS system could potentially prevent the satisfactory accomplishment of an SR function.
In addition, the LPCS system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.2.B.4-1, the applicant identified the following LPCS system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow elements
* piping and fittings
* pumps
* restriction orifices
* valves 2.3B.2.4.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.B.4 and the USAR Sections 6.3.1.2.2 and 6.3.2.2.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review
 
in accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-144 2.3B.2.4.3  Conclusion The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the LPCS system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the LPCS system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.2.5  NMP2 Primary Containment Isolation System 2.3B.2.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.5, the applicant described the primary containment isolation system.
The purpose of the primary containment isolati on system is to provide protection against a release of radioactive materials to the environment from accidents occurring to the RCPB, lines
 
connected to the RCPB, or lines that penetrate the primary containment. This is accomplished
 
by automatic isolation valve closure of appropria te lines that penetrate the primary containment system. The primary containment isolation system consists of automatic isolation valves and associated piping for lines that penetrate the primary containment.
The primary containment isolation system c ontains SR components that are relied upon to remain functional during and following DBEs. In addition, the primary containment isolation
 
system performs functions that support SBO.
The component types requiring an AMR for the pr imary containment isolation system are evaluated in their respective systems.
2.3B.2.5.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.B.5 and USAR Section 6.2.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.5.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be 2-145 subject to an AMR had not been identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the primary containment isolation system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the primary containment
 
isolation system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.2.6  NMP2 Reactor Core Isolation Cooling System 2.3B.2.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.6, the applicant described the reactor core isolation cooling (RCIC) system. The purpose of the RCIC system is to assure that sufficient reactor water inventory is
 
maintained in the reactor vessel to permit adequate core cooling following those events in which
 
the normal feedwater supply is unavailable. This system can be used for accident and
 
nonaccident conditions.
The RCIC system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RCIC system could potentially prevent the
 
satisfactory accomplishment of an SR function.
In addition, the RCIC system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.2.B.6-1, the applicant identified the following RCIC system component types that are within the scope of license renewal and subject to an AMR:
* blower
* bolting
* condensing chambers
* drain pots
* filters/strainers
* flow elements
* heat exchangers
* piping and fittings
* pumps
* restriction orifices
* rupture discs
* terry turbine
* valves 2-146 2.3B.2.6.2  Staff Evaluation The staff reviewed ALRA Section 2.3.2.B.6 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.6.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the RCIC system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the RCIC system components that are subject to
 
an AMR, as required by 10 CFR 54.21(a)(1).2.3B.2.7  NMP2 Residual Heat Removal System 2.3B.2.7.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.7, the applicant described the residual heat removal system. The residual heat removal system is composed of three independent loops, each of which contains
 
a motor-driven pump, piping, valves, instrumentation, and controls. Each loop has a suction
 
source from the suppression pool and is capable of discharging water to either the reactor
 
vessel via a separate nozzle or back to the suppression pool via a full-flow test line. The A and
 
B loops have heat exchangers cooled by service water. Loops A and B can also take suction
 
from the reactor recirculation system suction and can discharge into the reactor recirculation
 
discharge or to the suppression pool and drywell spray spargers. The A and B loops also have
 
connections to reactor steam via the RCIC system steam line (Section 2.3.2.B.6) and can
 
discharge the resultant condensate to the RCIC system pump suction or to the suppression
 
pool. In addition, Loops A and B take suction from the fuel pool and discharge to the fuel pool
 
cooling discharge.
The three loops of the RHR system combine to fulfill five modes of operation. Each mode has its own functional requirements and is presented separately as follows:  (1)low pressure coolant injection mode-following a small break and automatic depressurization system initiation this mode provides coolant inventory makeup 2-147  (2)suppression pool cooling mode-ensures that the suppression pool temperature does not exceed design limits following a reactor vessel blowdown or isolation event  (3)containment spray cooling mode-provides two redundant means to spray the drywell and suppression pool to reduce internal pressure to below design limits  (4)reactor steam-condensing mode--provides in conjunction with the RCIC turbine the capability to condense all of the steam generated 1-1/2 hours after a reactor scram  (5)shutdown cooling mode-provides the capability to remove decay and sensible heat from the reactor primary system so that the cold shutdown condition can be achieved and
 
maintained The RHR system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RHR system could potentially prevent the
 
satisfactory accomplishment of an SR function.
In addition, the RHR system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.2.B.7-1, the applicant identified the following RHR system component types that are within the scope of license renewal and subject to an AMR:  * "T" quenchers
* bolting
* condensing chambers
* filters/strainers
* flow elements
* heat exchangers
* level elements
* piping and fittings
* pumps
* restriction orifices
* temperature elements
* valves 2.3B.2.7.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.B.7 and the USAR Section 5.4.7 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
2-148 In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.7.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the RHR system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the RHR system components that are subject to
 
an AMR, as required by 10 CFR 54.21(a)(1).2.3B.2.8  NMP2 Standby Gas Treatment System 2.3B.2.8.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.2.B.8, the applicant described the standby gas treatment system (SGTS).
The purpose of the SGTS is to limit the release of radioactive gases from the RB to the
 
environment within the guidelines of 10 CFR 100 in the event of a LOCA and to maintain a
 
negative pressure in the RB under accident conditions. It is also used to provide charcoal
 
filtration of the primary containment atmosphere when inerting, deinerting or controlling primary
 
containment pressure.
The SGTS contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the SGTS could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the SGTS performs functions that support EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.2.B.8-1, the applicant identified the following SGTS component types that are within the scope of license renewal and subject to an AMR:
* actuator
* blowers
* bolting
* filters/strainers 2-149
* flow elements
* heaters
* piping and fittings
* restriction orifices
* tanks
* valves 2.3B.2.8.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.2.B.8 and USAR Section 6.5.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.2.8.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the SGTS components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the SGTS components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3B.3  Auxiliary Systems In ALRA Section 2.3.3.B, the applicant identified the structures and components of the NMP2 auxiliary systems that are subjec t to an AMR for license renewal.
The applicant described the supporting structures and components of the auxiliary systems in the following sections of the ALRA:
* 2.3.3.B.1NMP2 air startup-standby diesel generator system
* 2.3.3.B.2NMP2 alternate decay heat removal system
* 2.3.3.B.3NMP2 auxiliary service building HVAC system
* 2.3.3.B.4NMP2 chilled water ventilation system (removed)
* 2.3.3.B.5NMP2 compressed air systems
* 2.3.3.B.6NMP2 containment atmosphere monitoring system
* 2.3.3.B.7NMP2 containment leakage monitoring system
* 2.3.3.B.8NMP2 control building chilled water system
* 2.3.3.B.9NMP2 control building HVAC system 2-150
* 2.3.3.B.10NMP2 diesel generator building ventilation system
* 2.3.3.B.11NMP2 domestic water system
* 2.3.3.B.12NMP2 engine-driven fire pump fuel oil system
* 2.3.3.B.13NMP2 fire detection and protection system
* 2.3.3.B.14NMP2 floor and equipment drains system
* 2.3.3.B.15NMP2 generator standby lube oil system
* 2.3.3.B.16NMP2 glycol heating system (removed)
* 2.3.3.B.17NMP2 hot water heating system
* 2.3.3.B.18NMP2 makeup water system
* 2.3.3.B.19NMP2 neutron monitoring system
* 2.3.3.B.20NMP2 primary containment purge system
* 2.3.3.B.21NMP2 process sampling system
* 2.3.3.B.22NMP2 radiation monitoring system
* 2.3.3.B.23NMP2 reactor building closed loop cooling water system
* 2.3.3.B.24NMP2 reactor building HVAC system
* 2.3.3.B.25NMP2 reactor water cleanup system
* 2.3.3.B.26NMP2 seal water system (removed)
* 2.3.3.B.27NMP2 service water system
* 2.3.3.B.28NMP2 spent fuel pool cooling and cleanup system
* 2.3.3.B.29NMP2 standby diesel generator fuel oil system
* 2.3.3.B.30NMP2 standby diesel generator protection (generator) system
* 2.3.3.B.31NMP2 standby liquid control system
* 2.3.3.B.32NMP2 yard structures ventilation system
* 2.3.3.B.33NMP2 auxiliary boiler system
* 2.3.3.B.34NMP2 circulating water system
* 2.3.3.B.35NMP2 makeup water treatment system
* 2.3.3.B.36NMP2 radioactive liquid waste management system
* 2.3.3.B.37NMP2 roof drainage system
* 2.3.3.B.38NMP2 sanitary drains and disposal system
* 2.3.3.B.39service water chemical treatment system
* 2.3.3.B.40NMP2 turbine building closed loop cooling water system The staff's review findings regarding ALRA Sections 2.3.3.B.1 through 2.3.3.B.40 are presented in SER Sections 2.3B.3.1 through 2.3B.3.40, respectively.2.3B.3.1  NMP2 Air Startup-Standby Diesel Generator System 2.3B.3.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.1, the applicant described the air startup-standby diesel generator system. The air startup-standby diesel generat or system includes the diesel generator combustion air intake and exhaust system. It is designed to provide: (1) a sufficient volume and
 
pressure of compressed air to enable the EDG to start within the required times and (2) reliable
 
combustion air intake and exhaust paths that supply clean air for combustion and a means to
 
discharge exhaust gases outside the diesel generator building. Each standby diesel generator
 
has redundant air starting systems, either of which is capable of starting the engine. To supply
 
combustion air and an exhaust path, fresh air is drawn from outside and passes through an
 
intake filter and an intake silencer located just inside the DGB. The air then passes through the
 
overspeed trip valve, an exhaust driven turbocharger, through a pair of combination 2-151 intercooler-heaters and then is distributed to each cylinder bank through the engine intake manifolds. Exhaust gases are discharged to the atmosphere above the DGB.
The air startup-standby diesel generator system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the air
 
startup-standby diesel generator system c ould potentially prevent the satisfactory accomplishment of an SR function. In addition, the air startup-standby diesel generator system
 
performs functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.1-1, the applicant identified the following air startup-standby diesel generator system component types that are with in the scope of license renewal and subject to an AMR:
* bolting
* diesel engine air start motors
* expansion joints
* filters/strainers
* moisture air separators
* mufflers
* piping and fittings
* starting air lubricator
* tanks
* valves 2.3B.3.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.1 and USAR Sections 9.5.6 and 9.5.8 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of original LRA Section 2.3.3.B.1 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening
 
results. The applicant responded to the staff's RAIs as discussed below.
2-152 In RAI 2.3.3.B.1-1, dated November 19, 2004, the staff stated that drawing LR-104A-0 shows that the license renewal boundary for the air startup standby diesel generator system stops at
 
two valves. Downstream piping and equipment have an SR pressure boundary function.
 
Original LRA Table 2.3.3.B-1 lists the starting air lubricators as subject to an AMR. The drawing
 
shows that two lubricators are not part of the boundary. Therefore, the staff requested that the
 
applicant provide the basis for not including this piping and the associated equipment within the
 
license renewal boundary.
In its response by letter dated December 22, 2004, the applicant stated that the boundary flag upstream of air startup lubricators 2EGA*L U325A and 2EGA*LU325B on drawing LR-104A-0 is incorrect, that these components are SR and subject to an AMR, and that the boundary flag
 
should be downstream of these components but upstream of the high pressure core spray
 
diesel generator 2EGS*EG2. The applicant further clarified that the high pressure core spray
 
diesel generator remains within the scope of license renewal but is not subject to an AMR since
 
it is an active component and that there is no piping or equipment in this system within the
 
scope of license renewal and subject to an AMR under 10 CFR 54.4(a)(2) because there is no
 
liquid in the system.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.1-1 acceptable because it adequately explained that the components in question 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), but were inadvertently left un-highlighted on the LR drawing. Therefore, the
 
staff's concern described in RAI 2.3.3.B.1-1 is resolved.
In RAI 2.3.3.B.1-2 dated November 19, 2004, the staff stated that USAR Section 9.5.8 states that turbocharger and intercooler heaters are part of the combustion air intake and exhaust
 
system. These components are not listed in the original LRA Table 2.3.3.B-1. These
 
components have a pressure boundary function. Therefore, the staff requested that the
 
applicant provide the basis for excluding these components as subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the turbocharger is an engine-mounted subcomponent of the Division I and II standby diesel generators and that
 
the Division III HPCS diesel generator also has an engine-mounted turbocharger. The applicant
 
explained that the Division I and II and HPCS diesel generators are SR and within the scope of
 
license renewal but are not subject to an AMR as they are active components. Thus, according
 
to the applicant, their turbocharger subcomponents are also within the scope of license renewal
 
but as part of the engine not subject to an AMR. The description of these subcomponents can
 
be found in USAR Section 9.5.8.2.
Based on its review the staff found the applicant's response to RAI 2.3.3.B.1-2 acceptable because it adequately explained that the turbocharger is an engine-mounted subcomponent of
 
the Division I and II standby diesel generators. The Division III HPCS diesel generator also has
 
an engine-mounted turbocharger. The Division I and II and HPCS diesel generators are SR and
 
within the scope of license renewal but are not subject to an AMR because they are active
 
components. For license renewal purposes, the intercooler heater is part of the NMP2 standby
 
generator protection system and listed in original LRA Table 2.3.3.B.30-1 as a heat exchanger.
 
The intercooler heater is passive and long-lived and within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a). The intercooler heater is shown 2-153 in red on the LR drawing for the jacket water subsystem of the standby diesel generator protection system. Therefore, the staff's concern described in RAI 2.3.3.B.1-2 is resolved.
In RAI 2.3.3.B.1-3 dated November 19, 2004, the staff requested that the applicant clarify information given on the related boundary drawing and in original LRA Table 2.3.3.B.1-1
 
concerning SSCs in scope of license renewal per 10 CFR 54.4(a). In original LRA
 
Table 2.3.3.B.1 the component type "Moisture Separator" is not listed as being subject to an
 
AMR. This exclusion is inconsistent with the original LRA drawing LRA-104A-0 showing the
 
moisture separator within the license renewal boundary.
In its response by letter dated December 22, 2004, the applicant stated that original LRA Table 2.3.3.B.1-1 does list the component type "Air Separators," an abbreviated form of the
 
description "Moisture Air Separator" listed for components 2EGA*SP 1A, 2EGA*SP1B, 2EGA*SP2A, and 2EGA*SP2B. These air separators are subject to an AMR as shown in
 
original LRA Table 3.3.2.B-1 (page 3.3-191). Therefore, the applicant stated that the original
 
LRA drawing LR-104A-0 is correct as drawn with respect to the moisture separators. The
 
applicant will revise the original LRA Table 2.3.3.B.l-1 to call these components "Moisture Air
 
Separators" and this response has been incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the applicant provided the staff with the revised LR drawing identifying SSCs within the scope of license renewal and subject to an AMR under
 
10 CFR 54.4(a)(2). The applicant also provided clarification on the component groups included
 
in original LRA Table 2.3.3.B.1-1.
Based on review of the information submitted in the amended LRA the staff's concern described in RAI 2.3.3.B.1-3 is resolved.
2.3B.3.1.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the air
 
startup-standby diesel generator system com ponents that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the air startup-standby diesel generator system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.2  NMP2 Alternate Decay Heat Removal System 2.3B.3.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.2, the applicant described the alternate decay heat removal system.
The alternate decay heat removal system in conjunction with natural circulation is designed to
 
remove the decay heat released from the spent fuel pool, reactor core, reactor internals, storage
 
pool, and cavity during refueling outages to maintain reactor coolant temperatures suitable for
 
refueling. The alternate decay heat removal system accomplishes its design function by utilizing 2-154 a primary loop for removing decay heat from the spent fuel pool and the reactor core and a secondary loop to transfer the decay heat to the atmosphere.
The alternate decay heat removal system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the alternate decay
 
heat removal system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the alternate decay heat removal system performs functions that support
 
EQ.The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.2-1, the applicant identified the following alternate decay heat removal system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow elements
* heat exchangers
* piping and fittings
* pumps
* valves 2.3B.3.2.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.2 and the USAR Section 9.1.6 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.2.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant 2-155 had adequately identified the alternate decay heat removal system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the alternate decay heat
 
removal system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.3  NMP2 Auxiliary Service Building HVAC System 2.3B.3.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.3, the applicant descr ibed the auxiliary service building HVAC system.
The auxiliary service building HVAC system is designed to provide an environment that ensures habitability of the areas served consistent with personnel comfort and optimum performance of
 
equipment. The system also supplies filtered and tempered outdoor air for all air conditioned
 
areas.The auxiliary service building HVAC system performs functions that support fire protection.
The intended function within the scope of license renewal is to provide pressure retaining boundary.In ALRA Table 2.3.3.B.3-1 the applicant identified that the "Fire Dampers" component type of the auxiliary service building HVAC system is within the scope of license renewal and subject to an AMR.2.3B.3.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.3 and USAR Section 9.4.9 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.3.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the auxiliary service bu ilding HVAC system components that are within the scope of license renewal, as requir ed by 10 CFR 54.4(a), and the auxiliary service building HVAC system components that ar e subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-1562.3B.3.4  NMP2 Chilled Water Ventilation System (Removed)
In ALRA Section 2.3.3.B.4, the applicant stated the chilled water ventilation system has been removed from the scope of license renewal since it has been determined that it does not meet
 
any of the criteria of 10 CFR 54.4. The original LRA included this system within the scope of
 
license renewal in accordance with 10 CFR 54.4(a)(2). However, based upon the applicant's
 
detailed evaluations this system is not credited for mitigation of any CLB event, contains no
 
SR/NSR interfaces, nor introduces any spatial interactions with SR SSCs. Therefore, the chilled
 
water ventilation system is not within the scope of license renewal.2.3B.3.5  NMP2 Compressed Air Systems 2.3B.3.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.5, the applicant described the compressed air systems. The compressed air systems are designed to provide clean, filtered air to various areas of NMP2.
 
The compressed air systems consist of the instru ment air system, servic e air system, breathing air system, and the primary containment vent ilation, purge, and nitrogen system. The instrument air system is designed to supply clean, dry, and oil-free air to plant instrumentation and control
 
systems that require an air supply. The service ai r system is designed to distribute service air to the plant systems that require air as a motive force or for mixing. The breathing air system is
 
designed to provide a reliable supply of clean, filtered air for human breathing. It also supplies
 
clean dry air for use of instruments. The primary containment ventilation, purge, and nitrogen
 
system is used in conjunction with the standby gas treatment system to inert and de-inert the primary containment as required. Functions of the primary containment ventilation, purge, and nitrogen system include providing a dedicated source of nitrogen gas for the operation of the
 
automatic depressurization system relief valves , providing a primary source of instrument nitrogen for the operation of gas-operated valves in primary containment, providing containment isolation and containment bypass leakage control.
The compressed air systems contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the compressed air systems could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the
 
compressed air systems performs functions that support fire protection, EQ, ATWS, and SBO.
The intended functions within the scope of license renewal include the following:
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* provides shielding against radiation
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction 2-157 In ALRA Table 2.3.3.B.5-1, the applicant identified the following compressed air systems component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filter
* piping and fittings
* orifices
* radiation collars
* rupture discs
* tanks and receivers
* valves 2.3B.3.5.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.5 and the USAR Section 9.3.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.5 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 RAIs 2.3.3.B.5-1 and 2.3.3.B.5-4 dated November 19, 2004, the staff requested that the applicant clarify information given on LR boundary drawings concerning SSCs in scope of
 
license renewal per 10 CFR 54.4(a). In RAI 2.3.3.B.5-1 the staff stated that LR drawing LR-006
 
Sheet A shows air operated control valves FV2A, 2B, and 2C (locations F-3, F-7 and F-10) as
 
subject to an AMR. Therefore, the staff requested that the applicant provide the basis for
 
excluding compressed air system auxiliaries to these valves from requiring an AMR. In RAI 2.3.3.B.5-4 the staff requested that the applicant provide the basis for excluding the double
 
acting cylinders from AMR, noting that the LR dr awings do not show the air cylinders as part of the license renewal boundary. This RAI was based on the assumption that the valves will go to
 
their fail-safe position on loss of air pressure. This assumption would be true for single-acting air
 
cylinders with springs but double-acting cylinders require air pressure for one of the cylinders to
 
effect valve repositioning to its fail-safe position. Therefore, the double acting cylinders have a
 
pressure boundary function.
In its response to 2.3.3.B.5-1 by letter dated December 22, 2004, the applicant stated that drawing LR-6A-0 is incorrect, that air-operated valves 2FWR-FV2A, 2FWR-FV2B, and
 
2FWRFV2C are not within the scope of license renewal per 10 CFR 54.4(a)(1) or (3) as these
 
valves are NSR and part of the feedwater pump recirculation balance drum leakoff system
 
which supports feedwater control and main feedwater in their functions to maintain reactor water 2-158 level during normal plant operation and as such the system and the subject valves are not credited for safe shutdown of the plant. Therefore, the applicant explained that the air supply
 
tubing and the solenoid valves are not within the scope of license renewal. Per LRA
 
Section 2.3.4.B.3, however, the referenced FWR valves and their associated piping are
 
in-scope for LR and subject to an AMR per 10 CFR 54.4(a)(2) as they are liquid-filled
 
components located in the turbine building in the vicinity of SR components. In its response to
 
RAI 2.3.3.B.5-4 by letter dated December 22, 2004, the applicant agreed that SR double-acting
 
actuators are in-scope for LR and subject to an AMR for a "Pressure Boundary" intended
 
function. The applicant stated that revisions to incorporate the AMR results and other
 
associated LRA changes will be submitted to the staff.
In its ALRA dated July 14, 2005, the applicant provided the staff with revised LR drawings which identify all SSCs within the scope of license renewal and subject to an AMR including those
 
subject under 10 CFR 54.4(a)(2).
Based on review of the information submitted in the ALRA the staff's concerns described in RAIs 2.3.3.B.5-1 and 2.3.3.B.5-4 are resolved.
In RAI 2.3.3.B.5-2 dated November 19, 2004, the staff stated that drawing LR-013 sheet E shows a fail closed valve as subject to an AMR. However, the air supply tubing and solenoid
 
valves are not shown as subject to an AMR. Therefore, the staff requested that the applicant
 
provide the basis for excluding the compressed air system auxiliaries to this valve as subject to an AMR.In its response by letter dated December 22, 2004, the applicant stated:
Drawing LR-13E-0 is correct for the air supply tubing to valve 2CCP*AOV37B (location D7), but incorrect for the air supply tubing to valve 2CCP*AOV38B. The
 
tubing to the actuator for 2CCP*AOV38B should also be shown in red as
 
safety-related and subject to AMR. The actuators for both of these fail-safe, air-operated valves (AOV) are safety-related and in-scope for LR but are not
 
subject to AMR since they are active components per NEI 95-10, Revision 3, Appendix B. As such, the actuators are correctly colored black; however, both
 
actuators should have a boundary flag at the actuator air inlet with an indicating
 
arrow "LR-CAS" towards the air supply side of the actuator and a solid blue
 
arrow towards the actuator itself.
Similar corrections apply on drawing LR-13E-0 for the air supplies to valves 2CCP*AOV37A and 2CCP*AOV38A (coordinated K2 and K4, respectively).
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.5-2 acceptable because the air supply tubing and solenoid valves to the valve in question are within the scope
 
of license renewal and subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.B.5-2 is resolved.
In RAI 2.3.3.B.5-3 dated November 19, 2004, the staff stated that on drawing LR-019 sheets L and M main steam isolation valves are shown as subject to an AMR. However, the air supply
 
tubing and solenoid valves are not shown on detail A of drawing LR-019 sheet L as requiring an 2-159 AMR. Therefore, the staff requested that the applicant provide the basis for excluding the compressed air system auxiliaries to these valves as subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that detail A of drawing LR-19L-0 is incorrect. The applicant explained that the instrument air tubing and solenoid valves
 
should all be highlighted in red up to the operator for valve 2MSS*AOV6C as SR within the
 
scope of license renewal and subject to an AMR consistent with the indication for these lines
 
and components at the other locations for the AOV-6s on this drawing. Since the MSS*AOV-6s
 
are SR valves the supply air tubing and in-line components are also SR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.5-3 acceptable because it stated that the air tubing and solenoid valves to the operator for valve AOV6C are SR
 
within the scope of license renewal and subject to an AMR in accordance with
 
10 CFR 54.4(a)(1) and 10 CFR 54.21(a)(1), respectively. Therefore, the staff's concern
 
described in RAI 2.3.3.B.5-3 is resolved.
2.3B.3.5.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
compressed air systems components that are within the scope of license renewal, as required
 
by 10 CFR 54.4(a), and the compressed air systems components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.6  NMP2 Containment Atmosphere Monitoring System 2.3B.3.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.6, the applicant described the containment atmosphere monitoring system. The containment atmosphere monitoring system is designed to supply information concerning containment parameters during normal and post-accident conditions. Monitored
 
drywell parameters are pressure, air temper ature, hydrogen, and oxygen concentration along with gaseous and particulate radiation levels. Monitored suppression chamber parameters are
 
pressure, air temperature, hydrogen and oxygen concentration, suppression pool level, and
 
temperature. In addition, drywell and suppression chamber humidity are monitored during
 
containment leak rate testing. The containm ent atmosphere monitoring system consists of radiation and hydrogen/oxygen monitoring lines. Each line penetrates the primary containment
 
and monitors the radiation level and hydrogen/oxygen concentration during normal operation so
 
they are equipped with containment isolation valves.
The containment atmosphere monitoring system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the containment
 
atmosphere monitoring system could potentially pr event the satisfactory accomplishment of an SR function. In addition, the containment atmo sphere monitoring system performs functions that support fire protection, EQ, and SBO.
2-160 The intended functions within the scope of license renewal include the following:
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.6-1, the applicant identified the following containment atmosphere monitoring system component types that are wi thin the scope of license renewal and subject to an AMR:
* bolting
* condensing chambers
* piping and fittings
* pumps
* valves 2.3B.3.6.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.6 and USAR Sections 6.2.1.7 and 6.2.4.3.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.6.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the containment atmosphere monitoring system components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the containment
 
atmosphere monitoring system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.7  NMP2 Containment Leakage Monitoring System 2.3B.3.7.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.7, the applicant described the containment leakage monitoring system.
The containment leakage monitoring system is des igned to provide a means of monitoring the 2-161 drywell area pressure and the suppression chamber pressure during periodic leak rate testing.
Two independent pressure sensing lines penetrate the primary containment and connect to
 
instrumentation outside the drywell during testi ng. The system also continuously monitors the drywell electrical penetrations to detect leakage past the sealing mechanism.
The containment leakage monitoring system c ontains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the containment
 
leakage monitoring system could potentially prev ent the satisfactory accomplishment of an SR function. In addition, the containment leak age monitoring system performs functions that support EQ.
The intended functions within the scope of license renewal include the following:
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.7-1, the applicant identified the following containment leakage monitoring system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* valves 2.3B.3.7.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.7 and USAR Section 6.2.6 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.7.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the containment leakage monitoring system components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the containment 2-162 leakage monitoring system components that are subjec t to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.8  NMP2 Control Building Chilled Water System 2.3B.3.8.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.8, the applicant described the control building chilled water system.
The control building chilled water system is designed to provide chilled water to the air
 
conditioning units that provide cooling for personnel and equipment in the control room, relay
 
room, remote shutdown room, and computer room. This system is designed to perform during normal operation, plant shutdown, or accident conditions without loss of function. The control
 
building chilled water system is a closed loop piping system consisting of two independent, redundant chilled water loops.
The control building chilled water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the control building
 
chilled water system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the control building chilled water system performs functions that support
 
fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.8-1, the applicant identified the following control building chilled water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* chillers
* flow elements
* piping and fittings
* pumps
* tanks
* valves 2.3B.3.8.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.8 and the USAR Sections 7.3.1.1.11 and 9.4.10.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review
 
in accordance with the guidance described in SRP-LR Section 2.3.
2-163 In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.8.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the control building chilled water system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the control building chilled
 
water system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.9  NMP2 Control Building HVAC System 2.3B.3.9.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.9, the applicant described the control building HVAC system. The control building HVAC system provides filtration, pressurization, heating, and cooling to the
 
control building envelope during normal and emergency operations by operating in normal, smoke purge, and emergency modes. Outdoor air is supplied to the control building through
 
missile and tornado protected air intakes. From the intakes the air is drawn into large duct
 
chases by the four air conditioning units. The air is heated or cooled by cooling coils in the air
 
conditioning units or by heaters in the ductwork and force circulated by the air conditioning unit
 
fans throughout the control building envelope. Natural exhaust ventilation is provided through
 
return registers back to the duct chases where most of the air is then recirculated. In the
 
emergency mode the system will divert the intake air through special filters under certain
 
conditions. The filter trains are normally bypassed and automatically come on line on either a
 
supply air radiation monitor trip system si gnal or a LOCA signal. They would then provide filtered air to the control, relay, and computer rooms. The system is equipped with a special
 
smoke removal system for use post-fire. It removes smoke and heat from the control building
 
using special supply and exhaust fans, dampers, and controls.
The control building HVAC system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the control building HVAC system performs
 
functions that support fire protection, EQ, SBO.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* provides pressure retaining boundary 2-164 In ALRA Table 2.3.3.B.9-1, the applicant identified the following control building HVAC system component types that are within the scope of license renewal and subject to an AMR:
* air handling unit
* blowers
* bolting
* ducting
* filters/strainers
* flow elements
* heat exchangers
* piping and fittings
* radiation sample point
* valves and dampers (includes fire dampers) 2.3B.3.9.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.9 and USAR Section 9.4.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.9.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the control building HVAC system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the control building HVAC system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.10  NMP2 Diesel Generator Building Ventilation System 2.3B.3.10.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.10, the applicant described the diesel generator building ventilation system. The diesel generator building ventilati on system is designed to provide heating and outside air ventilation to the diesel rooms and diesel generator control rooms. Each diesel
 
generator room is equipped with its own ventila tion system. Additionally, the diesel generator building ventilation HVAC system is designed with unit coolers to maintain habitable conditions
 
for personnel comfort within the diesel generator control rooms. The diesel generator building 2-165 ventilation system performs the following functi ons: normal heating, normal ventilation, control room cooling, and general area emergency ventilation. The normal duty heating function maintains the diesel generator rooms above 65 °F during the winter. The normal ventilation
 
function maintains the diesel generator rooms adequately ventilated and exhausts room air to
 
the atmosphere. The control room cooling function maintains the diesel generator rooms below
 
the maximum design temperature via unit coolers which is provided from the service water
 
system (SER Section 2.3.3B.27). The general ar ea emergency ventilation function establishes a ventilating flow of outside air through the diesel generator rooms to ensure that the space temperatures remain below 125 °F outside the control room or 104 °F inside the control room for
 
efficient equipment operation.
The diesel generator building ventilation system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the diesel generator building
 
ventilation system performs functions that support fire protection and EQ.
The intended function within the scope of license renewal is to provide pressure retaining boundary.In ALRA Table 2.3.3.B.10-1, the applicant identified the following diesel generator building ventilation system component types that are wi thin the scope of license renewal and subject to an AMR:
* blowers
* dampers (includes fire dampers)
* ducting
* unit coolers 2.3B.3.10.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.10 and USAR Section 9.4.6 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.10.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the diesel generator building ventilation system components that are 2-166 within the scope of license renewal, as required by 10 CFR 54.4(a), and the diesel generator building ventilation system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.11  NMP2 Domestic Water System 2.3B.3.11.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.11, the applicant described the domestic water system. The domestic water system is designed to provide sufficient domestic water from an existing city main to various areas of the plant including the makeup water treatment system (SER
 
Section 2.3.3B.35) and the fire protection syst em (SER Section 2.3.3B.13). Additionally the domestic water system ensures minimization of flooding potential by providing isolation capabilities of the control building from domestic water supply should piping within the building
 
rupture during a seismic event. Domestic water is supplied to various buildings throughout the
 
plant including the control building, TB, and the auxiliary building. The domestic water system
 
also provides makeup water to various systems including the fire protection system and the
 
filtered water tank.
The domestic water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the domestic water system could
 
potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary In ALRA Table 2.3.3.B.11-1, the applicant identified the following domestic water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* tanks
* valves 2.3B.3.11.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.11 and USAR Sections 1.2.10.10 and 9.2.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not 2-167 omitted any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.11.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the domestic water system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the domestic water system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.12  NMP2 Engine-Driven Fire Pump Fuel Oil System 2.3B.3.12.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.12, the applicant described the engine-driven fire pump fuel oil system.
The engine-driven fire pump fuel oil system is designed to supply fuel oil to the diesel
 
engine-driven fire pump. The electric-driven fi re pump and diesel engine-driven fire pump are located in separate rooms within the SWB. The fuel oil storage tank for the diesel fire pump is
 
located in the diesel fire pump room above a sump. Fuel is gravity fed to the engine and excess
 
fuel supplied to the engine by its fuel pump is recirculated to the tank.
The engine-driven fire pump fuel oil system perfo rms functions that support fire protection.
The intended function within the scope of license renewal is to provide pressure retaining boundary.In ALRA Table 2.3.3.B.12-1, the applicant identified the following engine-driven fire pump fuel oil system component types that are within t he scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* tank
* valves
 
2.3B.3.12.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.B.12 and USAR Sections 9.5.1.2.2 and 9A.3.1.2.5.6 using the evaluation methodology described in SER Section 2.3. The staff conducted its review
 
in accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not 2-168 omitted any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
The staff also reviewed approved fire protection safety evaluation report NUREG-1047, dated February 1985 (and Supplements 1 through 6) for Unit 2. This report is referenced directly in the
 
Nine Mile Point Unit 2 fire protection CLB and summarize the Fire Protection Program and
 
commitments to 10 CFR 50.48 using the guidance of Appendix A to BTP CMEB 9.5-1. The staff
 
then reviewed those components that the applicant identified as being within the scope of
 
license renewal to verify that the applicant did not omit any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
On the basis of its review, the staff found that the applicant has identified those portions of the engine driven fire pump fuel oil system that meet the scoping requirements of 10 CFR 54.4(a) and has included them within the scope of license renewal in ALRA Section 2.3.3.B.12. The
 
applicant has also included engine driven fire pump fuel oil system components that are subject to an AMR in accordance with the requirements of 10 CFR 54.4(a) and 10 CFR 54.21(a)(1) in
 
LRA Table 2.3.3.B.12-1. The staff did not identify any omissions.
2.3B.3.12.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the engine-driven fire pump fuel oil system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the engine-driven fire pump
 
fuel oil system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.13  NMP2 Fire Detection and Protection System 2.3B.3.13.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.13, the applicant described the fire detection and protection system.
The fire detection and protection system is designed for detecting, alarming, isolating, and
 
suppressing fires in the plant. The fire protection system consists in part of a reliable freshwater
 
supply, one electric motor-driven fire pump and one diesel engine-driven fire pump, two
 
pressure maintenance fire pumps, one pressure maintenance pump supply tank, one
 
hydropneumatic tank, fire water yard mains, hydrants, standpipes, hose stations, sprinkler, water spray, preaction and deluge systems, foamwater deluge systems, low-pressure CO 2 systems, Halon 1301 systems, and a detection and signaling system. These components in the fire detection and protection system are further di vided into the fire protection foam system, the fire protection halon system, the Cardox fire protection system, the fire detection system, and the fire protection water system. The collectiv e capability of the fire suppression systems is adequate to minimize potential damage to SR equipment and is a major element in the facility
 
Fire Protection Program. The fire protection f oam system provides fire suppression through blanketing affected areas with dense foam provided by mixing of fire system water, foam
 
concentrate, and air. The fire protection halon system is designed to suppress cable fires in the
 
floor sections of the computer room, relay r oom, control room, and the radwaste control room.
2-169 The Cardox fire protection system is designed to supply CO 2 to fixed and hose reel stations for the purpose of extinguishing fires. The fire detection system is designed to provide early
 
detection, annunciation, and actuation of suppression systems in the event of a fire. The
 
thermal and smoke detection systems function to detect products of combustion, alarming both
 
locally and in the main control room. The fire pr otection water system is designed to provide a reliable, readily available source of water for controlling and extinguishing fires. Additionally the
 
fire protection water system provides control room indication and may be used as an alternative
 
injection/spray source into the RPV or as primary containment by cross-connecting fire
 
protection water to the RHR system. The water source for the fire protection system is Lake
 
Ontario, which is considered to be unlimited.
The failure of NSR SSCs in the fire detection and protection system could potentially prevent the satisfactory accomplishment of an SR function. The fire detection and protection system
 
also performs functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* provides over-pressure protection
* converts liquid into spray
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.13-1 the applicant identified the following fire detection and protection system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* fire hydrants
* flow elements
* halon tank flex hoses
* heat exchangers
* hose reels
* manifold
* nozzles
* odorizers
* orifices
* piping and fittings
* pumps
* ratio flow proportioner
* rupture discs
* silencer
* strainers
* tanks 2-170
* temperature indicators
* valves 2.3B.3.13.2  Staff Evaluation
 
The staff reviewed LRA and ALRA Section 2.3.3.B.13 and USAR Sections 9.5.1, 9A.3.1.2.5.4, and 9A.3.6 using the evaluation methodology described in SER Section 2.3. The staff
 
conducted its review in accordance with the guidance described in SRP-LR Section 2.3.
The staff also reviewed approved fire protection safety evaluation report NUREG-1047, dated February 1985 (and Supplements 1 through 6) for Unit 2. This report is referenced directly in the
 
Nine Mile Point Unit 2 fire protection CLB and summarize the Fire Protection Program and
 
commitments to 10 CFR 50.48 using the guidance of Appendix A to BTP CMEB 9.5-1. The staff
 
then reviewed those components that the applicant identified as being within the scope of
 
license renewal to verify that the applicant did not omit any passive and long-lived components that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).
In reviewing LRA Section 2.3.3.B.13, the staff identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results.
 
Therefore, by letter to the applicant dated November 17, 2004, the staff issued a request for RAI
 
concerning the specific issues to determine whether the applicant has properly applied the
 
scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1). The
 
applicant responded to the staff's RAIs as discussed below.In RAI 2.3.3.B.13-1 dated November 17, 2004, the staff stated that GALL Report Section XI.27 describes the requirements for aging management of the fire protection water system. It requires that an AMP be established to evaluate the aging effects of microbiologically induced
 
corrosion (MIC) and biofouling of carbon steel and cast iron components in fire protection
 
systems exposed to water.
The LRA discusses requirements for the fire detection and protection program but does not mention trash racks and traveling screens for the fire pump suction water supply. Trash racks
 
and traveling screens are mentioned in the LRA sect ion for the service water system but are not listed in the associated LRA table for that system containing the list of components that require
 
aging management. The components are not mentioned in the LRA.
The USAR states that the trash racks and traveling screens are located upstream of the fire pump suctions to remove any major debris from the water. Therefore, the staff requested that
 
the applicant explain the apparent exclusion of the trash racks and traveling screens located
 
upstream of the fire pump suctions from the scope of license renewal and from being subject to an AMR.In its response by letter dated December 17, 2004, the applicant stated that although the trash racks and traveling screens are addressed in USAR Section 9.2.5 as preventing large debris
 
from reaching the service water pumps and therefore the fire pumps as well the collection of
 
debris on the trash racks and/or the traveling screens such that blockage could occur is not a
 
license renewal intended function under 10 CFR 50.48. If such a blockage occurred bypass
 
valves would open automatically to bypass the blockage and continue to supply water to the
 
pump suctions. Additionally the fire pump sucti on headers have their own strainers in line so the 2-171 loss of the trash racks or traveling screens would not affect the operation of these pumps until repair/replacement of the damaged component could be performed.
The applicant further stated that the supports of the trash racks are within the scope of license renewal and subject to an AMR.
In evaluating this response the staff found that it was incomplete and that review of LRA Section 2.3.3.B.13 could not be completed. The response explains that the trash racks and
 
traveling screens are addressed in the USAR but that they perform no intended function. The
 
staff found this explanation contrary to the USAR, which includes the original NMP2 fire
 
protection SE as CLB. As a result the staff held a teleconference with the applicant on
 
January 25, 2005, to discuss information necessary to resolve the concern in RAI 2.3.3.B.13-1.
 
The product of the teleconference was an agreement by the applicant to transmit the required
 
information by a follow-up letter.
By letter dated February 11, 2005, the applicant provided references to the USAR that describes the bypass valves that provide a traveling water screen bypass flow path to the service water pumps and the fire water pumps. This bypass operates automatically using safety-related, seismically-qualified components, thereby assuring sufficient service water suction bay water level and adequate fire pump suction supply in the event of blockage of the
 
trash rakes or traveling screens. Thus, the applicant stated that the trash rakes and traveling
 
screens do not perform or support any fire protection intended functions.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-1, including the information in the teleconference and letter dated February 11, 2005, acceptable because it
 
adequately described the intended function supporting the fire pump suction supply as
 
accomplished by the automatic bypass valves. Furt her, the bypass valves and their controls are SR and are within the scope of license renewal under 10 CFR 54.4(a)(1). Therefore, the staff's
 
concern described in RAI 2.3.3.B.13-1 is resolved.
In RAI 2.3.3.B.13-2 dated November 17, 2004, the staff noted that the GALL ReportSection XI.27, "Fire Water System," states the requirements for sprinklers, including the
 
inspection frequency recommended by the National Fire Protection Association 25 leading to
 
their eventual replacement. LRA Table 2.3.3.B.13-1 does not include sprinklers within the scope
 
of license renewal and subject to an AMR. The applicant was asked to verify that sprinklers in
 
the fire detection and protection system are within the scope of license renewal and to indicate
 
where they are identified in the LRA.
In its response by letter dated December 17, 2004, the applicant stated that sprinklers are included within the scope of license renewal and subject to an AMR under the component type
 
"Nozzles" in the LRA table associated with the fire detection and protection system and that the
 
corresponding AMR summary is addressed in LRA Section 3.3.2.B.13 and in Table 3.3.2.B-13.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-2 acceptable because it adequately explained that the sprinklers in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a). Further, the
 
applicant stated that the sprinklers are represented in the LRA table by the component type
 
"Nozzles." Therefore, the staff's concern described in RAI 2.3.3.B.13-2 is resolved.
2-172 In RAI 2.3.3.B.13-3 dated November 17, 2004, the staff noted that LRA Section 2.3.3.B.13 states that the fire protection foam subsystem components subject to an AMR consist of one
 
water header valve. LRA Table 3.3.2.B-13 lists valve environments as air, dried air or gas, and
 
raw water, low flow. Also, the water supply portion of the fire protection foam subsystem
 
includes two foam concentrate storage tanks, four foam concentrate pumps, a foam water ratio
 
flow proportioner, numerous valves exposed to f oam concentrate and valves exposed to foam-water mixture, and a piping distribution system exposed to both foam concentrate and foam-
 
water mixture. Therefore, the staff requested that the applicant identify where the components in
 
question were shown in the LRA.
In its response by letter dated December 17, 2004, the applicant stated that the LRA section for the fire detection and protection system identifying the foam subsystem components subject to
 
an AMR consisting of one water header valve is in error and that the components subject to an
 
AMR for the fire protection foam subsystem are shown on its LR drawing and include the foam
 
concentrate tanks, foam concentrate pumps, valves, ratio flow proportioner, and piping as
 
indicated on the drawing. The applicant revised LRA Sections 2.3.3.B.13 and 3.3.2.B.13, and
 
Table 3.3.2.B-13 to address the fire protection foam subsystem properly. The applicant revised
 
LRA Section 2.3.3.B.13 to include the two foam concentrate tanks, the four foam concentrate
 
pumps, the ratio foam proportioner, and the associated piping, fittings, and valves connecting
 
these components which make up the foam dist ribution system as components subject to an AMR. LRA Section 3.3.2.B.13 was revised to add liquid foam concentrate and liquid foam concentrate/raw water, low flow environments. LRA Table 3.3.2.B-13 was revised by the
 
applicant to add AMR for the subject foam system components in these environments. The applicant stated that LRA scoping and screening Table 2.3.3.B.13-1 did not require revision
 
because it already generically included the components in question.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-3 acceptable because it adequately explained that the LRA erroneously excluded components in the foam
 
subsystem of the fire detection and protection system and that the associated AMR table and
 
LRA sections have been revised to add the subject components and environments. Therefore, the staff's concern described in RAI 2.3.3.B.13-3 is resolved.
In RAI 2.3.3.B.13-4 dated November 17, 2005, the staff stated that the NMP2 USAR states that fusible link-actuated heat vents are provided in the turbine building roof. The fusible links are set
 
high enough to preclude release due to a steam leak. These vents reduce the possibility of roof
 
collapse in the event of a fire on the operating level.
Fusible links are not described in the fire detection and protection section of the LRA. Fire dampers are described in another part of the LRA and identify a one-time inspection to manage
 
their aging effects.
Heat-sensitive fusible links are composed of heat-sensitive solder and are long-lived passive components that should be within the scope of license renewal and subject to an AMR.
 
Therefore, the staff requested that the applicant explain the apparent exclusion of the
 
heat-sensitive fusible links in the turbine building heat removal system from requiring an AMR
 
and how a one-time inspection would adequately manage the aging effects of fire dampers
 
which utilize fusible links as their actuating devices.
2-173 In its response by letter dated December 17, 2004, the applicant stated that because the fusible links require a change in state to perform their function they are considered an active
 
component. Therefore, although they are within scope of license renewal they are not subject to
 
an AMR. Further, the applicant explained that the NMP2 turbine building roof vent housings
 
inadvertently were excluded from scope and AM R. The applicant stated that these components fall into a component type already addressed in t he LRA. In LRA Table 2.4.B.13-1 the roof vent housings fall under the last component type in the table, i.e., "Structural Steel (Carbon and Low
 
Alloy Steel) in Air." Their intended function is "Structural Support for NSR." Their AMR is
 
addressed in LRA Section 3.5.2.B.13 and Table 3.5.2.B-13. These components will be
 
managed for aging consistent with the information presented in the referenced LRA locations.
As to aging management of the fire dampers included in LRA Table 3.3.2.B-9, because of their fabrication material, the environment to which they are exposed, and plant operating history the
 
fire dampers are not expected to experience loss of material. For that reason the one-time
 
inspection program has been deemed to be adequate for aging management of these dampers.
 
If the aging effect is discovered as a function of that inspection the inspection scope will be
 
expanded consistent with the program requirements described in LRA Section B2.1.20.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-4 acceptable because it adequately explained that although the fusible links in question are within the scope
 
of license renewal under 10 CFR 54.4(a) they are active components and are not subject to an
 
AMR under 10 CFR 54.21(a). In addition the applicant explained that due to their fabrication
 
material, the environment to which they are exposed, and plant operating history the fire
 
dampers are not expected to experience loss of material and the one-time inspection program is adequate for managing the aging of these components. Therefore, the staff's concern described
 
in RAI 2.3.3.B.13-4 is resolved.
In RAI 2.3.3.B.13-5 dated November 17, 2004, the staff stated that LR drawing LR-43A-O for the diesel engine-driven fire pump identifies the fuel oil supply piping immediately upstream of
 
the diesel engine as within scope of license renewal and subject to an AMR. Additionally the LR
 
drawing indicates that the engine should be subject to an AMR because it is enclosed within
 
"flags." The engine itself, however, is not shown as highlighted for AMR. The applicant was
 
asked to explain the apparent discrepancy between the LR drawing and the AMR boundary
 
flags. In its response by letter dated December 17, 2004, the applicant explained that drawing LR-43A-0 is incorrect and does not properly show the components within the scope of license
 
renewal and subject to an AMR. The applicant further stated that the engine is not subject to an
 
AMR but its fuel oil supply piping is.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-5 acceptable because it adequately explained that the components in question 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), but were inadvertently left un-highlighted on the LR drawing, except for the
 
engine which was correctly identified as not being subject to an AMR. Therefore, the staff's
 
concern described in RAI 2.3.3.B.13-5 is resolved.
In RAI 2.3.3.B.13-6 dated November 17, 2005, the staff stated that LR drawing LR-43B-0 for the fire detection and protection system identifies piping upstream of a valve leading to the 2-174 radwaste building via the yard as within the scope of license renewal and subject to an AMR.
However, the yard piping between the valve in question and the radwaste building appears to
 
be excluded from requiring an AMR. The applicant wa s asked to explain the apparent exclusion of this portion of the fire detection and protection system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that the LR drawing in question, LR-43B-0, was in error and that the yard piping and components in question should
 
have been highlighted on the LR drawing showing them within the scope of license renewal and
 
subject to an AMR but inadvertently were not highlighted. The components in question have
 
been included within the scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-6 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but were
 
inadvertently left un-highlighted on the LR drawing. The staff concludes that there is reasonable
 
assurance that the components were correctly included within the scope of license renewal and
 
subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-6 is resolved.
In RAI 2.3.3.B.13-7 dated November 17, 2004, the staff stated that although LR drawing LR-43E-0 for the fire detection and protection shows a valve installed in piping within the scope
 
of license renewal and subject to an AMR the valve itself is not. The applicant was asked to
 
explain the apparent exclusion of this valve from being subject to an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-43E-0 is incorrect and does not properly show the component within the scope of license renewal and
 
subject to an AMR. The component in question should have been highlighted on the LR drawing
 
showing it within the scope of license renewal and subject to an AMR but inadvertently was not
 
highlighted. The component in question has been included within the scope of license renewal
 
and is subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-7 acceptable because it adequately explained that the component in question is 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), but inadvertently was not highlighted on the LR drawing. The staff concludes
 
that there is reasonable assurance that the components were included correctly within the
 
scope of license renewal and subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.B.13-7 is resolved.
In RAI 2.3.3.B.13-8 dated November 17, 2004, the staff stated that although drawing LR-43E-0 depicts the water spray system for one of the reactor feedwater pumps in scope of license
 
renewal and subject to an AMR two other reactor feedwater pumps do not require AMR. The
 
applicant was asked to explain the apparent exclusion of this portion of the fire protection
 
system from being subject to an AMR.
In its response by letter dated December 17, 2004, the applicant stated that LR drawing LR-43E-0 is incorrect and does not properly show the components within the scope of license
 
renewal and subject to an AMR. The components in question should have been highlighted on
 
the LR drawing showing that they are within the scope of license renewal and subject to an 2-175 AMR but inadvertently were not highlighted. The components in question have been included within the scope of license renewal and are subject to an AMR.
 
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-8 acceptable
 
because it adequately explained that the components in question 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) but inadvertently were not highlighted on the LR drawing. The staff concludes
 
that there is reasonable assurance that the components were included correctly within the
 
scope of license renewal and subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.B.13-8 is resolved.
In RAI 2.3.3.B.13-10 dated November 17, 2004, the staff stated that drawing LR-43F-0 depicts several portions of piping zones within the scope of license renewal and subject to an AMR but
 
not other portions of the same piping zone. Therefore, the staff requested that the applicant
 
explain the apparent exclusion of these portions of the fire detection and protection system from
 
requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-43F-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR, that the components in question should have been highlighted on the LR
 
drawing showing them within the scope of license renewal and subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-10 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-10 is resolved.
In RAI 2.3.3.B.13-11 dated November 17, 2004, the staff stated that although drawing LR-43G-0 at location E-4 depicts piping adjacent to a specific valve as within the scope of license renewal
 
and subject to an AMR the piping to this valve is not. The applicant was asked to explain the
 
apparent exclusion of these portions of the fire detection and protection system from requiring an AMR.In its response by letter dated December 17, 2004, the applicant stated that drawing LR-43G-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should have been highlighted on the LR
 
drawing showing them within the scope of license renewal and subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-11 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-11 is resolved.
2-176 In RAI 2.3.3.B.13-12 dated November 17, 2004, the staff stated that drawing LR-43H-0 depicts piping to some pressure switches in the system as within the scope of license renewal and
 
subject to an AMR but not other piping to similar pressure switches. Therefore, the staff
 
requested that the applicant explain the apparent exclusion of this portion of the fire detection
 
and protection system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-43H-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should have been highlighted on the LR
 
drawing showing them within the scope of license renewal and subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-12 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were correctly included within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-12 is resolved.
In RAI 2.3.3.B.13-13 dated November 17, 2005, the staff stated that drawing LR-43H-0 depicts piping to some valve tamper switches in the system as within the scope of license renewal and subject to an AMR but not other piping to similar valve tamper switches. Therefore, the staff
 
requested that the applicant explain the apparent exclusion of this portion of the fire detection
 
and protection system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-43H-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should not have been highlighted on the LR
 
drawing showing that they are within the scope of license renewal and are subject to an AMR
 
but were highlighted. inadvertently. The components in question should not have been included
 
within the scope of license renewal and are not subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-13 acceptable because it adequately explained that the components in question are not within the scope of
 
license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but were
 
highlighted inadvertently on the LR drawing. The staff concludes that there is reasonable
 
assurance that the components were included incorrectly within the scope of license renewal
 
and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-13 is
 
resolved.In RAI 2.3.3.B.13-14 dated November 17, 2004, the staff stated that drawing LR-44A-0 depicts a piping section in the system as within the scope of license renewal and subject to an AMR but
 
not another piece of piping within this section connecting the system to a valve. Therefore, the
 
staff requested that the applicant explain the apparent exclusion of this portion of the fire
 
detection and protection system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-44A-0 is incorrect and does not properly show the components within the scope of license renewal and 2-177 subject to an AMR. The components in question should have been highlighted on the LR drawing showing them within the scope of license renewal and subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-14 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-14 is resolved.
In RAI 2.3.3.B.13-15 dated November 17, 2004, the staff stated that drawing LR-44A-0 depicts drain line piping in some portions of the system as within the scope of license renewal and
 
subject to an AMR but not drain line piping in other portions of the system. Therefore, the staff
 
requested that the applicant explain the apparent exclusion of this portion of the fire detection
 
and protection system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-44A-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should have been highlighted on the LR
 
drawing showing that they are within the scope of license renewal and subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-15 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-15 is resolved.
In RAI 2.3.3.B.13-16 dated November 17, 2004, the staff stated that drawing LR-44A-0 depicts piping in some portions of the system as within the scope of license renewal and subject to an
 
AMR but not other sections of piping connecting the system to valves. The applicant was asked
 
to explain the apparent exclusion of this portion of the fire detection and protection system from
 
requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-44A-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should have been highlighted on the LR
 
drawing showing them within the scope of license renewal and are subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and are subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-16 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance 2-178 that the components were included correctly within the scope of license renewal and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-16 is resolved.
In RAI 2.3.3.B.13-17 dated November 17, 2004, the staff stated that drawing LR-45C-0 depicts several solenoid valves in some portions of the system as within the scope of license renewal
 
and subject to an AMR but not other similar solenoid valves in the system. The applicant was
 
asked to explain the apparent exclusion of such valves in the fire detection and protection
 
system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that Drawing LR-45C-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should have been highlighted on the LR
 
drawing showing them within the scope of license renewal and are subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and are subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-17 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-17 is resolved.
In RAI 2.3.3.B.13-18 dated November 17, 2004, the staff stated that drawing LR-45C-0 depicts piping sections associated with several solenoid valves in portions of the system as within the
 
scope of license renewal and subject to an AMR but not other similar piping sections associated
 
with similar solenoid valves in the system. Therefore, the staff requested that the applicant
 
explain the apparent exclusion of these valves of the fire detection and protection system from requiring an AMR.
 
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-45C-0
 
is correct and properly shows some of the identified piping associated with SV153 excluded
 
from the scope of license renewal and from being subject to an AMR. The applicant stated that
 
although some of the components in question were highlighted incorrectly none of the identified
 
piping downstream of the solenoid valves should have been highlighted on the LR drawing in
 
question, LR-45C-0, showing them within the scope of license renewal and subject to an AMR, that the piping downstream of the solenoid valves is associated with cardox hose reels and
 
provides venting and that the piping described is not required for the cardox system to perform its intended function and therefore is not subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-18 acceptable because it adequately explained that all the similar components in question are not within the
 
scope of license renewal under 10 CFR 54.4(a) and not subject to an AMR under
 
10 CFR 54.21(a) but that some were highlighted inadvertently on the LR drawing. The staff
 
concludes that there is reasonable assurance that the components were excluded correctly
 
from the scope of license renewal. Therefore, the staff's concern described in RAI 2.3.3.B.13-18
 
is resolved.
In RAI 2.3.3.B.13-19 dated November 17, 2004, the staff stated that drawing LR-45C-0 depicts piping sections associated with several solenoid valves in portions of the cardox system as 2-179 within the scope of license renewal and subject to an AMR but not other similar piping sections associated with similar solenoid valves in t he system. The applicant was asked to explain the apparent exclusion of these sections of the fire detection and protection system from requiring
 
an AMR.In its response by letter dated December 17, 2004, the applicant stated that drawing LR-45C-0 is correct and properly shows some of the components in question excluded from the scope of
 
license renewal and requiring an AMR. Although some of the components in question were
 
highlighted incorrectly none of the components in question should have been highlighted on the
 
LR drawing showing them within the scope of license renewal and subject to an AMR. The
 
components in question are associated with cardox zone discharge piping and provide venting.
 
The piping described is not required for the cardox system to perform its intended function.
 
Therefore, they are not subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-19 acceptable because it adequately explained that all the similar components in question are not within the
 
scope of license renewal under 10 CFR 54.4(a) and not subject to an AMR in under
 
CFR 54.21(a) but that some were highlighted inadvertently on the LR drawing. The staff
 
concludes that there is reasonable assurance that the components were correctly excluded
 
from the scope of license renewal. Therefore, the staff's concern described in RAI 2.3.3.B.13-19
 
is resolved.
In RAI-2.3.3.B.13-20 dated November 17, 2004, the staff stated that drawing LR-46-0 depicts piping to a specific solenoid valve at a halon storage bottle in a portion of the halon system as
 
within the scope of license renewal and subject to an AMR but not similar piping to other
 
solenoid valves in the system, The applicant was asked to explain the apparent exclusion of this portion of the fire detection and protection system from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-46A-0 is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR. The components in question should have been highlighted on the LR
 
drawing showing them within the scope of license renewal and are subject to an AMR but
 
inadvertently were not highlighted. The components in question have been included within the
 
scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-20 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-20 is resolved.
In RAI-2.3.3.B.13-21 dated November 17, 2004, the staff stated that various LR drawings for the fire detection and protection system depict tamper switches associated with several water
 
supply valves in the system as within the scope of license renewal and subject to an AMR but
 
not other similar tamper switches in the foam and the cardox subsystems. Therefore, the staff requested that the applicant explain the apparent exclusion of these switches of the fire
 
detection and protection system from requiring an AMR.
2-180 In its response by letter dated December 17, 2004, the applicant stated that the identified LR drawings are incorrect and do not properly show the components within the scope of license
 
renewal and subject to an AMR. The applicant stated that the tamper switches in question
 
should not have been highlighted on the LR drawing showing them within the scope of license
 
renewal and subject to an AMR and that the components in question have been included within
 
the scope of license renewal but are active components and therefore excluded from being
 
subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-21 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) but are active and therefore not subject to an AMR under
 
CFR 54.21(a). The staff concludes that there is reasonable assurance that the components
 
correctly were included within the scope of license renewal and excluded from being subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.13-21 is resolved.
In RAI-2.3.3.B.13-22 dated November 17, 2004, the staff stated USAR Section 9A.3.1.2.5,"Detailed Fire Hazard Analysis by Building," includes descriptions of drains and smoke removal
 
for various buildings and also describes the floor drains provided to collect and remove fire
 
water detection and protection system water discharge. This section states that drains are
 
designed for sufficient capacity for this purpose. The applicant was asked whether drainage of
 
such capacity was included within the scope of license renewal and subject to an AMR.
In its response by letter dated December 17, 2004, the applicant stated that floor drains are included in the floor and equipment drains system, which is within the scope of license renewal, for performing an NSR functional support intended function and are subject to an AMR. The
 
applicant further stated that the scoping and screening LRA table for the floor and equipment
 
drains system identifies these components and that the AMR table describes their
 
environments.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-22 acceptable because it adequately explained that the floor and equipment drains of sufficient capacity to
 
provide drainage from a discharge of the fire detection and protection system are within the scope of license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a).
 
Therefore, the staff's concern described in RAI 2.3.3.B.13-22 is resolved.
In RAI 2.3.3.B.13-23 dated November 17, 2004, the staff stated that drawing LR-43C-0 depicts a portion of the dry pipe sprinkler system for the reactor building railroad access bay as being
 
excluded from the scope of license renewal and requiring an AMR. The applicant was asked to
 
explain the apparent exclusion of this portion of the fire detection and protection system from
 
requiring an AMR.
In its response by letter dated December 17, 2004, the applicant stated that drawing LR-43C-0 is correct and properly shows the components in question excluded from the scope of license renewal and from requiring an AMR. The dry-pipe sp rinkler system in the railroad access bay is not credited to meet the requirements of 10 CFR 50.48 and therefore not within the scope of
 
license renewal because it has no license renewal intended functions. The dry-pipe sprinkler
 
system in question is depicted correctly on it s LR drawing and is not subject to an AMR.
2-181 In evaluating this response the staff found it incomplete and that review of LRA Section 2.3.3.B.13 could not be completed. Although it explains that the dry-pipe sprinkler
 
system in question is not credited to meet the requirements of 10 CFR 50.48 the staff found this
 
explanation contrary to the USAR, which includes the original NMP2 fire protection SER as
 
CLB. The NMP2 USAR includes a description of this sprinkler system. The staff held a
 
telephone conference with the applicant on January 25, 2005, to discuss information necessary
 
to resolve the concern in RAI 2.3.3.B.13-23. The product of the telephone conference was an
 
agreement by the applicant to transmit the required information by a follow-up letter.
By letter dated February 11, 2005, the applicant provided references in the USAR that describe the railroad access bay as within the standby gas treatment building. Further, USAR
 
Table 9A.3-3 notes that there is no SR equipment in the railroad access bay. The USAR states
 
that the only SR equipment in the standby gas treatment building is the standby gas treatment system units. These units are located in the st andby gas treatment system rooms, which are separated from the railroad access bay by 3-hour fire walls and floors. Additionally, the USAR states that the safe shutdown analysis summarized in USAR Section 9B.8 does not identify any
 
equipment located in the railroad access bay (Fire Area 4, Zone 242 NW) required for safe
 
shutdown of the plant. Thus, the applicant stated that the dry-pipe sprinkler system in the
 
railroad access bay does not perform or support any fire protection intended functions.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-23 including the information in the teleconference and letter dated February 11, 2005, acceptable because it
 
adequately provided the CLB references that eliminate the dry-pipe sprinkler system in the
 
railroad access bay from compliance with 10 CFR 50.48. Further, this elimination conforms to
 
LRA Section 2.1.4.3.1, "Fire Protection (FP)," which describes the scoping criteria to determine
 
whether systems and structures require inclusion within scope of license renewal under
 
10 CFR 54.4(a)(3). Therefore, the staff's concern described in RAI 2.3.3.B.13-23 is resolved.
In RAI 2.3.3.B.13-24 dated November 17, 2004, the staff stated that USAR 9.5.1.2.14 describes structural steel fire protection coating but that it was not clear from review of the LRA that the
 
fire protection coatings for structural steel and steel embedded in fire barriers are included
 
within the scope of license renewal and subject to an AMR. The applicant was asked to identify
 
where in the LRA the fire protection coating for structural steel is evaluated or to explain its
 
exclusion.
In its response by letter dated December 17, 2004, the applicant stated that the structural steel fire protection coatings are within the scope of license renewal and subject to an AMR. They are
 
included in the scoping and screening table for the fire stops and seals commodity system of
 
the LRA represented by the component type "Fire Wrap in Air." Further, the applicant explained
 
that their aging management is described in t he AMR table for this commodity system.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-24 acceptable because it adequately explained that fire protection coatings for structural steel are within the
 
scope of license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a).
 
Therefore, the staff's concern described in RAI 2.3.3.B.13-24 is resolved.
In RAI 2.3.3.B.13-25 dated November 17, 2005, the staff stated that USAR 9.5.1.2.16 describes criteria for fire resistance of interior finishes but that it was not clear from review of the LRA that
 
interior finishes are included within the scope of license renewal. The applicant was asked to 2-182 confirm that interior finishes are within the scope of license renewal and subject to an AMR or to explain their exclusion.
In its response by letter dated December 17, 2004, the applicant explained that the USAR states that noncombustible and fire-resistive building and interior finish materials are used
 
wherever practical throughout the plant, particularly in structures containing safety-related
 
systems and components. The applicant stated that the interior finishes, which consist of paint
 
and floor coverings, serve no intended function and are not in scope for license renewal, and
 
that the materials used to seal structural gaps and joints that have an intended function for fire
 
protection can be found in the LRA Section 2.4.C.2, "Fire Stops and Seals."
In evaluating this response the staff found it incomplete and that review of original LRA Section 2.3.3.B.13 could not be completed. Although it explains that the interior finishes in
 
question are not credited with meeting the requirements of 10 CFR 50.48 the staff found this
 
explanation contrary to the USAR, which includes the original NMP2 fire protection SE as CLB.
 
The USAR includes a description of the fire resistance of interior finishes. The staff held a
 
telephone conference with the applicant on January 25, 2005, to discuss information necessary
 
to resolve the concern in RAI 2.3.3.B.13-25. The product of the teleconference was an
 
agreement by the applicant to transmit the required information by a follow-up letter.
By letter dated February 11, 2005, the applicant provided references in the USAR that describe the use and characteristics of interior finishes required for building construction. USAR
 
Section 9.5.1.2.16 provides the required flame spread and smoke and fuel contribution rating
 
applicable to structures containing SR system s and components. Further, USAR Section 9.5.1.4 satisfactorily evaluates the requirements of interior finishes against the basis for the original
 
NMP2 fire protection SE and determines that they are in compliance. Additionally, the USAR
 
and the SE do not describe finish materials as performing a fire barrier or fire proofing function.
 
Thus, interior finish materials do not perform or support any fire protection intended functions.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-25, including the information in the teleconference and letter dated February 11, 2005, acceptable because it
 
adequately provided the CLB references stating the use and characteristics of interior finishes
 
required for building construction containing SR systems and components. The USAR and the
 
staff SE do not describe finish materials as performing a fire barrier or fire proofing function.
 
Thus, interior finish materials do not perform or support any fire protection intended functions.
 
Further, this finding conforms to the original LRA Section 2.1.4.3.1, which describes the scoping
 
criteria to determine whether systems and structures require inclusion within scope of license
 
renewal under 10 CFR 54.4(a)(3). Therefore, the staff's concern described in RAI 2.3.3.B.13-25
 
is resolved.
In RAI 2.3.3.B.13-26 dated November 17, 2004, the staff stated that the original LRA Section 2.4.B does not include the condensate storage tank structure and the normal
 
switchgear building as structures within the scope of license renewal. These structures are
 
found in the USAR Appendix 9A as the fire protection licensing basis and thus should be
 
considered within the scope of license renewal. Because these structures support fire protection
 
intended functions, the applicant was asked to explain their apparent exclusion from requiring
 
an AMR.
2-183 In its response by letter dated December 17, 2004, the applicant explained that the normal switchgear building and the condensate storage building are located in the protected area and
 
considered to be nonessential yard structures. The applicant explained further that these
 
structures do not meet any of the three criteria of 10 CFR 54.4; that they contain no SR
 
equipment, equipment required for safe plant shutdown, or radioactive material; that fire
 
protection equipment in these structures is for asset protection only; and that neither of these
 
buildings is credited for 10 CFR 50.48 fire protection.
In evaluating this response the staff found it incomplete and that review of LRA Section 2.3.3.B.13 could not be completed. Although it explained that the normal switchgear
 
building and the condensate storage building are not credited to meet the requirements of
 
10 CFR 50.48, the staff found this explanation contrary to the USAR, which includes the original
 
NMP2 fire protection SER as CLB. The staff held a teleconference with the applicant on
 
January 25, 2005, to discuss information necessary to resolve the concern in RAI 2.3.3.B.13-26.
 
The result of the telephone conference was an agreement by the applicant to transmit the
 
required information by a follow-up letter.
By letter dated February 11, 2005, the applicant provided references in the USAR that describe the attributes of both the condensate storage facility and the normal switchgear building. The
 
condensate storage facility is shown in USAR Section 9.2.6.1 to include the condensate storage
 
tanks, condensate storage tank building, and access way to the turbine building. The USAR
 
states that condensate storage system is not required to effect or support safe shutdown of the
 
reactor. USAR Section 9A.3.1.2.5.8 describes the normal switchgear building NSR switchgear
 
and ventilation systems as not required to effect safe shutdown of the reactor. Further, the
 
applicant explained that neither the condensate storage facility nor the normal switchgear
 
building has any intended functions and have been excluded from the scope of license renewal
 
under 10 CFR 54.4.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-26, including the information in the teleconference and letter dated February 11, 2005, acceptable because it
 
adequately provided the CLB references stating that the condensate storage facility and the
 
normal switchgear building do not have intended functions under 10 CFR 54.4 and have been
 
correctly excluded from the scope of license renewal. Further, this exclusion conforms to LRA Section 2.1.4.3.1, which describes the scoping criteria to determine whether systems and
 
structures require inclusion within scope of license renewal under 10 CFR 54.4(a)(3). Therefore, the staff's concern described in RAI 2.3.3.B.13-26 is resolved.
In RAI 2.3.3.B.13-27, dated November 17, 2004, the staff stated that USAR Section 9A.3.6.2.6 requires at least 350 gallons of fuel in the fire pump diesel fuel oil storage tank. Drawing
 
LR-43A-0 shows air tubing and other components supplying the level indicating instrumentation
 
for the fuel oil storage tank excluded from the scope of license renewal and requiring an AMR.
 
Therefore, the staff requested that the applicant explain the apparent exclusion of these
 
components from the scope of license renewal and from requiring an AMR.
In its response by letter dated December 17, 2004, the applicant explained that the LR drawing identifies the diesel fire pump fuel storage tank, which has a capacity of 650 gallons, as subject
 
to an AMR and that lines running from the tank to the fuel storage tank level transmitter are also
 
within the scope of license renewal and subject to an AMR. However, the fuel storage tank level 2-184 indicator and the level switch in question are not subject to an AMR because they are active components.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.13-27 acceptable because it adequately explained that level instrumentation in question for the diesel fire pump
 
fuel storage tank is within the scope of license renewal under 10 CFR 54.4(a) but are active
 
components and are therefore not subject to an AMR under 10 CFR 54.21(a). Therefore, the
 
staff's concern described in RAI 2.3.3.B.13-27 is resolved.
2.3B.3.13.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
fire detection and protection system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the fire detection and protection system components that
 
are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.14  NMP2 Floor and Equipment Drains System 2.3B.3.14.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.14, the applicant described the floor and equipment drains system. The floor and equipment drains system collects, hol ds, monitors, and discharges drainage from floor and equipment drain subsystems from various buildings/areas and provides for the proper
 
handling and disposal of radioactive and nonradioactive effluents. The floor and equipment
 
drains system consists of the drywell and reactor building equipment drains/floor drains, the
 
standby diesel generator building floor and equipment drains, the miscellaneous floor and
 
equipment drains, the radwaste building floor and equipment drains, the auxiliary service building floor and equipment drains, the turbine building equipment and floor drains, and the
 
turbine plant miscellaneous drains subsystems. Floor and equipment drain systems are
 
designed to prevent contamination of the storm drain system with effluent from sumps
 
containing radioactive or potentially radioactive drainage. The floor and equipment drain
 
systems serving buildings that house SR equipment have sufficient capacity to prevent excessive drain buildup that could affect the operability of the equipment. Each equipment and
 
floor drain sump receiving radioactive influent is lined with either stainless steel or fiberglass to
 
prevent migration of its contents. Flow from floor and equipment drains that has no potential for
 
radioactive contamination is discharged to the storm drainage system.
The floor and equipment drains system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the floor and equipment
 
drains system could potentially prevent the sati sfactory accomplishment of an SR function. In addition, the floor and equipment drains system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
2-185
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* converts liquid into spray
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.3.B.14-1, the applicant identified the following floor and equipment drains system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* drain tank
* floor drains
* flow elements
* piping and fittings
* pumps
* orifices
* spray nozzle
* strainers
* valves 2.3B.3.14.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.14 and USAR Section 9.3.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.14 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.B.14-1 dated November 19, 2004, the staff stated that LR drawings LR-63C, LR-63D, LR-63E, and LR-66B do not show in-scope flagging as depicted in the typical boundary flagging legend on each drawing. Both red-colored and black-colored piping and fittings are
 
shown beyond the license renewal floor and equipment drains' blue flagging on the drawings.
 
Therefore, the staff requested that the applicant explain why the black-colored piping and 2-186 fittings are shown beyond the license renewal blue flagging. The staff also requested that the applicant discuss if the black-colored piping and fittings are within scope of license renewal
 
under 10 CFR 54.4(a)(2), and if not, justify how their failure would not affect the pressure
 
boundary function of the in-scope piping with which this piping connects.
In its response by letter dated December 22, 2004, the applicant stated:
The AMR boundary flags were purposely drawn this way so as not to obscure the depiction of the floor on the drawings. In all cases, the AMR boundary is correctly
 
shown by the components highlighted in red. NSR components of this system
 
containing liquid in the Auxiliary Service Building, Control Room Building, Diesel
 
Generator Building, Main Stack, Primary Containment Structure, Radwaste
 
Building, Reactor Building (secondary containment), Screenwell Building, and
 
Turbine Building are in-scope and subject to an AMR per criterion
 
10 CFR 54.4(a)(2). Per the convention adopted for the LR drawings, components
 
in-scope for LR and subject to an AMR for criterion (a)(2) only are not identified
 
in red on the LR drawings.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.14-1 acceptable because it adequately explained that the AMR boundary flags were purposely drawn as shown
 
on the subject LR drawings so as not to obscure the depiction of the individual floor levels on
 
the drawings. In addition the applicant stated that NSR components of the floor and equipment
 
drains system containing liquid in the auxiliary service building, control room building, diesel generator building, main stack, primary containment structure, radwaste building, reactor
 
building (secondary containment), screenwell building, and turbine building are within the scope
 
of license renewal, subject to an AMR, and are shown therefore only in black on the drawings
 
instead of in red. Therefore, the staff's concern described in RAI 2.3.3.B.14-1 is resolved.
In RAI 2.3.3.B.14-2 dated November 19, 2004, the staff requested that the applicant clarify information given on drawing LR-67A concer ning SSCs in scope of license renewal. The staff stated in the RAI that drawing LR-67A shows the drywell equipment drain tank 1, associated
 
discharge piping and fittings, and downstream va lves and downstream equipment drain pumps in red and within blue flagging boundaries, indicating that these components are in scope for
 
license renewal per 10 CFR 54.4(a)(3). However, the inlet piping and fittings to the drywell
 
equipment drain tank 1 upstream valves and ups tream drywell equipment drain cooler are shown in black, indicating these components are functionally outside the scope of license
 
renewal. The staff also requested that the applicant identify the intended function of the portion
 
of the system beyond the drywell equipment drain tank 1 that satisfies 10 CFR 54.4(a)(3) and
 
explain how the function is performed without reliance on the inlet piping to the tank to be
 
functional and within the scope of license renewal.
In its response by letter dated December 22, 2004, the applicant stated that, consistent with the description of equipment subject to an AMR in LRA Section 2.3.3.B.14, the identified liquid-filled
 
inlet piping and components are within the scope of licence renewal and subject to an AMR per
 
10 CFR 54.4(a)(2) because they are located in the reactor building in the vicinity of SR
 
components and, per the convention adopted for the LR drawings components within the scope
 
of license renewal and subject to an AMR for 10 CFR 54.4 (a)(2) only, are not to be identified in
 
red on the LR drawings.
2-187 In its ALRA dated July 14, 2005, the applicant provided the staff with a revised LR drawing which identifies all SSCs in scope of license renewal and subject to an AMR including those
 
subject under 10 CFR 54.4(a)(2).
Based on review of the information submitted in the ALRA the staff's concern described in RAI 2.3.3.B.14-2 is resolved.
2.3B.3.14.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
floor and equipment drains system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the floor and equi pment drains system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.15  NMP2 Generator Standby Lube Oil System 2.3B.3.15.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.15, the applicant described the generator standby lube oil system. The generator standby lube oil system is designed to lubricate the engine bearings, turbocharger, and other moving parts of the emergency diesel generators. Additionally, this system preheats
 
the oil, prelubricates the engine, warms the jacket water, cools the pistons, and keeps the inside
 
of the engine clean by preventing rust and corrosion. The generator standby lube oil system
 
also features a generator standby temperature system that preheats the lubricating oil and jacket water to enhance long-term engine reliability and first-try starting of the diesel engine.
 
When the engine starts the circulating oil pump stops and the main engine-driven oil pump
 
takes over. A thermostatic valve controls the oil temperature to the engine by regulating the flow
 
to the oil cooler.
The generator standby lube oil system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the generator standby lube oil system
 
performs functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* provides pressure retaining boundary In ALRA Table 2.3.3.B.15-1 the applicant identified the following generator standby lube oil system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* heat exchangers 2-188
* piping and fittings
* pumps
* orifices
* sight glasses
* valves 2.3B.3.15.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.15 and USAR Section 9.5.7 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.15 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.B.15-1 dated November 19, 2004, the staff stated that LR drawing 104E-0 shows several sight glasses not highlighted, indicating that they are not subject to an AMR. Sight
 
glasses are passive and long-lived components. Therefore, the staff requested that the
 
applicant clarify or justify the exclusion of this component from requiring an AMR under
 
10 CFR 54.21(a)(1).
In its response by letter dated December 22, 2004, the applicant stated that the sight glasses in question were excluded inadvertently from with in the scope of license renewal. They should have been identified as within the scope of license renewal and subject to an AMR, and
 
highlighted in red on the drawing LR-104E-0. In its response, the applicant provided revisions to
 
LRA Tables 2.3.3.B.15-1 and 3.3.3.B-15, and LRA Section 3.3.2.B.15 that included sight
 
glasses with the intended function of pressure boundary as within the scope of license renewal.
 
The applicant stated that the components connecting the sight glasses to the system piping are
 
included with the "Piping and Fittings" component type.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.15-1 acceptable because the it clarified that the sight gla sses had been excluded inadvertently from the scope of license renewal, stated that sight glasses on the LR drawing should be highlighted in red, and
 
provided the LRA revisions to include the components in question. Therefore, the staff's
 
concern described in RAI 2.3.3.B.15-1 is resolved.
In RAI 2.3.3.B.15-2 dated November 19, 2004, the staff stated that LR drawing 104E-0 shows the turbo lube oil pressure trip valves, PEV-18, for the Division I and II diesels and connecting
 
tubing as not subject to an AMR. It appears that failure of this component and its connecting
 
tubing could prevent its associated standby di esel generator from performing its intended 2-189 function. Therefore, the staff requested that the applicant describe the function of this component and its effects on the intended function for the standby diesel generator. Further, the
 
staff requested that the applicant include PEV-18 as a component requiring an AMR if found to
 
have an intended function.
In its response by letter dated December 22, 2004, the applicant stated that AMR boundary depiction shown on drawing LR-104E-0 for valve PEV-18 and its associated tubing components
 
is incorrect and does not show the components in question properly as within the scope of
 
license renewal and subject to an AMR. The applicant further explained that valve PEV-18 is the
 
tubocharger lube oil pressure trip valve and its function is to trip the diesel engine on low turbo
 
oil pressure; as such PEV-18 (similar to valve PEV-14) and connecting tubing as well as
 
2EGS*HV118A, -B, -C, and -D are within the scope of license renewal and subject to an AMR.
 
The applicant further stated that the LRA table already represents these components under the
 
component types "Valves" and "Piping and Fittings."
Based on its review the staff found the applicant's response to RAI 2.3.3.B.15-2 acceptable because it adequately explained that (1) the components in question are within the scope of
 
license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but
 
inadvertently were not highlighted on the LR drawing and (2) the valves and tubing are already
 
covered in the LRA tables. Therefore, the staff's concern described in RAI 2.3.3.B.15-2 is
 
resolved.In RAI 2.3.3.B.15-3 dated November 19, 2004, the staff stated that LR drawing 104E-0 shows three restricting orifices for the Division III diesel as subject to an AMR. LRA Table 2.3.3.B.15-1
 
includes the "Orifices" component type with a pressure boundary intended function. Restricting
 
orifices also have a flow restriction function (as defined in LRA Table 2.0-1) that has not been
 
identified in the LRA table. Therefore, the staff requested that the applicant confirm that the loss
 
of flow restriction is not an intended function for restricting orifices in the generator lube oil
 
system requiring an AMR.
In its response by letter dated December 22, 2004, the applicant stated that failure of the flow restriction function of the orifices in question w ould not prevent the system from performing its intended function. The applicant further stated that "pressure boundary" is the only intended
 
function credited for these components as identified in the LRA Table 2.3.3.B.15-1.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.15-3 acceptable because it adequately explained that the components in question perform only a pressure
 
boundary function and that the loss of the flow restriction function would not prevent the system
 
from performing its intended function. Therefore, the staff's concern described in
 
RAI 2.3.3.B.15-3 is resolved.
In RAI 2.3.3.B.15-4 dated November 19, 2004, the staff stated that drawing LR-104E-0 shows Y-strainers for the Division III diesel generator as subject to an AMR. LRA Table 2.3.3.B.15-1
 
includes the "Filters/Strainers" component type with an intended function of pressure boundary.
 
Y-strainers also have a filtration function that has not been identified in the LRA table.
 
Therefore, the staff requested that the applicant confirm that the loss of filtration is not an
 
intended function for Y-strainers in the generator lube oil system requiring an AMR.
2-190 In its response by letter dated December 22, 2004, the applicant stated that the filtration function of the Y-strainers is to establish an "initial condition" for the generator lube oil system
 
and that the failure of this function would not prevent the system from performing its intended function. The applicant further stated that pressure boundary is the only intended function
 
credited for these components as identified in the LRA Table 2.3.3.B.15-1.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.15-4 acceptable because it adequately explained that the components in question perform only a pressure
 
boundary function and that the loss of the filtration function would not prevent the system from
 
performing its intended function. Therefore, the staff's concern described in RAI 2.3.3.B.15-4 is
 
resolved.In RAI 2.3.3.B.15-5 dated November 19, 2004, the staff stated that USAR Section 9.5.7 states that each standby diesel generator has an independent lubrication system to lubricate engine
 
bearings and other moving parts. LR drawing 104E-0 shows a line labeled "To Engine Bearings" at location C8 for the Division I and II diesel generators as not requiring an AMR. This line
 
appears to support the intended function for the generator standby lube oil system. Therefore, the staff requested that the applicant explain why this line is not subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that drawing LR-104E-0 is incorrect. The lubrication to the engine bearing is within the scope of license renewal, subject
 
to an AMR, and included in LRA Table 2.3.3.B.15-1 under the "Piping and Fittings" component
 
type and as such should be highlighted in red on the drawing.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.15-5 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance
 
that the components were included correctly within the scope of license renewal and subject to
 
an AMR, as represented by the "Piping and Fittings" component type in LRA Table 2.3.3.B.15-1.
 
Therefore, the staff's concern described in RAI 2.3.3.B.15-5 is resolved.
2.3B.3.15.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
generator standby lube oil system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the generator standby lube oil system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.16  NMP2 Glycol Heating System (Removed)
In ALRA Section 2.3.3.B.16, the applicant stated that the glycol heating system has been removed from the scope of license renewal since it has been determined that it does not meet
 
any of the criteria of 10 CFR 54.4. The original LRA included this system within the scope of 2-191 license renewal in accordance with 10 CFR 54.4(a)(2). However, based upon the applicant's detailed explanation that this system is not credi ted for mitigation of any CLB event, this system does not contain any SR/NSR interfaces, nor does this system introduce any spatial interactions with SR SSCs, the staff agrees with the applicant that the glycol heating system is not within the
 
scope of license renewal.2.3B.3.17  NMP2 Hot Water Heating System 2.3B.3.17.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.17, the applicant described the hot water heating system. The hot water heating system functions with the glycol heating system to heat outdoor makeup air used
 
for ventilation. Hot water is generated from steam and circulated through glycol heat
 
exchangers. The hot water heating system is equipped with piping connections to allow this
 
system to be connected to a temporary hot water heating plant. This is only used if the hot water
 
heating system is not available and glycol heat ing in the RB is needed. The system is closed loop. Depending upon the operating mode, electric bo iler, auxiliary steam, or extraction steam is supplied to the shell side of both the building heating auxiliary heat exchangers and the
 
intermediate heat exchangers.
The failure of NSR SSCs in the hot water heating system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.17-1 the applicant identified the following hot water heating system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* valves 2.3B.3.17.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.17 and USAR Section 9.4.12 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-192 The staff's review of LRA Section 2.3.3.B.17 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.B.17-1 dated November 19, 2004, the staff requested that the applicant provide information to describe the interface between the reactor water and the hot water system that
 
precludes the interface from being a pressure boundary. The staff stated that the system
 
description section of LRA Section 2.3.3.B.17 indicates that reactor water may be supplied to
 
the shell side of the building heating auxiliary heat exchangers and the intermediate heat
 
exchangers. No LR drawings were provided for this system. LRA Table 2.3.3.B.17 indicates that NSR piping, fittings, and equipment with the intended function of preventing failure from
 
affecting safety-related equipment are subject to an AMR.
The applicant stated in the response by letter dated December 22, 2004, that the description in LRA Section 2.3.3.B.17 is incorrect, that reactor water does not interface with the hot water
 
heating system, and that LRA Section 2.3.3.B.17 will be revised to remove "reactor water" and
 
replace it with "auxiliary steam." In its ALRA dated July 14, 2005, the applicant provided the staff with a revised LRA system description and LR drawing which identify SSCs within the scope of license renewal and subject
 
to an AMR under 10 CFR 54.4. The applicant also provided clarification on the component
 
groups included in LRA Table 2.3.3.B.17-1 to address the concern in RAI 2.3.3.B.17-1.
 
Therefore, the staff's concern described in RAI 2.3.3.B17-1 is resolved.
In RAI 2.3.3.B.17-2 dated November 19, 2004, the staff stated that the system description section of LRA Section 2.3.3.B.17 states that components subject to an AMR include the NSR
 
piping, fittings, and equipment containing liquid in the control room building, reactor building (secondary containment), radwaste building, screenwell building, standby gas treatment
 
building, and turbine building. No LR drawings were provided for this system. Therefore, the
 
staff requested that the applicant provide information that describes the boundaries of this
 
system and confirms that there are no other components subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated, "Consistent with LR drawing convention, marked-up LR drawings we re not provided for systems where the only system intended function was to meet the 10 CFR 54.4(a)(2) criterion." The applicant further
 
stated that the components subject to an AMR for this system include the NSR piping, fittings, and equipment containing liquid or steam physica lly located in the control room building, radwaste building, reactor containment (secondary containment), screenwell building, standby
 
gas treatment building, and turbine building. The applicant also referred to the diagram provided
 
with its response to RAI 2.3.3.B.16-1 and stated that the system description from LRA
 
Section 2.3.3.B.17 in conjunction with the diagram provides an adequate description of the
 
components that are subject to an AMR.
In evaluating the applicant's response the staff found it incomplete and that review of LRA Section 2.3.3.B.17 could not be completed because the applicant did not describe the SR
 
components in the radwaste building with which hot water heating system components can
 
interact. The staff held a teleconference with the applicant on January 27, 2005, to discuss
 
information necessary to resolve the concern in RAI 2.3.3.B.17-2. The result of this 2-193 teleconference was an agreement by the applicant to transmit the required information in a follow-up letter.
In its follow-up response dated January 31, 2005, the applicant stated that the methodology employed for determining those NSR systems and components in the radwaste building within the scope of license renewal was based on the building in which the system/component was
 
located, that this approach is conservative in that it brings into scope many more components
 
than would be required if detailed walkdowns were performed, and that as such NMPNS did not
 
specifically identify the SR components with which the hot water heating system could interact
 
because the entire system within the radwaste building is subject to an AMR under
 
10 CFR 54.21(a).
Prior to the issuing of its ALRA, on July 14, 2005, the applicant performed a new scoping of the system, using the methdology from ALRA Section 2.1. In its ALRA, the applicant stated that the
 
components subject to AMR for this system in clude the Hot water heating system NSR piping, fittings, and valves in the reactor building that are in the vicinity of the liquid poison tanks. The
 
remaining portions of this system are not credited for the mitigation of CLB events, do not
 
contain any SR/NSR interfaces, and are not located in the vicinity of SR SSCs. Therefore, those
 
portions are not within the scope of license renewal.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.17-2, acceptable because it adequately explained what NSR piping, fittings, and equipment is subject to an AMR
 
because of the possibility of spatial interaction with SR components. Therefore, the staff's
 
concern described in RAI 2.3.3.B.17-2 is resolved.
2.3B.3.17.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
hot water heating system components that are within the scope of license renewal, as required
 
by 10 CFR 54.4(a), and the hot water heating system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.18  NMP2 Makeup Water System 2.3B.3.18.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.18, the applicant described the makeup water system. The makeup water system is designed to provide demineralized makeup water for the TB closed loop cooling
 
water system and the RB closed loop cooling water system. The makeup water system
 
produces demineralized water by removing dissolved and suspended solids from city water
 
using a portable demineralizer. The makeup water system also stores and distributes
 
demineralized water from the makeup water treat ment system. The system consists of the makeup water treatment system and the makeup water storage and transfer system.
2-194 Additionally, the makeup water system meets plant requirements for demineralized water, including the suppression pool and the spent fuel pool.
The failure of NSR SSCs in the makeup water system could potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.18-1 the applicant identified the following makeup water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* valves 2.3B.3.18.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.18 and the USAR Section 1.2.10.9 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.18.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the makeup water system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the makeup water system components that
 
are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.19  NMP2 Neutron Monitoring System 2.3B.3.19.1  Summary of Technical Information in the Amended Application 2-195 In ALRA Section 2.3.3.B.19, the applicant described the neutron monitoring system. The neutron monitoring system is designed to provide neutron flux level monitoring of the reactor in three separate ranges, source range monitoring, intermediate range monitoring, and power
 
range monitoring. It is used to monitor and aid the operator in controlling the reactor from
 
startup through full power, inputs to the reactor manual control system (not within scope of
 
license renewal) to initiate rod blocks if preset flux limits are exceeded, and it inputs signals to the reactor protection system to in itiate a scram if limits are exceeded.
The neutron monitoring system has five subsys tems. The source range monitoring subsystem measures the flux from startup through critic ality. The intermediate range monitoring subsystem overlaps the source range monitoring subsystem and extends well into the power range. The
 
power range is monitored by detectors that make up the local power range monitor subsystem.
 
The average power range monitor subsystem is composed of core-wide sets of local power
 
range monitor detectors that are averaged to provide a core average neutron flux. The traversing in-core probe subsystem provides a means for calibrating the local power range
 
monitor subsystem.
The neutron monitoring system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the neutron monitoring system performs
 
functions that support fire protection, EQ, ATWS, and SBO.
The intended function within the scope of license renewal is to provide pressure retaining boundary.In ALRA Table 2.3.3.B.19-1, the applicant identified the following neutron monitoring system component types that are within the scope of license renewal and subject to an AMR:
* bellows
* bolting
* piping and fittings
* valves 2.3B.3.19.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.19 and the USAR using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with 10 CFR 54.21(a)(1).
2-196 2.3B.3.19.3  Conclusion The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the neutron monitoring system components that are within the scope
 
of license renewal, as required by 10 CFR 54.4(a), and the neutron monitoring system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.20  NMP2 Primary Containment Purge System 2.3B.3.20.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.20, the applicant described the primary containment purge system.
The primary containment purge system is desi gned to inert the primary containment with nitrogen, and to limit oxygen and hydrogen concentrations in the primary containment and
 
ensure a combustible atmosphere does not occur following a LOCA. The primary containment
 
purge system is also designed to de-inert and v entilate the primary containment during plant shutdown for the purpose of drywell entry. The pr imary containment purge system operates as a subsystem of the reactor building HVAC system. Inerting the primary containment is
 
accomplished by feed and bleed. To inert, nitrogen gas from the nitrogen system is fed into the
 
drywell or suppression chamber. Air is ex hausted into and processed by the standby gas treatment system before it is discharged through the main stack.
The primary containment purge system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the primary containment
 
purge system could potentially prevent the satisf actory accomplishment of an SR function. In addition, the primary containment purge syst em performs functions that support EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.20-1, the applicant identified the following primary containment purge system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* debris screens
* flow element
* piping and fittings
* valves 2-197 2.3B.3.20.2  Staff Evaluation The staff reviewed ALRA Section 2.3.3.B.20 and the USAR Section 9.4.2.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.20.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the primary containment purge system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the primary containment purge
 
system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.21  NMP2 Process Sampling System 2.3B.3.21.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.21, the applicant described the process sampling system. The process sampling system is designed to monitor sele cted plant process streams and provide grab sample points to back up the continuous analyzers and allow laboratory analysis of other
 
process streams. The process sampling system is a water chemistry analysis system involving multipoint sample panels and grab sample sinks in the RB, TB, and radwaste building (RWB).
 
Miscellaneous sample points are provided on individual process systems where needed.
The process sampling system consists of the following subsystems: post-accident sampling system, RWB sampling system, reactor plant sampling system, and turbine plant sampling system. The post-accident sampling system is designed to obtain representative liquid and gas samples from within the primary containment for radiological analysis in association with the
 
possible consequences of a LOCA. The radwaste building sampling system is used for
 
obtaining grab samples for monitoring the radioactive liquid waste management and radwaste
 
auxiliary steam system drain coolers. The reacto r plant sampling system monitors the quality of reactor coolant and various reactor plant fluids. The turbine plant sampling system monitors the
 
quality of reactor grade water flowing in the TB.
The failure of NSR SSCs in the process sampling system could potentially prevent the satisfactory accomplishment of an SR function.
2-198 The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products In ALRA Table 2.3.3.B.21-1, the applicant identified the following process sampling system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow indicators
* heat exchangers
* piping and fittings
* valves 2.3B.3.21.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.21 and USAR Sections 1.2.10.7, 1.10.II.B.3, and 9.3.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its
 
review in accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.21 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.B.21-1 dated November 19, 2004, the staff requested that the applicant clarify drawing inconsistencies that the staff encountered in its review. The staff stated that LR drawing
 
LRA-31 sheet D (location G7) and sheet E (location D8) show valves 2-RHS-SOV-35A and
 
2-RHS-SOV-35B highlighted in red and within the residual heat removal system AMR boundary
 
flags. However, LR drawing LR-17 sheet G (locat ions I1, K1) does not show these valves within the AMR boundary of the residual heat removal system. The staff requested that the applicant
 
confirm that valves 2-RHS-SOV-35A and 2-RHS-SOV-35B are within the scope of license
 
renewal and subject to an AMR or explain the discrepancy between the LR drawings.
In its response by letter dated December 22, 2004, the applicant stated that valves 2RHS*SOV35A and 2RHS*SOV35B are SR within the scope of license renewal and subject to
 
an AMR, that drawing LR-17G for these valves and their associated piping should be
 
highlighted in red consistent with the depiction of the respective valves on drawings LR-31D and
 
LR-31E, and that at continuation locations I1 and K1 on drawing LR-17G the continuation flags 2-199 should be marked as "LR-31D" and "LR-31E" as appropriate and include LR continuation flags showing "LR-RHS" in both directions.
In its ALRA dated July 14, 2005, the applicant provided the staff with revised LR drawings correcting the inconsistencies and accurately depicting all the components subject to an AMR, including those subject under 10 CFR 54.4(a)(2). Therefore, the staff's concern described in
 
RAI 2.3.3.B.21-1 is resolved.
2.3B.3.21.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
process sampling system components that are within the scope of license renewal, as required
 
by 10 CFR 54.4(a), and the process sampling sy stem components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.22  NMP2 Radiation Monitoring System 2.3B.3.22.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.22, the applicant described the radiation monitoring system. The radiation monitoring system is designed to init iate appropriate manual or automatic protective action to limit the potential release of radioactive materials from the reactor vessel, primary and
 
secondary containment, and fuel storage areas if predetermined radiation levels are exceeded
 
in major process/effluent streams and to provide main control room personnel with radiation
 
level indication throughout the course of an accident.
The radiation monitoring system consists of a computer-based digital radiation monitoring system, a computer-based gaseous effluent m onitoring system, and the main steam line radiation monitors. The digital radiation moni toring system measures, evaluates, and reports radioactivity in process streams and liquid effluents and annunciates and/or initiates an
 
automatic control function for abnormal system or plant operating conditions. The gaseous
 
effluent monitoring system measures, evaluates , and reports radioactivity in gaseous effluents.
It also provides annunciation if release levels approach limits specified in the offsite dose
 
calculation manual. The gaseous effluent monitoring system also provides real time noble gas isotopic analysis and continuous iodine and particulate sample collection for main stack, RWB, and RB vent releases. The main steam line radi ation monitoring system monitors the gamma radiation level exterior to the main steam lines. In the event of a gross release of fission
 
products from the core this monitoring syst em provides annunciation in the control room.
The radiation monitoring system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the radiation monitoring
 
system could potentially prevent the satisf actory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
2-200
* provides filtration
* provides pressure retaining boundary
* provides flow restriction In ALRA Table 2.3.3.B.22-1, the applicant identified the following radiation monitoring system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters
* flow elements
* piping and fittings
* pumps
* valves 2.3B.3.22.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.22 and USAR Sections 11.5.2 and 12.3.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.22 identified an area in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAI as discussed below.
In RAI 2.3.3.B.22-1 dated November 19, 2004, the staff stated that the applicant did not identify the radiation monitoring system components within the scope of license renewal under
 
I0 CFR 54.4(a)(1) and (2). Furthermore, an LR drawing for the NMP2 radiation monitoring
 
system was not provided to show the portions of this system containing components within the scope of license renewal. Therefore, the staff requested that the applicant identify the
 
components of the radiation monitoring system within the scope of license renewal under
 
10 CFR 54.4(a)(1) and (2) and justify the exclusion of these components from being subject to
 
an AMR under 10 CFR 54.21(a)(1).
In its response by letter dated December 22, 2004, the applicant stated that SR radiation monitors and their inclusive mechanical components are in-scope for LR and subject to an AMR
 
for a "Pressure Boundary" intended function that the subject components that perform the LR
 
intended function will be identified, and that AMR of those components will be performed. The
 
applicant stated that LRA revisions to incorporate the AMR results and any other associated
 
LRA changes would be submitted to the staff.
2-201 In its ALRA dated July 14, 2005, the applicant provided the staff with revised LR drawings accurately depicting all the components subject to an AMR, including those subject under
 
10 CFR 54.4(a)(2). The applicant also added ALRA Table 2.3.3.B.22-1 to provide a list of
 
component types requiring an AMR and their intended functions. Therefore, the staff's concern
 
described in RAI 2.3.3.B.22-1 is resolved.
2.3B.3.22.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
radiation monitoring system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the radiation m onitoring system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.23  NMP2 Reactor Building Closed Loop Cooling Water System 2.3B.3.23.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.23, the applicant described the reactor building closed loop cooling water system. The RBCLC water system is designed to remove heat from various reactor
 
auxiliary equipment located in the primary c ontainment, RB, and TB. The RBCLC water system is cooled by the service water system and makeup water is supplied from the makeup water
 
system. During normal plant operation the syst em provides an intermediate barrier between systems containing radioactive products and the se rvice water system, which precludes a direct release of radioactive products into the environment.
The RBCLC water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RBCLC water system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the RBCLC
 
water system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.23-1, the applicant identified the following RBCLC water system component types that are within the scope of license renewal and subject to an AMR:
2-202
* bolting
* flow element
* heat exchangers
* piping and fittings
* unit coolers
* valves 2.3B.3.23.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.23 and USAR Section 9.2.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.23.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the RBCLC water system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the RBCLC water system components that
 
are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.24  NMP2 Reactor Building HVAC System 2.3B.3.24.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.24, the applicant described the reactor building HVAC system. The reactor building HVAC system is designed to remove heat generated within the drywell and
 
maintain ambient temperature within design lim its, thus providing an environment that ensures optimum performance of equipment. Additionally, the reactor building HVAC system is an alternative system for venting the primary containment to the atmosphere if necessary.
The reactor building HVAC system consists of the following subsystems: drywell cooling, primary containment purge, and all other RB ar eas. The drywell cooling system conditions the air inside the drywell where unit coolers control drywell temperature and pressure for all other
 
reactor building areas subsystems. The supply v entilation air handling unit assembly consists of an air intake, prefilter, filter, heating coil, cooling coil, dampers, controls, and supply fans. The
 
system operates in both a normal operation mode and an emergency operation mode.
2-203 The reactor building HVAC system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the reactor building HVAC system performs
 
functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides rated fire barrier
* provides heat transfer
* provides pressure retaining boundary In ALRA Table 2.3.3.B.24-1, the applicant identified the following reactor building HVAC system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* ducting
* filters/strainers
* flow elements
* piping and fittings
* pumps
* radiation sample points
* unit coolers
* valves and dampers (includes fire dampers) 2.3B.3.24.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.24 and USAR Section 9.4.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.24.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the reactor building HVAC system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the reactor building HVAC system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-2042.3B.3.25  NMP2 Reactor Water Cleanup System 2.3B.3.25.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.25, the applicant described the RWCU system. The purpose of the RWCU system is to maintain high reactor water quality and remove excess reactor coolant from
 
the RPV during all modes of plant operation. High water quality is maintained to minimize the
 
fouling of heat transfer surfaces and limit impurities available for neutron activation. The RWCU
 
system provides the means to maintain water chemistry within the limits outlined in Regulatory Guide (RG) 1.56, Revision 1. The RWCU system recirculates a portion of reactor coolant
 
through a filter demineralizer to remove particulate and dissolved impurities from the reactor
 
coolant. It also removes excess coolant from the reactor system under controlled conditions.
 
The major components of the RWCU system are located outside the drywell.
The RWCU system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RWCU system could potentially prevent
 
the satisfactory accomplishment of an SR function. In addition, the RWCU system performs
 
functions that support fire protection, ATWS, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.3.B.25-1, the applicant identified the following RWCU system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filter/strainer
* flow elements
* heat exchanger
* piping and fittings
* orifices
* valves
* pumps 2.3B.3.25.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.25 and the USAR Section 5.4.8 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
2-205 In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.25 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.B.25-1 dated November 19, 2004, the staff stated that LR drawings LR-37A-1 and LR-37B-2 show components not highlighted indicating that they require no AMR. Therefore, the
 
staff requested that the applicant justify the exclusion of these components from within the
 
scope of license renewal and not subject to an AMR. The applicant's response by letter dated
 
December 22, 2004, has been incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the applicant provided the staff with a revised LRA Table 2.3.3.B.25-1 identifying components subject to an AMR and revised LR drawings which
 
identify SSCs within the scope of license renewal and subject to an AMR under 10 CFR 54.4.
 
Therefore, the staff's concern described in RAI 2.3.3.B.25-1 is resolved.
In RAI 2.3.3.B.25-2 dated November 19, 2004, the staff stated that the introduction to NMP2 USAR Table 3.9B-2 states that this table lists the major SR components in the plant. Item W and X identify the RWCU system pumps and the RWCU heat exchangers respectively as parts
 
of this table. However, neither of these components is highlighted on drawing LR-37B-0 as
 
within the scope of license renewal and subject to an AMR. Also the LRA Table 2.3.3.B.25-1
 
does not include the component type "Pumps or Heat Exchangers." The staff believes that
 
these components meet 10 CFR 54.4(a)(1) criteria and should require a 10 CFR 54.21(a)(1)
 
AMR. Therefore, the staff requested that the applicant justify the exclusion of these components
 
from within the scope of license renewal and AMR.
In its response by letter dated December 22, 2004, the applicant stated that NMP2 USAR Table 3.2-1 describes in additional detail the portions of the RWCU system that perform a safety
 
function and are therefore within the scope of license renewal for 10 CFR 54.4(a)(1) or (3).
 
According to the applicant, the RWCU system pumps and heat exchangers are not SR per
 
NMP2 USAR Table 3.2-1 or the NMP2 MEL and are not required for safe shutdown of the
 
reactor. The applicant indicated that consistent with 10 CFR 54.4(b) these components do not
 
support any system intended functions pursuant to 10 CFR 54.4(a)(1) or (3).
The applicant further clarified that the NSR liquid filled piping and components shown in black on drawing LR-37B-0 are in-scope for license renewal and subject to 10 CFR 54.4(a)(2) AMR
 
because all of these components are located in the reactor building in the vicinity of SR
 
components. However, these components are not highlighted on the LR drawing because they
 
are within the scope of license renewal and subject to an AMR for 10 CFR 54.4(a)(2) only.
In evaluating this response the staff found it incomplete and that review of LRA Section 2.3.3.B.25 could not be completed because (1) it does not explain why RWCU heat 2-206 exchangers and pumps are listed in NMP2 USAR Table 3.9B-2 as the major safety-related component in the plant if they are not safety-related and (2) USAR Table 3.2-1 classifies RWCU
 
heat exchangers and pumps as the American Society of Mechanical Engineers (ASME) Safety
 
Class 3 and differs from the applicant's response. The staff held a teleconference with the
 
applicant on January 27, 2005, to discuss information necessary to resolve the concern in
 
RAI 2.3.3.B.25-2. The result of the teleconference was an agreement by the applicant to
 
transmit the required information by a follow-up letter.
By letter dated February 11, 2005, the applicant acknowledged a discrepancy between USAR sections, in that the applicant has categorized the RWCU pump and heat exchangers as
 
nonsafety-related components for the purpose of license renewal, but these components also
 
are listed in NMP2 UFSAR Table as a major safety-related component and in the UFSAR
 
Table 3.2-1 as ASME safety class 3, which differs from the applicant's previous response to the
 
RAI. In the February 11, 2005, the applicant stated that NMPNS applied design criteria that
 
exceed those required for the RWCU component safety classifications. The USAR
 
Section 3.9B.3.1.14 states:
The RWCU pump and regenerative and non-regenerative heat exchangers are not part of a safety system and are not designed to Category I requirements.
The requirements of ASME Boiler and Pressure Vessel Code, Section III, Safety Class 3 components are used as guidelines in evaluating the RWCU system
 
pump and heat exchanger components. The loading conditions, stress criteria, and calculated and allowable stresses are summarized in Tables 3.9B-2w and
 
3.9B-2x.The applicant further stated in the February 11, 2005, letter, that (1) USAR Section 5.4.8 provides the description of the RWCU system and st ates that the portion of the system from the RPV to the outboard isolation valves is SR and the remainder of the system is NSR, and that
 
(2) the discrepancy between the USAR sections has been placed into the site CAP for
 
resolution. The applicant stated that it did not consider the resolution of this issueto be an
 
impact to license renewal since the components are in-scope under 10 CFR 54.4(a)(2) and
 
subject to an AMR.
Based on its review of the above applicant's explanation that the discrepancy between the USAR sections has been placed into the site CAP for resolution, and that the RWCU pump and
 
heat exchangers were evaluated under ASME Boiler and Pressure Vessel Code, Section III, Safety Class 3 guide lines, the staff found the applicant's response to RAI 2.3.3.B.25-2, including the information in the letter dated February 11, 2005, acceptable, because it
 
adequately explained that the USAR had a discrepancy that will be resolved and that the
 
components in question are within the scope of license renewal. Therefore, the staff's concern
 
described in RAI 2.3.3.B.25-2 is resolved.
2.3B.3.25.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition the staff performed a review
 
to determine whether any components that should be subject to an AMR had not been identified 2-207 by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant had adequately identified the RWCU
 
system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the RWCU system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).2.3B.3.26  NMP2 Seal Water System (Removed)
The NMP2 seal water system has been removed fr om the scope of license renewal since it has been determined that it does not meet any of the criteria of 10 CFR 54.4. The original LRA
 
included this system within the scope of license renewal under 10 CFR 54.4(a)(2). However, based upon detailed evaluations, this system is not credited for mitigation of any CLB event, does not contain any SR/NSR interfaces, nor introduce any spatial interactions with SR SSCs.
 
Therefore, the seal water system is not within the scope of license renewal.2.3B.3.27  NMP2 Service Water System 2.3B.3.27.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.27, the applicant described the service water system. The service water system is designed to provide a reliable supply of cooling water for essential components
 
and systems. The service water sy stem provides cooling water to the secondary sides of the RBCLC water system and TBCLC water system heat exchangers during normal plant operation
 
and planned outages. Service water is also supplied to the secondary side of the RHR system
 
heat exchangers during planned unit outages. In addition, the system is designed to provide
 
makeup water to the circulating water system and cooling water to miscellaneous nonessential
 
TB and RB components during normal plant operation. The service water system at is a
 
once-through system which utilizes raw lake water from Lake Ontario.
The service water system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the service water system could
 
potentially prevent the satisfactory accomplishment of an SR function. In addition, the service water system performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides filtration
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction 2-208 In ALRA Table 2.3.3.B.27-1, the applicant identified the following service water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow elements
* orifices
* piping and fittings
* pumps
* temperature elements
* valves 2.3B.3.27.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.27 and USAR Section 9.2.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.27 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.B.27-1 dated November 19, 2004, the staff stated that drawing LR-11 for the service water system shows a certain component within the AMR boundary of the service water system, an expansion joint or bellows. Similarl y, the same LR drawing shows two components that appear to be expansion joints or bellows connecting to the high pressure core spray diesel
 
generator cooler. The LRA table associated with the service water system does not list
 
expansion joints or bellows as a component subject to an AMR within the NMP2 service water
 
system. In addition a review of the AMR table a ssociated with the service water system did not identify expansion joints or bellows as a component type. The applicant was asked to confirm
 
that this component is included in the AMR of piping and fittings or explain the basis for omitting
 
these component types from LRA Table 2.3.3.B.27-1 and from requiring an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the components addressed in question are expansion joints in the suction lines for the service water pumps
 
P1D, B, F, and C respectively. These expansion joints are within the scope of license renewal
 
and are shown as components subject to an AMR under the component type "Piping and
 
Fittings" in the LRA tables for the NMP2 service water system.
Based on its review, the staff found the applicants response acceptable because it identifies the expansion joints in question and confirmed their inclusion within the scope of license renewal 2-209 and subject to an AMR. Therefore, the staff's concerns described in RAI 2.3.3.B.27-1 are resolved.In RAIs 2.3.3.B.27-2 through 2.3.3.B.27-4 dated November 19, 2004, the staff requested that the applicant clarify information given on such LR drawings as LR-11 sheet B, LR-11J-0, LR-43
 
sheet G, LR-11 sheet E concerning SSCs for NMP2 service water systems that are within the
 
scope of license renewal per 10 CFR 54.4(a). The applicant's response by letter dated
 
December 22, 2004, provided adequate information to the staff and the information has been
 
incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the applicant provided the staff with revised LR drawings which identify all SSCs within the scope of license renewal and subject to an AMR including those
 
under 10 CFR 54.4(a)(2). Based on review of the information submitted in the ALRA the staff's
 
concerns described in RAI 2.3.3.A.27-2 through 2.3.3.A.27-4 are resolved.
In RAI 2.3.3.B.27-5 dated November 19, 2004, the staff stated that drawing LR-11 shows two flow element root valves, V53B and V54B, and associated piping outside the scope of license
 
renewal and not subject to an AMR. Failure of these pipes could affect the integrity of the
 
service water system. Therefore, the staff requested that the applicant explain the basis for
 
excluding these components from being subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the root valves V53B and V54B and their associated piping highlighted in black are SR globe root valves.
 
Therefore, these valves and their associated piping back to flow element FE-161B should be
 
highlighted in red as within the scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response acceptable because the applicant concurred that the flow element root valves and associated piping are within the scope of
 
license renewal and subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.B.27-5 is resolved.
2.3B.3.27.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
service water system components that are with in the scope of license renewal, as required by 10 CFR 54.4(a), and the service water system components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3B.3.28  NMP2 Spent Fuel Pool Cooling and Cleanup System 2.3B.3.28.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.28, the applicant described the spent fuel pool cooling and cleanup system. The spent fuel pool cooling and cleanup system is designed to remove the decay heat 2-210 released from the spent fuel elements and maintain a specified fuel pool water temperature, water clarity, and water level. The spent fuel pool cooling and cleanup system is also designed
 
to provide cooling to the spent fuel pool, reactor cavity pool, and reactor internals during plant
 
refueling outages. The cooling section can operate independently from the cleanup section.
The spent fuel pool cooling and cleanup system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the spent fuel pool
 
cooling and cleanup system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the spent fuel pool cooling and cleanup system performs functions that
 
support fire protection.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.28-1, the applicant identified the following spent fuel pool cooling and cleanup system component types that are within the scope of license renewal and subject to an
 
AMR:
* bolting
* filters/strainers
* flow elements
* heat exchangers
* orifices
* piping and fittings
* pumps
* tanks
* valves 2.3B.3.28.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.28 and the USAR Section 9.1.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not 2-211 omitted any passive and long-lived components that should be 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.B.28 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.B.28-1 dated November 19, 2004, the staff stated that the spent fuel pool cooling and cleanup system is shown primarily on LR drawings LR-38A, -B, and -C. Because the cooling and cleanup systems operate independently of one another and the majority of the
 
cleanup system does not contain components subjec t to an AMR the drawings supplied by the applicant do not contain all of the detail the staff needs for complete review to understand the
 
configuration of the components requiring an AMR. This information is not depicted clearly in
 
the LR drawings supplied. The staff requested that the applicant supply figures from the NMP2
 
USAR for the spent fuel pool cooling and cleanup system and for drawing LR-38D-0.
In its response by letter dated December 22, 2004, the applicant stated that NMP2 USAR Figures 9.1-5a through 9.1-5d were enclosed. The applicant also clarified that the drawing
 
LR-38D-0 does not exist since there are on t hat drawing no components in-scope to meet the requirements of 10 CFR 54.4(a)(1) or (a)(3).
Based on its review, the staff found the applicant's response acceptable because the applicant provided the requested USAR figures and clarified that there is no drawing LR-38D-0.
 
Therefore, the staff's concern described in RAI 2.3.3.B.28-1 is resolved.
In RAI 2.3.3.B.28-2 dated November 19, 2004, the staff stated that there are spargers noted on LR drawings at the bottom of the spent fuel pool (LR-38B-0), the reactor refueling cavity (LR-38A-0), and the reactor internals storage pit (LR-38A-0) as subject to an AMR. The staff
 
asked the applicant to clarify whether these spargers are included in the component type
 
"Piping and Fittings" in the LRA Table 2.3.3.B.28-1 or indicate if they are included in the table
 
under any another component type.
In its response by letter dated December 22, 2004, the applicant stated that these spargers, also known as spray nozzles, are included with the component type "Piping and Fittings" in
 
Table 2.3.3.B.28-1.
Based on its review, the staff found the applicant's response acceptable because it stated that the spargers are included with the component type "Piping and Fittings" in the AMR tables for
 
this system. Therefore, the staff's concern described in RAI 2.3.3.B.28-2 is resolved.
In RAI 2.3.3.B.28-3 dated November 19, 2004, the staff stated that LRA Tables 2.3.3.B.28-1 and 3.3.2.B-27 list the component "Filter/Strainer" as subject to an AMR. In LR drawings for the
 
spent fuel pool cooling and cleanup system no filters or strainers were found. Therefore, the
 
staff requested that the applicant clarify whether there are any filters or strainers in the spent
 
fuel cooling and cleanup system subject to an AMR and, If not, that the applicant remove the
 
reference from the LRA tables.
2-212 In its response by letter dated December 22, 2004, the applicant stated that drawing LR-038A-0 identifies one of the strainers, STRT1B, in question, and drawing LR-038B-0 identifies the other, STRT1A. Both components are within the scope of license renewal and subject to an AMR.
 
Both components are included with the component type "Filters/Strainers" in LRA
 
Tables 2.3.3.B.28-1 and 3.3.2.B-27.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.28-3 acceptable because it adequately identified the strainers on the LR drawings. Therefore, the staff's concern
 
described in RAI 2.3.3.B.28-3 is resolved.
2.3B.3.28.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
spent fuel pool cooling and cleanup system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the spent fuel pool cooling and cleanup system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.29  NMP2 Standby Diesel Generator Fuel Oil System 2.3B.3.29.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.29, the applicant described the standby diesel generator fuel oil system. The standby diesel generator fuel oil system is designed to deliver sufficient fuel oil flow to the EDGs and provide fuel oil storage capacity for each diesel generator for seven days of
 
continuous diesel generator operation without interconnection to any other onsite fuel oil
 
system. The EDGs are equipped with a fuel oil day tank which has enough fuel for
 
approximately one hour of running time plus a margin of 10 percent at the highest allowed
 
gravity. The day tank is elevated above the EDG and k ept full of fuel oil from the fuel oil storage tank by the fuel oil transfer pumps. The elevated location of the tank provides adequate net
 
positive suction head to the engine-driven fuel pump of the diesel engine. Each storage tank is
 
filled from its own tank truck fill station located in the yard. Electric oil transfer pumps mounted
 
on top of each tank permit the transfer of fuel oil to the day tanks. One fuel oil transfer pump is
 
capable of supplying the maximum fuel demand of a standby diesel generator. Each pump
 
discharges through a strainer with an automatic shutoff in case of high differential pressure.
 
After passing through the strainer the fuel oil discharges into the day tank.
The standby diesel generator fuel oil system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the standby diesel
 
generator fuel oil system could potentially prev ent the satisfactory accomplishment of an SR function. In addition, the standby diesel generator fuel oil system performs functions that
 
support fire protection.
2-213 The intended functions within the scope of license renewal include the following:
* provides filtration
* provides heat transfer
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.29-1, the applicant identified the following standby diesel generator fuel oil system component types that are within t he scope of license renewal and subject to an AMR:
* bolting
* filters/strainers
* flow elements
* heat exchangers
* piping and fittings
* pumps
* tanks
* valves 2.3B.3.29.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.29 and USAR Section 9.5.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.29 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.B.29-1 dated November 19, 2004, the staff stated that on LR drawing LR-104F-0 orifices are shown to be within the scope of license renewal and subject to an AMR. However, "Orifice" is not included as a component type in LRA Table 2.3.3.B.29-1. LRA Table 2.0-1
 
identifies "Flow Restriction" as a component intended function applicable to an orifice. The staff
 
asked the applicant to clarify whether this component is included with another component type
 
within the scope of license renewal and subject to an AMR and, if not, to justify its exclusion
 
from the scope of license renewal and from being subject to an AMR or update the
 
corresponding table to include this component.
2-214 In its response by letter dated December 22, 2004, the applicant stated that flow orifices are included under the component type "Flow Element" in LRA Table 2.3.3.B.29-1. The applicant
 
also explained that not all orifices have an intended function of "Flow Restriction," which is an
 
intended function only if required for the system in which it is installed to meet an intended
 
functions for safe shutdown of the plant. Most orifices have a "Pressure Boundary" function
 
only.Based on its review, the staff found the applicant's response acceptable because it adequately explained that the flow orifices in question are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a). Further, the applicant stated
 
that the flow orifices are represented in t he LRA table by the component type flow element.
Therefore, the staff's concern described in RAI 2.3.3.B.29-1 is resolved.
In RAI 2.3.3.B.29-2 dated November 19, 2004, the staff stated that on LR drawing LR-103B-0, flexible hoses are shown within the scope of license renewal and subject to an AMR. However, flexible hose is not included as a component type in LRA Table 2.3.3.B.29-1 associated with the
 
standby diesel generator fuel oil system. Therefore, the staff requested that the applicant clarify
 
whether this component is included with another component type within the scope of license
 
renewal and subject to an AMR and, if not, to justify its exclusion from the scope of license
 
renewal and from being subject to an AMR or update the corresponding table to include this
 
component.
In its response by letter dated December 22, 2004, the applicant stated that the flexible hoses in question are stainless steel and included under the component type "Piping and Fittings" in the
 
LRA Table 2.3.3.B.29-1.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.29-2 acceptable because it adequately explained that the flexible hoses in question are within the scope of
 
license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a). Further, the applicant stated that the flexible hoses are represented in the LRA Table by the component
 
type "Piping and Fittings." Therefore, the staff's concern described in RAI 2.3.3.B.29-2 is
 
resolved.In RAI 2.3.3.B.29-3 dated November 19, 2004, the staff stated that NMP2 USAR Section 9.5.4 states that the standby diesel generator fuel oil storage and transfer system consists of six
 
electric motor-driven, vertical, turbine-type fuel oil transfer pumps. The pumps are mounted in
 
duplex sets on top of each fuel oil storage tank and each duplex set is connected in parallel to
 
its respective day tank to permit the transfer of fuel oil by the pumps. Drawing LR-104C-0 shows two of these pumps and drawing LR-104B-0 shows four within the scope of license renewal and
 
subject to an AMR. However, the LR drawings do not show the piping within the standby diesel
 
generator storage tanks connecting to these pumps as subject to an AMR. The staff believed
 
that this piece of piping should be within the scope of license renewal and subject to an AMR for
 
the standby diesel generator fuel oil storage tanks to perform their intended function to ensure
 
the transfer of fuel oil to the day tanks. Therefore, the staff requested that the applicant justify
 
the exclusion of this piece of piping from the scope of license renewal and from being subject to
 
an AMR.In its response by letter dated December 22, 2004, the applicant agreed with the staff that the suction piping inside the diesel fuel oil storage tanks is in-scope for license renewal and subject 2-215 to an AMR, that the piping is included with the component type "Piping and Fittings" in LRA Table 2.3.3.B.29-1, and that LR drawings LR-104B and LR-104C should show these piping
 
segments highlighted in red.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the piping in question is within the scope of license renewal and subject to an
 
AMR and included with the component type "Piping and Fittings." The staff concludes that there
 
is reasonable assurance that the components were included correctly within the scope of
 
license renewal and subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.B.29-3 is resolved.
In RAI 2.3.3.B.29-4 dated November 19, 2004, the staff stated that drawing LR-104B-0 shows piping within the standby diesel generator fuel oil storage and transfer system connecting to
 
nine level switches and drawing LR-104C-0 shows such piping connecting to four level switches
 
as not within the scope of license renewal or subject to an AMR. The staff believed that the level
 
switches are used to monitor the oil level in their associated day tanks and that the piping
 
connecting to these level switches should be within the scope of license renewal and subject to
 
an AMR. Therefore, the staff requested that the applicant justify the exclusion of this piping from
 
the scope of license renewal and from being subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the sensing lines up to the referenced level switches are within the scope of license renewal and subject to an AMR.
 
The components in question should have been highlighted on drawing LR-104B-0 showing
 
them within the scope of license renewal and are subject to an AMR but inadvertently were not
 
highlighted.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the components in question are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently were not
 
highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the
 
components were included correctly within the scope of license renewal and subject to an AMR.
 
Therefore, the staff's concern described in RAI 2.3.3.B.29-4 is resolved.
In RAI 2.3.3.B.29-5 dated November 19, 2004, the staff stated that on LR drawings LR-104B-0, LR-104C-0, and LR-104F-0 vents are shown to be within the scope of license renewal and
 
subject to an AMR. However, vents are not included as a component type in the LRA
 
Table 2.3.3.B.29-1. Therefore, the staff requested that the applicant clarify whether this
 
component is included with another component type within the scope of license renewal and
 
subject to an AMR and, if not, to justify its exclusion from the scope of license renewal and from
 
being subject to an AMR or update the corresponding table to include this component.
In its response by letter dated December 22, 2004, the applicant stated that vents were included under the component type "Piping and Fittings" in LRA Table 2.3.3.B.29-1.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the vents are represented in t he LRA table by the component type "Piping and Fittings." Therefore, the staff's concern described in RAI 2.3.3.B.29-5 is resolved.
2-216 2.3B.3.29.3  Conclusion The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
standby diesel generator fuel oil system co mponents that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the standby diesel generator fuel oil system
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.30  NMP2 Standby Diesel Generator Protection (Generator) System 2.3B.3.30.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.30, the applicant described the standby diesel generator protection (generator) system. The standby diesel generator protection (generator) system is designed to provide for the operation of emergency systems and ESFs during and following the shutdown of
 
the reactor when the preferred power supply is not available. The standby power supply system
 
consists of three standby diesel generators. One generator is dedicated to each of the three
 
divisions of the SR electric power distribution system feeding each Class 1E load group. Any
 
two of the three standby diesel generators have sufficient capacity to start and supply all
 
needed ESFs and emergency shutdown loads in case of a LOCA or LOOP. The standby diesel
 
generators are normally maintained in a standby status. In case of a LOOP or degraded offsite
 
voltage condition the standby diesel generators automatically start, accelerate to rated speed
 
and voltage, and start picking up loads sequentially. In case of a LOCA the standby diesel
 
generators automatically start, accelerate to rated speed, voltage, and frequency, and run
 
unloaded. Should any subsequent LOOP occur, the standby diesel generators would then
 
energize their respective busses. The standby diesel generator protection (generator) system
 
also includes the generator support systems for cooling water and lube oil discussed in the
 
generator standby lube oil system.
The standby diesel generator protection (generato r) system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the standby diesel
 
generator protection (generator) system performs functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides heat transfer
* provides pressure retaining boundary In ALRA Table 2.3.3.B.30-1, the applicant identified the following standby diesel generator protection (generator) system component types t hat are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchangers
* piping and fittings 2-217
* pumps
* sight glass
* tank
* valves 2.3B.3.30.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.30 and USAR Sections 1.2.9.17 and 8.3.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.30 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.3.3.B.30-1 dated November 19, 2004, the staff stated that drawing LR-104D-0 (location C-3) shows the turbocharger as not subject to an AMR. The turbocharger is required for the
 
proper operation of the diesel and has a passive pressure boundary function. This component
 
meets 10 CFR 54.4(a)(1) criteria. Therefore, the staff requested that the applicant provide the
 
basis for excluding the turbocharger from the scope of license renewal and from being subject
 
to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the emergency diesel generators and its turbochargers, are within the scope of license renewal; however, since
 
they are active components, they are not subjec t to an AMR. This statement is consistent with the guidance provided in NEI 95-10, Revision 3, Appendix B.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the component in question is within the scope of license renewal under
 
10 CFR 54.4(a) but not subject to an AMR under 10 CFR 54.21(a) because it is an active
 
component. Therefore, the staff's concern described in RAI 2.3.3.B.30-1 is resolved.
In RAI 2.3.3.B.30-2 dated November 19, 2004, the staff stated that drawing LR-104D-0 (locations H4 and H5) shows that lube oil coolers, fuel oil coolers, and inter coolers were not
 
highlighted as subject to an AMR. These components have a passive pressure boundary
 
function and meet 10 CFR 54.4(a)(1) criteria. Therefore, the staff requested that the applicant
 
provide the basis for omitting these component s from the scope of license renewal and from being subject to an AMR.
In its response by letter dated December 22, 2004, the applicant stated that drawing LR-104D-0 (locations H4 and H5) identifies intercoolers, fuel oil coolers, and lube oil coolers. These heat 2-218 exchangers are passive and long-lived. They are within the scope of license renewal and subject to an AMR. As such they should be shown in red on this drawing. They are included in
 
LRA Sections 2.3.3.B.29, 2.3.3.B.30, 3.3.2.B.28, and 3.3.2.B.29, and in Tables 3.3.2.B-29 and
 
3.3.2.B-30.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the components in question are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently were not
 
highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the
 
components were included correctly within the scope of license renewal and subject to an AMR.
 
Therefore, the staff's concern described in RAI 2.3.3.B.30-2 is resolved.
In RAI 2.3.3.B.30-3 dated November 19, 2004, the staff stated that drawing LR-104D-0 shows jacket water circulation heaters as not subject to an AMR. The USAR does not describe clearly
 
how the heater functions. If the immersion heater works by immersing the heating element in
 
the cooling fluid, then the heater containing the cooling fluid has a passive pressure boundary
 
function and is subject to an AMR per 10 CFR 54.4(a)(1). Because drawing LR-104E-0 shows a
 
similar heater as subject to an AMR the applicant was asked to provide the basis for not
 
including these heaters on drawing LR-104D-0 in the license renewal boundary.
In its response by letter dated December 22, 2004, the applicant stated that drawing LR-104D-0 is incorrect, that the jacket water heaters in question 2EGT*CH4/5 and immersion heater
 
2EGT*CH1 have a pressure boundary function similar to that of lube oil heaters 2EGT*CH2 and
 
2EGT*CH3 on drawing LR-104E-0, that the chamber for 2EGT*CH4/5 is within the scope of
 
license renewal and subject to an AMR. The applicant explained that these chambers are
 
treated as part of the "Piping and Fittings" component type. The applicant stated that, however, these heaters themselves are also in-scope but are active components per NEI 95-10, Revision
 
3, Appendix B, and as such not subject to an AMR.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the components in question are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently were not
 
highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the
 
components were included correctly within the scope of license renewal and subject to an AMR
 
as part of the "Piping and Fittings" component ty pe. The heaters themselves are also in-scope but are active components not subject to an AMR. Therefore, the staff's concern described in
 
RAI 2.3.3.B.30-3 is resolved.
In RAI 2.3.3.B.30-4 dated November 19, 2004, the staff stated that drawing LR-104D-0 shows the water expansion tank and overflow line as subject to an AMR. However, the tubing leading
 
to the level switches and the sight glass on the expansion tank is specifically excluded from
 
AMR. LRA Table 2.3.3.B.30-1 does not identify tanks as a component type requiring an AMR.
 
Therefore, the staff requested that the applicant provide the basis for excluding the sight glass
 
and tubing from the scope of license renewal and omitting the component type "Tank" from the referenced table. The applicant's response by letter dated December 22, 2004, has been
 
incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the applicant provided the staff with a revised LR drawing which identifies SSCs in scope of license renewal and subject to an AMR under 2-219 10 CFR 54.4(a)(2). The applicant also provided clarification on the component groups included in LRA Table 2.3.3.B.30 -1. Therefore, the staff's concern described in RAI 2.3.3.B.30-4 is
 
resolved.In RAI 2.3.3.B.30-5 dated November 19, 2004, the staff stated that on drawing LR-104D-0 the tube sides of jacket water coolers are not highlighted as subject to an AMR. Therefore, the staff
 
requested that the applicant provide the basis for not including this portion of the component
 
within the scope of license renewal.
In its response by letter dated December 22, 2004, the applicant stated that drawing LR-104D-0 identifies the jacket water coolers in question, 2EGS*E1A, 2EGS*E1B, 2EGS*E2A, and
 
2EGS*E2B. The applicant stated that, these coolers and their subcomponents are
 
safety-related, in-scope for license renewal, and subject to an AMR. The LR drawing therefore
 
should show the tube side of the jacket water coolers in red.
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the components in question are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently were not
 
highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the
 
component type was included correctly within the scope of license renewal and subject to an
 
AMR as part of the "Piping and Fittings" component type. Therefore, the staff's concern
 
described in RAI 2.3.3.B.30-5 is resolved.
In RAI 2.3.3.B.30-6 dated November 19, 2004, the staff stated that on drawing LR-104E-0 the LR boundary stops at an open valve HV31J. The tubing beyond this valve has a pressure
 
boundary function subject to an AMR. The same concern exists at location B-7 for piping
 
downstream of valve HV18C. Therefore, the sta ff requested that the applicant provide the basis for not subjecting the piping/tubing down stream of an open valve to AMR.
In its response by letter dated December 22, 2004, the applicant stated that drawing LR-104E-0 has several errors such as at location D10, hand valves 2EGS*HV131J, 2EGS*HV131K, 2EGS*HV231J, and 2EGS*HV231K are shown in black. These components are safety-related, in-scope for license renewal, and should be shown in red as subject to an AMR. In addition the
 
associated piping (from 2EGS*V165 and 2EGS*V265 up to but not including 2EGS*PS4002A
 
and 2EGS*PS4002B) also should be shown in red as in-scope and subject to an AMR.
With respect to hand valve 2EGS*HV118C the same issue was also addressed by the applicant in its response to RAI 2.3.3.B.15-2 (discussed in SER Section 2.3.3.B.15).
Based on its review, the staff found the applicant's response acceptable because it adequately explained that the components in question are within the scope of license renewal under
 
10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently were not
 
highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the
 
component types were included correctly within the scope of license renewal and subject to an
 
AMR as part of the "Piping and Fittings" and "Valves" component types. Therefore, the staff's
 
concern described in RAI 2.3.3.B.30-6 is resolved.
In RAI 2.3.3.B.30-7 dated November 19, 2004, the staff noted a discrepancy between drawings LR-104B-0 and LR-104F-0 in that LR-104B-0 showed the interconnecting piping on LR-104F-0 2-220 as not subject to an AMR while LR-104F-0 showed the piping as subject to an AMR. Therefore, the staff requested that the applicant explain the apparent discrepancy.
In its response by letter dated December 22, 2004, the applicant assumed that the location referenced for drawing LR-104B-0 is in error and that the correct location reference in the RAI
 
for drawing LR-104B-0 appears to be M8, and that the LR continuation flag at location M8 should indicate "LR-EGF" in both directions as opposed to "LR-EGFlsolid blue." The drawing
 
continuation flag directs the reader to "LR-104F (G4)." The LR continuation flag at location G4
 
on drawing LR-104F-0, showing "LR-EGF" in both directions is correct and the lower of the two
 
drawing continuation flags at this location correctly sends the reader to "LR-104B (M8)." Based on its review, the staff found the applicant's response to RAI 2.3.3.B.30-7 acceptable because it adequately explained that the LR renewal continuation flags at location M8 should
 
have indicated "LR-EGF" in both directions as opposed to "LR-EGF" in one direction and "solid
 
blue" in the other. The components on both sides of the continuation flags in question are within
 
the scope of license renewal under 10 CFR 54.4(a) and subject to an AMR under
 
10 CFR 54.21(a). The staff concludes that there is reasonable assurance that the components
 
were included correctly within the scope of license renewal and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.30-7 is resolved.
2.3B.3.30.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
standby diesel generator protection (generator) sy stem components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the standby diesel generator protection (generator) system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.31  NMP2 Standby Liquid Control System 2.3B.3.31.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.31, the applicant described the standby liquid control system. The standby liquid control system is designed to inject a boron solution into the reactor when
 
needed to bring the core to a subcritical condition, providing an alternate method to shut down
 
the reactor in the event that sufficient control rods cannot be inserted in the reactor core to
 
accomplish shutdown and cooldown in the normal manner. This system is designed to provide sufficient negative reactivity to shut down the reactor and keep the reactor from going critical as
 
it cools by mixing a neutron absorber with the primary reactor coolant. The neutron absorber is
 
injected within the core zone via the HPCS system injection line. The standby liquid control
 
system can be initiated manually or automatica lly by the redundant reactivity control system.
The sodium pentaborate solution is discharged radially over the top of the core through the high
 
pressure core spray sparger.
2-221 The standby liquid control system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the standby liquid control
 
system could potentially prevent the satisfactory accomplishment of an SR function. In addition, the standby liquid control system performs functions that support ATWS.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.3.B.31-1, the applicant identified the following standby liquid control system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* expansion joint
* filters/strainers
* flow elements
* piping and fittings
* pumps
* orifices
* tanks
* temperature elements
* valves 2.3B.3.31.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.31 and USAR Section 9.3.5 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
In reviewing LRA Section 2.3.3.B.31, the staff identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
2-222 In RAI 2.3.3.B.31-1 dated November 19, 2004, the staff stated that drawing LR-36A-0 shows Y-strainers at locations G5 and G9 and a strainer element plate at location B9 as subject to an
 
AMR. LRA Table 2.3.3.B.31-1 includes the component type "Filters/Strainers" with an intended
 
function of "Pressure Boundary." Strainers also have a filtration function (as defined in LRA
 
Table 2.0-1) not identified in LRA Table 2.3.3.B.31-1. Therefore, the staff requested that the
 
applicant confirm that filtration is not an intended function for the strainers in the standby liquid
 
control system that requires AMR.
In its response by letter dated December 22, 2004, the applicant stated that a component function would be considered an intended function only if failure of that component function
 
would cause the failure of a system intended function. The applicant also stated that failure of
 
the "Filtration" function of the Y-strainers in question would not prevent the system from
 
performing its intended function the only intended function credited for these components is "Pressure Boundary" as identified in the LRA Table.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.31-1 acceptable because it adequately explained that the components in question perform only a pressure
 
boundary function and that the loss of the filtration function would not prevent the system from
 
performing its intended function. Therefore, the staff's concern described in RAI 2.3.3.B.31-1 is
 
resolved.IN RAI 2.3.3.B.31-2 dated November 19, 2004, the staff stated that drawing LR-36A-0 shows a manhole as subject to an AMR. However, manhole is not listed in the LRA Table 2.3.3.B.31-1
 
as a component type subject to an AMR. Manholes serve a pressure boundary intended
 
function and are passive, long-lived components. To clarify whether this component is a
 
sub-component of a component type listed in LRA Table 2.3.3.B.31-1 the staff requested that
 
the applicant justify the exclusion of the manhole component from being subject to an AMR
 
under 10 CFR 54.21(a)(1).
In its response dated December 22, 2004, the applicant stated that manholes are within the scope of license renewal, subject to an AMR, and included under the component type "Tanks" in the LRA Table.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.31-2 acceptable because it adequately explained that the manhole component in question is within the scope of
 
license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a). Further, the applicant stated that the manhole component is represented in the LRA Table by the
 
component type "Tanks." Therefore, the staff's concern described in RAI 2.3.3.B.31-2 is
 
resolved.In RAI 2.3.3.B.31-3 dated November 19, 2004, the staff requested that the applicant clarify information on drawing LR-36A-0 concerning SSCs in the scope of license renewal. The
 
applicant's response by letter dated December 22, 2004, has been incorporated in the ALRA as
 
discussed below.
In its ALRA dated July 14, 2005, the applicant provided the staff with revised LR drawings which identify all SSCs within the scope of license renewal and subject to an AMR including those
 
subject under 10 CFR 54.4(a)(2). Based on review of the information submitted in the amended
 
LRA the staff's concern described in RAI 2.3.3.B.31-3 is resolved.
2-223 In RAI 2.3.3.B.31-4 dated November 19, 2004, the staff stated that drawing LR-36A-0 shows thepneumatic signals from the FIC103, LT-103, and LIX103 to the storage tank TK1 as subject to
 
an AMR. However, the flow indicator controller FIC103 is shown as excluded from requiring an
 
AMR. This instrument as shown on LR-36A-0 is installed in-line for isolation of the air supply to
 
the level instruments. Therefore, FIC103 serves a pressure boundary intended function. The
 
applicant was asked to explain why FIC103 had been excluded from the scope of license
 
renewal and from requiring an AMR under 10 CFR 54.4(a) and 10 CFR 54.21(a)(1).
Furthermore, drawing LR-36A-0 does not show how this pneumatic signal (line) extends inside the storage tank. Therefore, the staff requested that the applicant clarify whether the pneumatic
 
line portions inside the storage tank are within the scope of license renewal and subject to an
 
AMR and, if not, justify their exclusion under 10 CFR 54.4(a) and 10 CFR 54.21(a)(1).
In its response by letter dated December 22, 2004, the applicant stated that the pneumatic lines are shown incorrectly on drawing LR-36A-0 as in-scope for license renewal and subject to an
 
AMR. The applicant stated that these lines are NSR and should be shown in black. Additionally, the applicant expalined that the instruments are NSR and as such are not within the scope of
 
license renewal. As active devices if they were within scope they would not be subject to an
 
AMR.Based on its review, the staff found that the applicant's NSR level instruments in question are not needed to perform safe shutdown of the reactor and do not have an intended function under
 
10 CFR 54.4(a). Therefore, the staff's concern described in RAI 2.3.3.B.31-4 is resolved.
In RAI 2.3.3.B.31-5 dated November 19, 2004, the staff stated that drawing LR-36A-0 shows pipeline 2-MWS-001-68-4 at location B1, to 2-SLC-001-28-4, at location C-1. The staff therefore
 
sought the following additional information:  a.The acronym MWS, apparently the makeup water system that provides demineralized water, is not defined in the license renewal boundary drawing LR-000-2F-0. Define the
 
MWS acronym. b.The check valve V3 at location C1 function is to isolate the in-scope portion of the pipeline 2-SLC-001-28-4 from the out of scope pipeline 2-MWS-001-68-4. Check valves
 
are passive and long-lived components. Justify the exclusion of V3 from the scope of
 
license renewal and from being subject to an AMR under 10 CFR 54.4(a) and
 
10 CFR 54.21(a)(1).
In its response by letter dated December 22, 2004, the applicant stated:  a."MWS" does stand for Make-up Water System. This acronym was inadvertently omitted from drawing LR-000-2F-0.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.31-5a acceptable because it adequately explained that the acronym MWS stands for make-up water system.
 
Therefore, the staff's concern described in RAI 2.3.3.B.31-5a is resolved.
2-224 In its response to part b the applicant further stated:  b.See response to RAI 2.3.3.B.31-3. The described correction in that RAI includes the incorrect depiction of valve 2SLS-V3 on drawing LR-36A-0.
Based on its review, the staff found the applicant's response to RAI 2.3.3.B.31-5b acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently
 
were not highlighted on the LR drawing. There is reasonable assurance that the components
 
were included correctly within the scope of license renewal and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.3.B.31-5b is resolved.
2.3B.3.31.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
standby liquid control system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the standby liquid control system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.32  NMP2 Yard Structures Ventilation System 2.3B.3.32.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.32, the applicant described the yard structures ventilation system. The yard structures ventilation system is designed to provide heating and outside air ventilation for the service water pump bays, screenwell building, fire pump rooms, demineralizer water storage tank building, CST building, electrical bay, screenhouse, and chiller building. Each of the service
 
water pump bays is also equipped with redundant unit coolers which maintain the space
 
temperature within design limits by dischargi ng heat to the service water system. The yard structures ventilation system also provides space cooling to the service water pump bays, ensuring that ambient temperature remains within the pump operating design limits.
The yard structures ventilation system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the yard structures ventilation system
 
performs functions that support fire protection and EQ.
The intended functions within the scope of license renewal include the following:
* provides rated fire barrier
* provides heat transfer
* provides pressure retaining boundary In ALRA Table 2.3.3.B.32-1, the applicant identified the following yard structures ventilation system component types that are within the scope of license renewal and subject to an AMR:
2-225
* blowers
* dampers (includes fire dampers)
* ducting
* unit coolers 2.3B.3.32.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.32 and USAR Sections 9.4.7 and 9B.4.4.3.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.32.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the yard structures ventilation system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the yard structures ventilation
 
system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.33  NMP2 Auxiliary Boiler System 2.3B.3.33.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.33, the applicant described the auxiliary boiler system. The auxiliary boiler system is designed to supply primary loads during plant shutdown including building
 
heating, radwaste process reboiler system, and other auxiliary system heat exchangers. As the auxiliary boilers are not normally used to augment the auxiliary steam sy stem, auxiliary boiler steam may be used to provide a heat source to the off-gas system and clean steam reboilers
 
prior to start-up.
The failure of NSR SSCs in the auxiliary boiler sy stem could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.33-1, the applicant identified the following auxiliary boiler system component types that are within the scope of license renewal and subject to an AMR:
2-226
* accumulator
* bolting
* filter housing
* heat exchanger
* piping and fittings
* pumps
* restricting orifices
* tanks
* valves 2.3B.3.33.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.33 and USAR Section 9.5.10 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.33.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the auxiliary boiler system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the auxiliary boiler system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.34  NMP2 Circulating Water System 2.3B.3.34.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.34, the applicant described the circulating water system. The function of the circulating water system is to provide the main condenser with a continuous supply of
 
cooling water. The water is used to remove the heat discharged from the turbine exhaust and
 
turbine bypass steam as well as from other equipment over the full range of operating loads.
Makeup water for the circulating water system is obtained from the service water system. During the winter months warm water from the circul ating water system is used to temper the lake intake water.
The failure of NSR SSCs in the circulating water system could potentially prevent the satisfactory accomplishment of an SR function.
2-227 The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.34-1, the applicant identified the following circulating water system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* valves 2.3B.3.34.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.34 and USAR Section 10.4.5 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.34.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the circulating water system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the circulating water system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.35  NMP2 Makeup Water Treatment System 2.3B.3.35.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.35, the applicant described the makeup water treatment system. The makeup water treatment system processes domestic water to supply the makeup water storage
 
and transfer system with demineralized water. The system will also provide domestic water from the filtered water storage tank for seal water to the circulating water system pumps. The
 
domestic water is pumped by one of the filter pum ps from either the filtered water storage tank 2-228 or the waste water recovery tanks through the water treating filter to the Ecolochem trailer. After processing through the Ecolochem trailer, it is pumped to the demineralized water storage
 
tanks.The failure of NSR SSCs in the makeup water tr eatment system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.35-1, the applicant identified the following makeup water treatment system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* valves 2.3B.3.35.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.35 and USAR Section 9.2.3.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.35.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the makeup water treatment system components that are within the
 
scope of license renewal, as required by 10 CFR 54.4(a), and the makeup water treatment
 
system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.36  NMP2 Radioactive Liquid Waste Management System 2.3B.3.36.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.36, the applicant described the radioactive liquid waste management system. The radioactive liquid waste management system is conceptually divided into four subsystems: the waste collector subsystem, the floor drain collector subsystem, the regenerant 2-229 waste subsystem, and the phase separator subsystem. The waste collection subsystem provides for collection, filtering, and demineralizing of generally low conductivity waste. The
 
floor drain collector system pumps provide necessary head and flow for mixing, sampling, or processing. Floor drain system water is normally processed using vendor-supplied equipment (Thermex). The two cleanup phase separator tanks accept RWCU filter/demineralizer
 
backwashes. The spent fuel pool phase separator tank accepts spent fuel pool
 
filter/demineralizer backwashes. The two regenerant waste tanks receive waste transferred from
 
the waste neutralizer tank at the demineraliz er regeneration system or from the radwaste chemical sump. Regenerant waste pumps provide necessary head and flow for mixing, sampling, and processing to vendor-supplied equipment (Thermex) or through spent resin. The
 
spent resin tank accepts transfers from the phase separator tanks, filter backwash tank, waste
 
sludge tank, Thermex, and demineralizer regenerati on system. The tank is decanted by gravity drain to the floor drain collector tanks. The remaining waste is transferred to the waste sludge
 
tank for transfer to a liner using solid radwaste procedures.
The failure of NSR SSCs in the radioactive liquid waste management system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.36-1, the applicant identified the following radioactive liquid waste management system component types within t he scope of license renewal and subject to an AMR:
* bolting
* filters
* piping and fittings
* pumps
* restricting orifice
* tanks
* valves 2.3B.3.36.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.36 and USAR Section 11.2.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-230 2.3B.3.36.3  Conclusion The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the radioactive liquid waste management system components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the radioactive liquid
 
waste management system components that ar e subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.37  NMP2 Roof Drainage System 2.3B.3.37.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.37, the applicant described the roof drainage system. The roof drainage system is designed to collect water accumulation on building roofs and transport it to
 
Lake Ontario.
The failure of NSR SSCs in the roof drainage syst em could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.37-1, the applicant identified that the "Piping and Fittings" component type of the roof drainage system is within the scope of license renewal and subject to an AMR.
2.3B.3.37.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.37 and USAR Section 2.4.2.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.37.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On 2-231 the basis of its review, the staff concludes that there is reasonable assurance that the applicant had adequately identified the roof drainage system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the roof drainage system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.38  NMP2 Sanitary Drains and Disposal System 2.3B.3.38.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.38, the applicant described the sanitary drains and disposal system.
The sanitary drains and disposal system is designed to treat and dispose of the waste from all
 
plumbing fixtures except lavatories, sinks, and drains containing waste that is contaminated or
 
potentially contaminated with chemicals or r adioactivity. Such contaminated or potentially contaminated waste is physically segregated from the sanitary drains and disposal system and is connected to the floor and equipment drains systems. Noncontaminated sanitary waste from NMP2 flows by gravity to an underground wetwell (11,500-gallon storage capacity). The wetwell
 
is located adjacent to a sewage lift station equipped with two sewage pumps to transport the
 
waste to an on-site sanitary waste treatment facility. All noncontaminated waste lines are vented
 
to the atmosphere.
The failure of NSR SSCs in the sanitary drains and disposal system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.38-1, the applicant identified that the "Piping and Fittings" component type of the sanitary drains and disposal syst em is within the scope of license renewal and subject to an AMR.
2.3B.3.38.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.38 and USAR Section 9.2.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.38.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be 2-232 subject to an AMR had not been identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the sanitary drains and disposal system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the sanitary drains and
 
disposal system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.39  NMP2 Service Water Chemical Treatment System 2.3B.3.39.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.39, the applicant described the service water chemical treatment system. The service water chemical treatment sy stem provides biocides and detoxification to the service water system to control MIC. The biocides (sodium hypochlorite and sodium
 
bromide) are dripped into the service water intake bay and the detoxification agent (sodium
 
bisulfite) is introduced into the two 30-inch return lines. The chemicals are stored in the
 
refurbished acid and hypochlorite tanks. The chemicals are delivered by six skid-mounted dosing pumps, two sodium bisulfite pumps, tw o sodium hypochlorite pumps, and two sodium bromide pumps. Demineralized carrier water is supplied from the makeup water system and is
 
used to deliver chemicals from the dosi ng pumps to the appropriate delivery point.
The failure of NSR SSCs in the service water chemical treatment system could potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components In ALRA Table 2.3.3.B.39-1, the applicant identified the following service water chemical treatment system component types that are wi thin the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* valves 2.3B.3.39.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.3.B.39 and USAR Section 9.2.4 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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 2-233 had identified as being within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.39.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the service water chemic al treatment system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the service water
 
chemical treatment system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.3.40  NMP2 Turbine Building Closed Loop Cooling Water System 2.3B.3.40.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.3.B.40, the applicant described the turbine building closed loop cooling water (TBCLCW) system. The TBCLCW system is a demineralized water, closed-cycle, heat transfer system that consists of three 50-percent capacity pumps and heat exchangers along
 
with appropriate controls and instrumentation to ensure adequate cooling capacity for the TB
 
and RWB auxiliary systems and components during nor mal plant operation. Heat removed from components by the TBCLCW system is transferr ed to the service water system. A surge and makeup tank accommodates system volume changes due to temperature variations, maintains
 
static head on the pumps, and allows detection of gross leaks in the system. It also provides for
 
normal leakage in the system. Makeup water to the surge tank is provided by the makeup water system.The failure of NSR SSCs in the TBCLCW system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.3.B.40-1, the applicant identified the following TBCLCW system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* piping and fittings
* sample cooler
* valves 2.3B.3.40.2  Staff Evaluation 2-234 The staff reviewed ALRA Section 2.3.3.B.40 and USAR Section 9.2.7 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.3.40.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the TBCLCW system components that are within the scope of license
 
renewal, as required by 10 CFR 54.4(a), and the TBCLCW system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.4  Steam and Power Conversion Systems In ALRA Section 2.3.4.B, the applicant identified the structures and components of the NMP2 steam and power conversion systems that ar e subject to an AMR for license renewal.
The applicant described the supporting structures and components of the steam and power conversion systems in the following sections of the ALRA:
* 2.3.4.B.1NMP2 main condenser air removal system
* 2.3.4.B.2NMP2 condensate system
* 2.3.4.B.3NMP2 feedwater system
* 2.3.4.B.4NMP2 main steam system
* 2.3.4.B.5NMP2 moisture separator and reheater system
* 2.3.4.B.6NMP2 extraction steam and feedwater heater drain system
* 2.3.4.B.7NMP2 turbine main system
 
The staff's review findings regarding ALRA Sections 2.3.4.B.1 through 2.3.4.B.7 are presented
 
in SER Sections 2.3B.4.1 through 2.3B.4.7, respectively.2.3B.4.1  NMP2 Main Condenser Air Removal System 2.3B.4.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.B.1, the applicant described the main condenser air removal system. The purpose of the main condenser air removal system is to establish and maintain a main
 
condenser vacuum by removing air and noncondensable gases from the main condenser. This
 
system consists of two subsystems. The hoggi ng subsystem is used to establish condenser 2-235 vacuum during plant startup. The holding subs ystem is used to maintain condenser vacuum during normal plant operations.
The failure of NSR SSCs in the main condenser air removal system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.B.1-1, the applicant identified the following main condenser air removal system component types that are within the scope of license renewal and subject to an AMR:
* air ejectors
* bolting
* heat exchangers
* piping and fittings
* valves 2.3B.4.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.4.B.1 and USAR Section 10.4.2 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.4.1.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the main condenser air removal system components that are within
 
the scope of license renewal, as required by 10 CFR 54.4(a), and the main condenser air
 
removal system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.4.2  NMP2 Condensate System 2.3B.4.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.B.2, the applicant described the condensate system. The condensate system provides a reliable supply of condensat e to the feedwater (FW) system. The condensate 2-236 system consists of the main condenser, three condensate pumps, three condensate booster pumps, three trains of drain coolers and low pressure heaters, controls, instrumentation, piping, valves, and associated equipment to supply the FW system with heated, high quality
 
condensate.
For license renewal purposes the condensate sy stem also includes the following systems:
condensate makeup and drawoff system, condens ate demineralizer system, condensate demineralizer system - mixed bed system , condensate booster pump lube oil system, and auxiliary condensate system. The condensate mak eup and drawoff system provides makeup water to various systems in the plant, serves as a source of water during refueling operations, serves as reserve for the RCIC system and the HPCS system, and provides for condenser hotwell level control. The condensate demineralizer system and condensate demineralizer
 
system - mixed bed system are designed to mainta in reactor feedwater purity by the removal of soluble and insoluble impurities from the condens ate. They also provide a means of cleaning the condensate resins. The condensate booster pump lube oil system provides lubricating oil to
 
the condensate booster pump seals. The auxiliary condensate system provides level controls and condensate removal functions for systems, structures, and components that are supplied
 
with auxiliary steam.
The condensate system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the condensate system could potentially
 
prevent the satisfactory accomplishment of an SR function. In addition, the condensate system
 
performs functions that support fire protection, EQ, ATWS, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary In ALRA Table 2.3.4.B.2-1, the applicant identified the following condensate system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow element
* heat exchanger
* main condenser
* piping and fittings
* pump
* restriction orifice
* tanks
* valves 2.3B.4.2.2  Staff Evaluation 2-237 The staff reviewed ALRA Section 2.3.4.B.2 and USAR Sections 9.2.6, 10.4.1, 10.4.6, and 10.4.7 using the evaluation methodology described in SER Section 2.3. The staff conducted its review
 
in accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.2 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 2.3.4.B.2-1 dated November 19, 2004, the staff stated that drawing LR-004B-0 shows
 
that check valve *V298 is subject to an AMR. However, the line on which this valve is located is
 
shown not requiring an AMR on both the upstream (line 2-CNS-006-44-4) and downstream (line 2-CNS-006-298-4) sides of the valve. The staff believes that a failure in these lines could affect
 
structural support of the valve, cause a discontinuity in pressure boundary across the valve, and
 
possibly prevent the valve from performing its intended function. The applicant was asked to
 
describe the intended function of check valve *V298 and justify why the valve line would not
 
require AMR.
In its response dated December 22, 2004, the applicant stated that the intended function for this check valve is "Pressure Boundary" to provide secondary containment integrity. The applicant
 
stated that all support to the line in which the valve is located is seismic that and the associated
 
piping upstream and downstream of the check valve is not required to be within the scope of
 
license renewal for pressure boundary. The applicant stated further that the main supply line
 
into the secondary containment contains this check valve at a low point which in case of a pipe
 
break outside the containment is sealed by a 70-foot column of water. A line break within the
 
reactor building would provide a preferential flow path for containment atmosphere leakage into
 
the reactor building atmosphere and any gaseous leakage would be collected by the standby
 
gas treatment system and thus not be classifi ed as bypass leakage. The applicant also stated that the associated piping upstream and downstream of 2CNS*V298 is not required to be within
 
the scope of license renewal for the pressure boundary intended function. However, the piping, on either end of the valve that is contained within the reactor building and piping tunnel is within
 
the scope of license renewal and subject to AMR pursuant to 10 CFR 54.4(a)(2) criterion.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.2-1 acceptable because it adequately explained that although the check valve in question provides a pressure
 
boundary function to preserve secondary containment integrity and is therefore in the scope of
 
license renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) its
 
upstream and downstream piping is not necessary for secondary containment integrity.
 
Therefore, the staff's concern described in RAI 2.3.4.B.2-1 is resolved.
In RAI 2.3.4.B.2-2 dated November 19, 2004, the staff stated that NMP2 USAR page 9.2-43 states that the "condensate storage facility's condensate makeup and drawoff (CNS) system" 2-238 which contains both condensate storage tanks "is not required to effect or support safe shutdown of the reactor or to support the operation of any nuclear safety system." However, NMP2 USAR page 8.3-64 states that the CST inventory is monitored daily to assure the
 
"availability, adequacy, and capability to achieve and maintain a safe plant shutdown and to
 
recover from an SBO for the four-hour coping duration." Further, LRA Section 2.3.4.B.2 states
 
that the CSTs are within the scope of license renewal and subject to an AMR. Therefore, the
 
staff requested that the applicant explain the apparent discrepancy described above.
In its response by letter dated December 22, 2004, the applicant stated that NMP2 USAR Sections 9.2.6.1.1 and 9.2.6.3 properly state the safety design basis for the condensate storage
 
facility CNS system. The applicant stated that the CNS system is NSR and is not required to
 
prevent or mitigate DBEs but that, as discussed in USAR Section 8.3.1.5, the inventory in the
 
condensate storage tanks is credited in the station blackout coping analysis. The applicant
 
stated further that USAR Section 9.2.6.3 notes the condensate storage requirements related to
 
station blackout. Therefore, there is no discrepancy and the condensate storage tanks and
 
other components identified in the LRA section are included correctly within the scope of license
 
renewal.Based on its review, the staff found the applicant's response to RAI 2.3.4.B.2-2 acceptable because it adequately explained that although the nonsafety-related condensate storage tanks
 
in question provide a pressure boundary function to recover from an SBO and are therefore in
 
the scope of license renewal and subject to an AMR they are not required to prevent or mitigate
 
DBEs under 10 CFR 54.4(a)(1). Therefore, the staff's concern described in RAI 2.3.4.B.2-2 is
 
resolved.In RAI 2.3.4.B.2-3 dated November 19, 2004, the staff requested that the applicant clarify inconsistencies in drawing LR-004A-0. The applicant's response by letter dated December 22, 2004, has been incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the applicant provided the staff with a revised LR drawing correcting the inconsistencies and accurately depicting the components subject to an AMR
 
under 10 CFR 54.4(a)(2). Therefore, the staff's concern described in RAI 2.3.3.B.2-3 is
 
resolved.In RAI 2.3.4.B.2-4 dated November 17, 2004, the staff stated that drawing LR-003A-0 shows lines from connections labeled 39 on condenser 1A and 1C to pressure transmitters 46A,B and
 
46C,D respectively. These instruments transmit condenser vacuum pressure. Upon loss of
 
condenser vacuum the signal from these transmitters will effect a reactor scram and main
 
turbine trip. However, only a segment of these lines from valves V2A and V2B to their
 
respective transmitters is shown within the scope of license renewal. The segment from the
 
condenser connection up to and including these valves is shown outside of scope. Since these
 
transmitters perform a safety function the staff believed the entire line should have been within
 
scope. Further, the drawing did not show corresponding lines and transmitters for condenser
 
1B. Therefore, the staff requested that the applicant justify exclusion of such line segments and
 
valves from the scope of license renewal and to explain the absence of the corresponding lines
 
and transmitters for condenser 1B.
In its response by letter dated December 22, 2004, the applicant stated that condenser 1B was not provided with the safety-related pressure transmitters per the original design and that the 2-239 three condenser shells are connected by equalizing ducts in the condenser necks and by condensate pipes between the hotwells.
The applicant stated further that the SR pressure transmitters monitor main condenser vacuum and upon loss of vacuum will effect main steam line isolation and reactor trip, that the main
 
condenser itself is NSR and not required for the safe shutdown of the reactor that the line
 
segment from the main condenser up to and including valves addressed in the RAI form part of
 
the NSR main condenser boundary, and that the SR pressure transmitters and the connecting
 
tubing function to monitor loss of main condenser vacuum due to air in-leakage caused by
 
failure of the NSR main condenser boundary.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.2-4 acceptable because it adequately explained that although the safety-related pressure transmitters effect a
 
main steam line isolation and reactor trip on loss of condenser vacuum, the transmitters' piping
 
and condensers they monitor are non-safety related, not required for safe shutdown of the
 
reactor, and have no intended functions under 10 CFR 54.4(a). Therefore, the staff's concern
 
described in RAI 2.3.4.B.2-4 is resolved.
In RAI 2.3.4.B.2-5 dated November 17, 2004, the staff stated that LR drawings LR-004A-0, LR-033B-0, and LR-035D-0 show that the vent on each condensate tank does not require AMR
 
while the tank itself is within scope and subject to an AMR. The staff believed that failure of this
 
vent could prevent the tank from performing it s intended function by debris falling into the tank and blocking the supply lines to the RCIC and HPCS systems or tank collapse due to
 
inadequate venting. Therefore, the staff requested that the applicant justify exclusion of the
 
condensate tank vents from requiring an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the NSR condensate storage tank vent line does not have an intended function for license renewal and
 
therefore is not in-scope. The applicant stated that the condensate piping connects to the side
 
of the tank and any potential negligible debris fr om general corrosion from the vent line would settle to the bottom of the tank with no possibility of condensate piping blockage. The applicant
 
stated further that a sudden catastrophic failure of the vent line blocking the vent path is also
 
implausible and that elimination of the vent piping would result in a hole in the tank which would
 
act as a vent path.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.2-6 acceptable because it adequately explained that due to the configuration of the suction piping to the tank
 
and the geometry of the vent line piping debris falling into the tank would not cause loss of the
 
venting function. Therefore, the staff's concern described in RAI 2.3.4.B.2-5 is resolved.
 
In RAI 2.3.4.B.2-6 dated November 17, 2004, the staff stated that on drawing LR-033B-0, the acronyms "F1" and "GEX1" are shown encircled at various locations. However, they were not
 
defined in the LRA, the USAR, the drawing legend, or on the drawing itself. The applicant was asked to define the acronyms F1 and GEX1.
 
In its response by letter dated December 22, 2004, the applicant stated that the "F1" and "GEX1" notations relate to the ASME in-service pressure test program.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.2-6 acceptablebecause it adequately explained that the acronyms F1 and GEX1 shown on LR drawings relate 2-240 to the ASME in-service pressure test program and may be ignored for LRA purposes.
Therefore, the staff's concern described in RAI 2.3.4.B.2-6 is resolved.
2.3B.4.2.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
condensate system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the condensate system components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3B.4.3  NMP2 Feedwater System 2.3B.4.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.B.3, the applicant descr ibed the FW system. The FW system provides a reliable supply of feedwater to the reactor at the temperature, pressure, quality, and flow rate
 
required by the reactor. Connections from the zi nc injection passivation system are provided on both the suction and discharge to the feedwater pumps. The RWCU system also connects to
 
the FW system between the feedwater heaters and system isolation valves.
For license renewal purposes the FW system al so includes the following systems: feedwater pump seals and leakoff system, feedwater pump re circulation balance drum leakoff system, and feedwater pump drive lube oil system. The feedw ater pump seals and leakoff system provides seal water to the pump mechanical seals from the condensate booster pump discharge. The
 
seal water minimizes pump mechanical seal leakage and cools the pump seals to minimize seal
 
degradation. The feedwater pump recirculation balanc e drum leakoff system provides minimum flow protection for each feedwater pump via a recirculation line to the main condenser. The
 
feedwater pump drive lube oil system prov ides lube oil to the reactor feed pumps.
The FW system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the FW system could potentially prevent the
 
satisfactory accomplishment of an SR function.
In addition, the FW system performs functions that support EQ and ATWS.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components 2-241 In ALRA Table 2.3.4.B.3-1, the applicant identified the following FW system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* flow element
* heat exchanger
* piping and fittings
* pump
* restriction orifice
* strainer
* valves 2.3B.4.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.4.B.3 and USAR Section 10.4.7 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.3 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 2.3.4.B.3-1 dated November 19, 2004, the staff stated that drawing LR-037B shows segments of piping labeled 2-WCS-008-89-1 and 2-WCS-008-250-1 within the scope of license
 
renewal and subject to an AMR and the branch lines that connect these segments to
 
temperature elements TE79A and TE79B not subjec t to an AMR. In the LR drawing it appeared that these branch lines are exposed to the same fluid and not isolated from the lines they
 
connect. Therefore, the staff believed they should be subject to an AMR. The applicant was
 
asked to justify exclusion of the abovementioned branch lines from requiring an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the LR drawing is incorrect and does not properly show the components within the scope of license renewal and
 
subject to an AMR, that the components should have been highlighted on the LR drawing
 
showing them within the scope of license renewal under 10 CFR 54.4(a) and are subject to an
 
AMR under 10 CFR 54.21(a) but inadvertently were not highlighted. The components have
 
been included within the scope of license renewal and subject to an AMR.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.3-1 acceptable because it adequately explained that the components in question are within the scope of license
 
renewal under 10 CFR 54.4(a) and subject to an AMR under 10 CFR 54.21(a) but inadvertently 2-242 were not highlighted on the LR drawing. The staff concludes that there is reasonable assurance that the components were included correctly within the scope of license renewal and subject to
 
an AMR. Therefore, the staff's concern described in RAI 2.3.4.B.3-1 is resolved.
In RAI 2.3.4.B.3-2 dated November 19, 2004, the staff stated that on drawing LR-006A the only components shown within the scope of license renewal are eight valves located on the
 
discharge side of the three reactor feed pumps (LV10A, -B, -C, FV2A, -B, -C, and LV55A, -B).
 
However, the piping on both the upstream and downstream sides of these valves is shown
 
outside of scope and not subject to an AMR. Further, on LRA page 2.3-203 the paragraph which
 
describes the portions of the system containing components subject to an AMR does not
 
reference these valves. Therefore, the staff requested that the applicant describe the intended
 
function of the eight valves per 10 CFR 50.54(a)(1) or (a)(3) and discuss the effect of a pressure
 
boundary breach in the lines housing these valves on the ability of the valves to perform their
 
intended function.
In its response by letter dated December 22, 2004, the applicant stated that the valves located on the discharge side of the reactor feed pumps and the feedwater bypass valves to the
 
condenser work in conjunction to mitigate the consequences of an anticipated transient without
 
scram (ATWS) event by isolating feed flow to the reactor and diverting flow to the main
 
condenser. The applicant stated that although the valves are within the scope of license
 
renewal and NSR they do not have the pressure boundary intended function to accomplish the
 
system level ATWS function. Further, the applicant explained that a pressure boundary breach
 
in the lines housing these valves will not affect the ability of the valves to prevent feedwater flow
 
to the reactor.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.3-2 acceptable because it adequately explained that although the nonsafety-related valves in question work in
 
conjunction to isolate feedwater flow to the reactor to mitigate an ATWS and are therefore in the
 
scope of license renewal under 10 CFR 54.4(a)(3) and subject to an AMR under
 
10 CFR 54.21(a) a pressure boundary breach in their associated piping would not affect this
 
intended function. Therefore, the staff's concern described in RAI 2.3.4.B.3-2 is resolved.
2.3B.4.3.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
FW system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the FW system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).2.3B.4.4  NMP2 Main Steam System 2.3B.4.4.1  Summary of Technical Information in the Amended Application 2-243 In ALRA Section 2.3.4.B.4, the applicant described the main steam system. The main steam system provides high pressure steam from t he RPV to the main turbine and the reheating side of the moisture separator/reheater. The main steam system also provides steam to the RCIC system for operation of its turbine-driven pump.
The main steam system consists of four main steam lines, eight main steam isolation valves, eighteen safety relief valves, controls, instrumentation, piping, valves, and associated equi pment. Seven of the safety relief valves are used by the automatic depressurization system to depressurize the RPV during accident
 
conditions.
For license renewal purposes the main steam sy stem also includes the auxiliary steam system and the main steam safety valves vents and drains system. The auxiliary steam system provides reduced pressure steam to the steam jet air ejectors, offgas preheaters, clean steam
 
reboiler, building heating intermediate heat exchanger and is the backup steam supply for the
 
turbine gland seal system. The main steam safety valves vents and drains system directs high pressure steam from the safety relief valves to the suppression pool.
The main steam system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the main steam system could potentially
 
prevent the satisfactory accomplishment of an SR function. In addition, the main steam system performs functions that support fire protection, EQ, and SBO.
The intended functions within the scope of license renewal include the following:
* maintains mechanical and structural integrity of NSR components to prevent spatial interactions with SR components
* provides removal and/or holdup of fission products
* provides pressure retaining boundary
* maintains mechanical and structural integrity of NSR components that provide structural support to attached SR components
* provides flow restriction In ALRA Table 2.3.4.B.4-1, the applicant identified the following main steam system component types that are within the scope of license renewal and subject to an AMR:  * "T" quenchers
* bolting
* condensing chambers
* flexible hose
* flow elements
* piping and fittings
* restriction orifices
* strainers
* valves 2-244 2.3B.4.4.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.B.4 and USAR Sections 5.2.2, 5.4, and 10.3 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.B.4 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 2.3.4.B.4-1 dated November 19, 2004, the staff requested that the applicant provide information concerning the auxiliary steam system , specifically if it had been included within the scope of license renewal and subject to an AMR. The applicant's response by letter dated
 
December 22, 2004, has been incorporated in the ALRA as discussed below.
The applicant stated in its response letter that it had transferred all of the auxiliary steam system components to the main steam system and thus ev aluated them as part of this system in the LRA but that because none of the auxiliary steam system components were within the scope of license renewal per 10 CFR 54.4(a)(1) or (a)(3) they were not included on any LR drawings.
 
Consistent with the system description in LRA Section 2.3.4.B.4, the applicant explained that
 
any of the fluid-filled main steam or auxiliary steam system components located in the main steam tunnel, the reactor building, or the turbine building are within the scope of license renewal
 
and subject to an AMR per 10 CFR 54.4(a)(2). Consistent with LR drawing convention, components within the scope of license renewal and subject to an AMR per 10 CFR 54.4(a)(2)
 
only, are not to be shown in red.
In its ALRA dated July 14, 2005, the applicant provided the requested information. Based on review of the information submitted in the ALRA the staff's concern described in RAI 2.3.3.B.4-1
 
is resolved.
In RAI 2.3.4.B.4-2 dated November 17, 2004, the staff stated that LR drawings LR-1E-0 and LR-1F-0 show the inboard and outboard main steam isolation valves (MSIVs) respectively for
 
each of the four main steam lines. These valves perform an SR function (system isolation) and
 
are shown as requiring an AMR on the drawings. However, the pneumatic actuators for these
 
valves are not shown to require AMR. Because the actuators are required to effect operation of
 
the MSIVs the staff believes they likewise should be subject to an AMR. The applicant was
 
asked to justify exclusion of the MSIV actuators from requiring an AMR.
In its response by letter dated December 22, 2004, the applicant stated that the MSIV pneumatic actuators are within the scope of license renewal and subject to an AMR for a
 
pressure boundary intended function. The applicant further stated that AMR of these actuators 2-245 will be performed and LRA revisions to incorporate the AMR results and any other associated LRA changes will be submitted by February 28, 2005.
In evaluating this response the staff found it incomplete and that review of LRA Section 2.3.4.B.4 could not be completed. Although it adequately explained that the MSIV
 
pneumatic actuators in question are within the scope of license renewal and subject to an AMR, however, the applicant did not provide LRA revisions to incorporate the AMR results and any
 
other associated LRA changes. The staff held a teleconference with the applicant on
 
January 27, 2005, to discuss information necessary to resolve the concern in RAI 2.3.4.B.4-2.
 
The product of the teleconference was an agreement by the applicant to transmit the required
 
information by a follow-up letter.
By letter dated January 31, 2005, the applicant stated that NMPNS has reviewed the function of the NMP2 MSIV actuators and has concluded that an AMR is not required for license renewal.
 
The eight MSIVs are air-operated valves normally open with a fail-safe position of closed. The
 
actuator is a double-acting cylinder and air is used to move the valve in both the open and
 
closed directions. The valves are also equipped with closing springs that will close them upon
 
loss of air pressure. Valve closure following loss of air is assisted by air directed from an air tank
 
accumulator to the top of the actuator cylinder but the closing spring forces are sufficient to
 
meet the accident analysis time limit (3 to 10 seconds) for MSIV closure without the air assist
 
feature. Therefore, the air pressure boundary function of the actuators is not required for the
 
MSIVs to travel to their fail-safe (closed) positions. The applicant stated that more information
 
regarding the design and evaluation of the MSIVs is available in NMP2 USAR Section 5.4.5.
Based on its review, the staff found the applicant's response to RAI 2.3.4.B.4-2, including the information in the teleconference and letter dated January 31, 2005, acceptable, because it
 
adequately explained that the MSIV air cylinder actuators possess no pressure boundary
 
intended function and therefore do not require an AMR. Additionally, the response described the
 
USAR section applicable to these valve actuators. Therefore, the staff's concern described in
 
RAI 2.3.4.B.4-2 is resolved.
2.3B.4.4.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and accompanying scoping boundary drawings to determine whether any SSCs that should be within the scope of license renewal had not been
 
identified by the applicant. No omissions were identified. In addition, the staff performed a
 
review to determine whether any components that should be subject to an AMR had not been
 
identified by the applicant. No omissions were identified. On the basis of its review, the staff
 
concludes that there is reasonable assurance that the applicant had adequately identified the
 
main steam system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the main steam system components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.3B.4.5  NMP2 Moisture Separator and Reheater System 2.3B.4.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.B.5, the applicant described the moisture separator and reheater system.
The moisture separator and reheater system removes entrained moisture from the high 2-246 pressure turbine exhaust and reheats the dried steam to superheated conditions before it passes on to the low pressure turbine. The moisture separator and reheater system
 
encompasses the cold reheat steam, hot reheat steam, moisture separator and reheater vents, and moisture separator vents and drains systems.
The failure of NSR SSCs in the moisture separator and reheater system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.B.5-1, the applicant identified the following moisture separator and reheater system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchanger
* piping and fittings
* restriction orifice
* strainer
* tank
* valve 2.3B.4.5.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.3.4.B.5 and USAR Sections 10.1 and 10.2.2.1 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in
 
accordance with the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.4.5.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the moisture separator and reheater system components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the moisture separator
 
and reheater system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).
2-2472.3B.4.6  NMP2 Extraction Steam and Feedwater Heater Drain System 2.3B.4.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.B.6, the applicant described the extraction steam and feedwater heater drain system. The extraction steam and feedwater heater drain system is designed to heat the reactor feedwater to meet reactor inlet requi rements. The system also provides heating steam to the building heating intermediate heat exchangers and clean steam reboilers. The
 
low-pressure section of the system consists of three independent strings of feedwater heaters, each containing two drain coolers and five closed feedwater heaters. The high-pressure section
 
consists of three strings each with one closed feedwater heater.
The failure of NSR SSCs in the extraction st eam and feedwater heater drain system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.B.6-1, the applicant identified the following extraction steam and feedwater heater drain system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchangers
* piping and fittings
* pumps
* tanks
* valves
 
2.3B.4.6.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.B.6 and USAR Section 10.4.10 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.4.6.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant 2-248 had adequately identified the extraction steam and feedwater heater drain system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the extraction
 
steam and feedwater heater drain system component s that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.3B.4.7  NMP2 Turbine Main System 2.3B.4.7.1  Summary of Technical Information in the Amended Application In ALRA Section 2.3.4.B.7, the applicant described the turbine main system. The turbine main system converts the thermal energy contained in the steam from the reactor into electrical energy. The turbine is a tandem-compound, single-stage reheat unit with 38-inch last-stage, low-pressure buckets. It consists of a double-flow, high-pressure turbine and three double-flow, low-pressure turbines.
The turbine main system consists of multiple subsystems including the main turbine system, turbine electric hydraulic oil and controls system, turbine generator gland seal and exhaust
 
steam system, turbine generator lube oil syst em, turning gear and seal system, turbine generator oil conditioner and storage system, turbine main alarms and trips system, turbine
 
main lube oil system, turbine main supervisory instrumentation system, and the turbine plant equipment vents system. Of t hese systems the turbine generator gland seal and exhaust steam system and the turbine electric hydraulic oil and controls system, specifically the turbine overspeed trip system, are in scope for licens e renewal. The turbine gland sealing system is designed to provide clean sealing steam for the turbine shaft and turbine steam control valves
 
and to exhaust air drawn into the system to the stack. The sealing steam prevents steam leakage out through the high-pressure turbine shaft and turbine steam control valves (i.e., stop
 
valves, control valves, bypass valves, and co mbined intermediate valves) and prevents air in-leakage through the low-pressure turbine shaft. The turbine generator has an emergency trip
 
system which will close the main stop valves, control valves, and low-pressure turbine combined
 
intermediate valves upon receipt of various protective signals, including a mechanical (110
 
percent) or electrical (112 percent) overspeed trip signal. These setpoints prevent the turbine
 
rotor from exceeding the maximum transient speed of 120 percent (design overspeed) of rated
 
turbine speed.
The failure of NSR SSCs in the turbine main system could potentially prevent the satisfactory accomplishment of an SR function.
The intended function within the scope of license renewal is to maintain mechanical and structural integrity to prevent spatial interactions.
In ALRA Table 2.3.4.B.7-1, the applicant identified the following turbine main system component types that are within the scope of license renewal and subject to an AMR:
* bolting
* heat exchanger
* piping and fittings
* restriction orifice
* tank
* valves 2-249 2.3B.4.7.2  Staff Evaluation The staff reviewed ALRA Section 2.3.4.B.7 and USAR Section 10 using the evaluation methodology described in SER Section 2.3. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.3.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.3B.4.7.3  Conclusion
 
The staff reviewed the ALRA to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions were identified. In
 
addition, the staff performed a review to determine whether any components that should be
 
subject to an AMR had not been identified by the applicant. No omissions were identified. On
 
the basis of its review, the staff concludes that there is reasonable assurance that the applicant
 
had adequately identified the turbine main system components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and the turbine main system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
 
===2.4 Scoping===
and Screening Results:
Structures and Component Supports This section documents the staff's review of the applicant's scoping and screening results for structures and component supports. Specifically, this section discusses the following structures, component supports, and commodities:
* NMP1 structures
* NMP2 structures
* NMPNS structural commodities In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant identified and listed passive, long-lived SCs that are within the scope of license renewal and subject to an AMR. To
 
verify that the applicant properly implemented it s methodology, the staff focused its review on the implementation results. This approach allowed the staff to confirm that there were no
 
omissions of structures and components that meet the scoping criteria and are subject to an
 
AMR.Staff Evaluation Methodology. The staff's evaluation of the information provided in the ALRA was performed in the same manner for all structures, components, and commodities. The
 
objective of the review was to determine if the components and supporting structures for a
 
specific structure, component, or commodity that appeared to meet the scoping criteria specified in 10 CFR Part 54 were identified by the applicant as within the scope of license
 
renewal in accordance with 10 CFR 54.4. Similarly, the staff evaluated the applicant's screening 2-250 results to verify that all long-lived, passive components were subject to an AMR in accordance with 10 CFR 54.21(a)(1).
Scoping. To perform its evaluation, the staff reviewed the applicable ALRA section and associated component drawings, focusing its review on components that had not been identified
 
as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the NMP1 UFSAR and NMP2 USAR, for each structure, component, and commodity
 
to determine if the applicant had omitted components with intended functions delineated under
 
10 CFR 54.4(a) from the scope of license renewal. The staff also reviewed the licensing basis
 
documents to determine if all intended functions delineated under 10 CFR 54.4(a) were
 
specified in the ALRA. If omissions were identified, the staff requested additional information to
 
resolve the discrepancies.
Screening. Once the staff completed its review of the scoping results, the staff evaluated the applicant's screening results. For those structures, components, and commodities with intended
 
functions, the staff sought to determine (1) if the functions are performed with moving parts or a
 
change in configuration or properties or (2) if they are subject to replacement based on a
 
qualified life or specified time period as described in 10 CFR 54.21(a)(1). For those that did not
 
meet either of these criteria, the staff sought to confirm that these structures, components, and
 
commodities were subject to an AMR as required by 10 CFR 54.21(a)(1). If discrepancies were
 
identified, the staff requested additional information to resolve them.
2.4A  NMP1 Structures In ALRA Section 2.4.A, the applicant identified the NMP1 structures that are subject to an AMR
 
for license renewal.
The applicant described the supporting systems and structures for the structures in the following sections of the ALRA:
* 2.4.A.1NMP1 primary containment structure
* 2.4.A.2NMP1 reactor building
* 2.4.A.3NMP1 essential yard structures
* 2.4.A.4NMP1 fuel handling system
* 2.4.A.5NMP1 material handling system
* 2.4.A.6NMP1 offgas building
* 2.4.A.7NMP1 personnel/equipment access system
* 2.4.A.8NMP1 radwaste solidification and storage building
* 2.4.A.9NMP1 screen and pump house building
* 2.4.A.10NMP1 turbine building
* 2.4.A.11NMP1 vent stack
* 2.4.A.12NMP1 waste disposal building The staff's review findings regarding ALRA Sections 2.4.A.1 through 2.4.A.12 are presented in SER Sections 2.4A.1.1 through 2.4A.1.12 respectively.2.4A.1  NMP1 Primary Containment Structure 2.4A.1.1  Summary of Technical Information in the Amended Application 2-251 In ALRA Section 2.4.A.1, the applicant described the primary containment structure (PCS). The PCS is a seismic Class I structure. The primary containment is a Mark I design that consists of a
 
drywell, a suppression chamber in the shape of a torus, and a connecting vent system between the drywell and the suppression chamber. It also includes valves and piping associated with the
 
vacuum breaker system and the structural por tions of primary containment penetrations. The drywell is a steel pressure vessel in the shape of an inverted light bulb. The drywell is enclosed
 
in reinforced concrete for shielding purposes. The stiffened pressure suppression chamber is a
 
steel pressure vessel in the shape of a torus located below and encircling the drywell. The PCS
 
is part of a multibarrier system with a primary barrier consisting of the primary containment with
 
its pressure suppression system and a secondary barrier consisting of the RB. The PCS
 
contains the released steam in the event of the design basis LOCA to limit the release to the RB
 
of fission products associated with this accident. The PCS is an enclosure for the RPV, the
 
reactor recirculation system, and other branch connections of the reactor coolant pressure
 
boundary.The PCS contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the PCS could potentially prevent the satisfactory
 
accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides shielding against high energy line breaks
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.1-1, the applicant identified the following PCS component types that are within the scope of license renewal and subject to an AMR:
* beam seats
* bearing plates
* concrete & grout
* containment penetrations (electrical)
* containment penetrations (instrument)
* containment penetrations (mechanical)
* downcomer tie straps
* drywell
* drywell coating
* drywell equipment hatch 2-252
* drywell emergency airlock
* drywell floor
* drywell floor seal
* drywell head
* drywell head closure bolts
* drywell head manway
* drywell jet deflector
* drywell personnel airlock
* drywell ring girder
* drywell stabilizer hatches
* embedded structural plates
* expansion joints (mechanical)
* expansion/grouted anchors
* moisture barrier
* primary containment bellows
* primary containment sump
* reactor pedestal
* reactor pedestal anchor bolts
* reactor shield wall
* reactor stabilizers
* refueling seal platform
* refueling seal platform bellows
* refueling seal platform covers
* seals and gaskets
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines
* torus
* torus access manhole fasteners
* torus access manholes
* vacuum breaker small bore piping
* vacuum relief piping
* vacuum relief valves
* vent header deflector
* vent header supports 2.4A.1.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.1 and the UFSAR. The staff's review, using the evaluation methodology described in SER Section 2.4, was conducted in accordance with the
 
guidance described in SRP-LR Section 2.4, "Scoping and Screening Results: Structures."
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant 2-253 had not omitted any passive and long-lived components that should be 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.A.1 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 2.4A-1, dated December 9, 2004, the staff requested that the applicant identify the location in the LRA where the following specific components that may perform SR functions per
 
10 CFR 50.54(a)(1) are addressed:  (a)reactor vessel to biological shield stabilizers  (b)biological shield to containment stabilizer (c)RPV male stabilizer attached to outside of drywell shell (d)RPV female stabilizer and anchor rods (also referred to as GIB) embedded in reactor building concrete wall  (e)biological shield wall and anchor bolts (f)reactor vessel support skirt and anchor bolts (g)reactor vessel support ring girder and anchor bolts and reactor vessel support pedestal (h)drywell internal steel shear ring (i)drywell steel support skirt and anchor bolts (j)drywell head closure bolts and double gasket, tongue-and-groove seal arrangement.
In its response by letter dated January 10, 2005, the applicant provided the specific information requested. The staff reviewed the response and found the information acceptable because the
 
applicant had included the structures and components and their intended functions adequately
 
in LRA Table 2.4.A.1-1.
In follow-up to RAI 2.4.A-1 dated October 11, 2005, the staff noted that leakage through the refueling seals located at the top of the drywell potentially exposes the carbon steel drywell shell
 
inner and outer surfaces to loss of material due to corrosion. This concern was particularly
 
applicable to the embedded portion of the drywell shell. The staff pointed out that the corrosion
 
detected on the outer shell surface in the sand pocket region in a number of Mark I steel
 
containments has been attributed to leakage past the drywell-to-reactor building refueling seal
 
coupled with clogging of the sand pocket drains. Leakage into the drywell past the reactor
 
vessel-to-drywell refueling seal creates the potential for corrosion of the inaccessible portion of
 
the inner surface of the drywell shell embedded in the concrete floor. Therefore, the staff
 
requested that the applicant clarify whether all components of the drywell to the refueling cavity
 
seal are within the scope of license renewal.
The staff further noted that from the information in ALRA Table 2.4.A.1-1 it was not clear (1) whether the refueling seals have been included in the license renewal scope or (2) if included
 
how aging management is addressed. Therefore, in RAI 2.4.A-1 dated October 11, 2005, the
 
staff also requested that the applicant provide the following information:
2-254
* Verification that the refueling seals are included in the license renewal scope or a detailed explanation for their exclusion.
* A detailed description of the plant-specific operating experience for the refueling seals including incidences of degradation, method of detection, root cause, corrective actions, and current inspection procedures.
* A detailed description of the scoping, screening, and aging management review for the refueling seals.
* The AMPs credited to manage aging of the refueling seals.
In its response by letter dated October 28, 2005, the applicant stated that the NMP1 refueling seals are within the scope of license renewal and subject to an AMR. The applicant described in
 
detail the six components of the refueling seal. Two of the components are stainless steel
 
bellows, one between the liner and the drywell shell and the other between the refueling seal
 
platform and the reactor vessel flange. The third component is the carbon steel refueling seal
 
platform, the fourth is the aluminum refueling seal platform cover, the fifth is the gaskets
 
between the covers and the platform, and the sixth is the stainless steel bolting that fastens the
 
platform covers to the platform proper. The applicant stated that all of these components are
 
within the scope of license renewal except the gaskets. The gaskets between the cover pieces
 
and the platform are within scope of license renewal but not subject to an AMR because new
 
gaskets are used during each refueling outage.
The applicant also explained that the components within the scope of license renewal and subject to an AMR are addressed in the ALRA Table 2.4.A.1-1 as follows: (1) the bellows are
 
included as the component "Refueling Seal Platform Bellows," (2) the refueling seal platform is
 
included with the component "Refueling Seal Platform" as the component type "Structural Steel (Carbon Low Alloy Steel) in Air," (3) the refueling seal platform covers are included as the
 
component "Refueling Seal Platform Covers," and (4) the bolting is included with the
 
Component "Refueling Seal Platform" as the component type "Fasteners (Wrought Austenitic
 
Stainless Steel) in Air." The indication in the ALRA that the bolting component type is
 
"Fasteners (Carbon or Low Alloy Steel) in Air" is an error. The bolting is stainless steel. The
 
environment is air because these components are in an air environment during normal operation. They are wetted only during refueling operations.
As requested in the RAI, the applicant stated that there had been no plant operating experience indicating leakage from the refueling seals at NMPNS. Furthermore, any corrosion of the drywell
 
in visible areas would be detected and mitigated at each refueling outage when the refueling
 
cavity is filled. Any leakage would be observed prior to settling in an inaccessible area of the
 
drywell.Additionally, the applicant noted that the NRC staff had requested that utilities mitigate and/or identify potential degradation of Mark I containments in Information Notice IN 86-99 and Generic
 
Letter GL 87-05. Such degradation occurred at Oyster Creek Generating Station as a result of
 
water intrusion in the air gap from leakage past the refueling seal and subsequent wetting of the
 
sand cushion at the bottom of the air gap. NMPNS conducted several investigations and
 
inspections which determined that water intrusion into the NMP1 sand cushion had not occurred
 
and that periodic examination of the sand cushion area drain lines is not warranted.
2-255 Historically, the applicant's management of this area has been vigilant in detecting water leakage. The applicant has found no leakage from this area and stated in the response that
 
NMPNS plans to manage the components of the refueling seal during the period of extended
 
operation. The staff found the applicant's approach of managing the reactor cavity to drywell
 
refueling seal acceptable. Therefore, the staff's concern described in RAI 2.4.A-1 is resolved.
2.4A.1.1.3  Conclusion
 
The staff reviewed the ALRA, RAI responses, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the PCS
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the PCS components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.2  NMP1 Reactor Building 2.4A.1.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.2, the applicant described the RB. The RB is a seismic Class I structure which encloses the PCS pressure suppression system. The RB is a multi-floored structure, comprising a substantial reinforced concrete substructure with reinforced concrete walls
 
extending up to the operating floor level and a steel framed superstructure above the operating
 
floor level. Airlocks are provided on the areas of the building where access doors are provided.
 
The reinforced concrete building substructure is founded on bedrock. Precast concrete panels
 
and uninsulated metal wall panels are applied to the exterior of the reinforced concrete walls of
 
the reactor building, except around the airlocks. However, these panels do not form a part of the
 
building support. Metal wall panels and roofing above the operating floor are leak tight. This
 
structure provides secondary containment when t he pressure suppression system is in service, and primary containment during refueling, maintenance, or testing, when the PCS is open or not
 
required. The RB houses the refueling and reactor servicing equipment, fresh and spent fuel
 
storage facilities, and other reactor auxiliary or service equipment.
The RB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the RB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier 2-256
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides over-pressure protection
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.2-1, the applicant identified the following RB component types that are within the scope of license renewal and subject to an AMR:
* blowout panels
* compressible joints
* concrete & grout
* concrete columns
* concrete curbs
* concrete floors
* concrete slabs
* concrete walls
* doors and framing/hardware
* drywell shield wall
* drywell shield wall sleeves
* electrical and air duct sleeves
* embedded structural plates
* expansion/grouted anchors
* fuel pool gate gaskets
* fuel pool gates
* fuel transfer canal
* fuel transfer canal liner
* hatch cover seals
* hatch covers
* main steam tunnel
* masonry walls
* penetration seal clamps
* penetration seals
* penetration sleeves
* precast concrete panels
* RB foundation fill concrete
* RB foundation mat
* RB metal siding
* RB overhead crane rail clips and fasteners
* RB overhead crane rail crane girder
* RB sumps
* reactor head cavity
* reactor head cavity liner
* reactor internal storage pit 2-257
* reactor internal storage pit liner
* reactor shield plug liners
* reactor shield plugs
* refueling platform rubber seal
* refueling platform track anchor bolts
* refueling platform track and embedded plate
* removable masonry wall anchors
* removable masonry wall framing
* rock anchors
* sealing compounds
* seals and gaskets
* spent fuel storage pool
* spent fuel storage pool liner
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines
* sump liner fasteners (RB and auxiliary bay)
* torus ring girder
* torus saddle anchors
* torus support column sway rod turnbuckles
* torus support column sway rods
* torus support columns
* torus support foundation 2.4A.1.2.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.2 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be 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.A.2 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.A-4 dated December 9, 2004, the staff stated that from LRA Table 2.4.A.2-1 it was not clear whether the entire enclosure building of the BWR reactor building with steel
 
superstructure (including metal structure, metal panels) is within the scope of license renewal.
 
RAI 2.4A.2-4 requested that the applicant clarify the extent to which items of the enclosure
 
building are within the scope of license renewal and indicate the locations where its components
 
are included in AMR in Table 3.5.2.A-2.
2-258 In its response by letter dated January 10, 2005, the applicant stated:
The reactor building (RB) is a concrete structure up to the refueling floor elevation. Above this elevation, it is a steel-framed structure with metal wall and
 
panels. The concrete structure of the RB is included under the component type
 
"Concrete in Air" in LRA Tables 2.4.A.2-1 and 3.5.2.A-2. The steel structural
 
members above the refueling floor are included under the component type
 
"Structural Steel (Carbon and Low Alloy Steel) in Air" in LRA Tables 2.4.A.2-1
 
and 3.5.2.A-2. The metal panels are included under the component type Siding in
 
Air" in LRA Table 2.4.A.2-1 and under the component type "Metal Siding in Air" in
 
LRA Table 3.5.2.A-2. The concrete, steel, and metal siding are all within the
 
scope of LR. The last sentence on LRA page 2.4-5 states: "The entire RB is
 
made up of components that require AMR." This was meant to indicate that all of
 
the components that comprise the RB are within the scope of LR and subject to
 
AMR.The staff found the applicant's explanation adequate. Therefore, the staff's concern described in RAI 2.4.A-4 is resolved.
2.4A.1.2.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the RB
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the RB components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.3  NMP1 Essential Yard Structures 2.4A.1.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.3, the applicant described the essential yard structures (EYS). The EYS include the seismic Class I and Class II essential yard buildings, plus structures and civil
 
foundation supports for SR electrical or mechanical equipment items located within the yard.
 
The yard is defined as the owner controlled outside areas surrounding the major NMP1 plant
 
buildings, both inside and outside the NMPNS protected area. The earthen structures, which
 
provide flood protection to the site, are included in the EYS. Included in the EYS are the
 
administration building and the administration building extension and the radwaste pipe tunnel
 
extension. The administration building extension is a Class II structure and is seismically
 
designed due to its proximity to the NMP1 diesel generator rooms. Also included are SR tank
 
foundations. There are no class 1E ductlines or manholes in the yard at NMP1. The EYS also
 
include the structures that support the equipment and high voltage lines in the 115KV
 
switchyard for SBO. The SBO components are addressed in the 115KV AC electrical
 
distribution system.
2-259 The EYS contain SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the EYS could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the EYS perform functions that support fire
 
protection and SBO.
The intended functions within the scope of license renewal include the following:
* provides rated fire barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.3-1, the applicant identified the following EYS component types that are within the scope of license renewal and subject to an AMR:
* administration building concrete columns
* administration building concrete floors
* administration building concrete foundation
* administration building concrete walls
* administration building structural beams
* administration building structural columns
* administration building structural fasteners
* concrete encasement of ductlines
* emergency diesel fuel oil tank foundations
* nitrogen tank foundations
* nitrogen tank protective structure
* pipe tunnels
* SBO equipment foundations
* structural polymer bearing pad 2.4A.1.3.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.3 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-260 2.4A.1.3.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the EYS components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the EYS components
 
that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.4  NMP1 Fuel Handling System 2.4A.1.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.4, the applicant described the fuel handling system. The fuel handling system involves those components used to move fuel from the time of receipt of new fuel to the
 
storage of spent fuel in the spent fuel storage pool. Components that are evaluated in the fuel
 
handling system include the refueling platform, fuel preparation machines, and spent fuel racks.
 
Although the reactor building crane handles fuel, it is analyzed in the material handling system.
The fuel handling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the fuel handling system could
 
potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.4-1, the applicant identified the following fuel handling system component types that are within the scope of license renewal and subject to an AMR:
* fuel preparation machines
* spent fuel rack fasteners
* spent fuel racks 2.4A.1.4.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.4 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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 2-261 had identified as being within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4A.1.4.3  Conclusion
 
The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the fuel handling system
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the fuel handling system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).2.4A.1.5  NMP1 Material Handling System 2.4A.1.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.5, the applicant described the material handling system. The material handling system consists of overhead traveli ng cranes, monorail hoists, platform cranes, jib cranes, and associated mechanical and electrical components. For license renewal purposes, the crane girders and rails are included in the structural steel asset of the structure in which the
 
crane is located.
The material handling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the material handling system could
 
potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.5-1, the applicant identified the following material handling system component types that are within the scope of license renewal and subject to an AMR:
* decontamination area monorail hoist
* reactor building crane
* reactor building jib crane
* screen house building crane
* screen house building gate hoists
* turbine building 30 ton capacity crane
* turbine building crane
* turbine building monorail hoist 2-262 2.4A.1.5.2  Staff Evaluation The staff reviewed ALRA Section 2.4.A.5 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be 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.A.5 identified an area in which additional information was necessary to complete review of the applicant's scoping and screening results. The applicant
 
responded to the staff's RAI as discussed below.
In RAI 2.4.A-5 dated December 9, 2004, the staff stated that LRA Section 2.4.A.5 indicates the only components that require AMR are the screenhouse gate hoists and the 125-ton capacity
 
RB crane. No rail or and crane associated components appear to be included within the scope
 
requiring AMR. Therefore, the staff requested that the applicant clarify the treatment of cranes, rails, and hoists in the scoping and screening and in the AMR. RAI 2.4A.5-5 requested that the
 
applicant submit the following information:  a.A list of all cranes, hoists, rails, and associated components in the scope of license renewal. b.A list of all cranes, hoists, rails, and associated components requiring aging management review (i.e., passive, long-lived). c.A list of all cranes, hoists, rails, and associated components requiring aging management and/or TLAA.
In its response by letter dated January 10, 2005, the applicant stated:
  (a)The NMP1 125-ton capacity RB overhead crane and the screenhouse gate hoists are the only cranes/hoists that meet 10 CFR 54.4(a) criteria for inclusion within the scope of
 
LR. These components perform safety-related intended functions. LRA Section 2.4.A.5
 
includes the crane rails and girders as part of the structural steel component type for the
 
building in which the crane is located. Other associated components, annunciators, circuit breakers, switches, motors, relays, resistors, and transformers, are classified as
 
active components and, therefore, are not subject to AMR.  (b)The list of components requiring AMR along with corresponding LRA table locations:    *125-ton RB Crane - Table 3.5.2.A-5
  *Screenhouse Gate Hoists - Table 3.5.2.A-5
  *125-ton RB Crane Girders and Rails - Table 3.5.2.A-2 under the component type "Structural Steel (Carbon and Low Alloy Steel) in Air" 2-263  *Screenhouse Gate Hoists Girders and Rails - Table 3.5.2.A-8 under the component type "Structural Steel (Carbon and Low Alloy Steel) in Air"  (c)LRA Section 2.4.A.5 and Table 2.4.A.5-1 list component types within the scope of license renewal and subject to AMR. Because the in-scope NMP1 cranes are
 
designated Service Class A ("Standby or Infrequent Service") by the Crane
 
Manufacturers Association of America none meet the fatigue analysis requirement for a
 
TLAA. The staff found the above applicant's response acceptable because it provides adequate information. Therefore, the staff's concern described in RAI 2.4A-5 is resolved.
2.4A.1.5.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the material
 
handling system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the material handling system components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).2.4A.1.6  NMP1 Offgas Building 2.4A.1.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.6, the applicant described the offgas building (OGB). The OGB is a seismic Class I structure. The OGB is located adjacent to the TB and the WDB. The OGB
 
substructure is a reinforced concrete structure and is founded on bedrock. The superstructure is
 
structural steel frame with exterior metal walls and masonry block. The interior walls of the
 
substructure are reinforced concrete and concrete block. The OGB contains the piping and
 
equipment associated with the condenser air removal and offgas system.
The OGB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the OGB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the OGB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides rated fire barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides structural and/or functional support to SR equipment 2-264 In ALRA Table 2.4.A.6-1, the applicant identified the following OGB component types that are within the scope of license renewal and subject to an AMR:
* building foundation
* concrete and grout
* concrete columns
* concrete floors
* concrete lean fill
* concrete walls
* doors and framing/hardware
* expansion/grouted anchors
* masonry wall fasteners
* masonry wall framing
* masonry walls
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines 2.4A.1.6.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.6 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4A.1.6.3  Conclusion
 
The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the OGB components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the OGB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.7  NMP1 Personnel/Equipment Access System 2.4A.1.7.1  Summary of Technical Information in the Amended Application 2-265 In ALRA Section 2.4.A.7, the applicant described the personnel/equipment access system. The personnel/equipment access system consists of doors, gates, and the electronic equipment that monitors their positions. The gates and electronic equipment are not in scope for license
 
renewal.The personnel/equipment access system contai ns SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the
 
personnel/equipment access system could potentia lly prevent the satisfactory accomplishment of an SR function. In addition, the personnel/
equipment access system performs functions that support fire protection.
All doors are addressed in the sections for the structures where the doors are located. There are no other components subject to an AMR for this system.
2.4A.1.7.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.7 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4A.1.7.3  Conclusion
 
The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the personnel/equipment
 
access system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the personnel/equipment access system components that are subject to
 
an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.8  NMP1 Radwaste Solidification and Storage Building 2.4A.1.8.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.8, the applicant described the radwaste solidification and storage building (RSSB). The RSSB is a seismic Class I structure located to the east of, and directly
 
adjacent to, the OGB and the WDB. The RSSB is a reinforced concrete structure. The
 
foundation mat is founded on bedrock. During normal operation, maintenance, and loading and
 
unloading operations, the structure provides sufficient environmental isolation.
2-266 The RSSB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RSSB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the RSSB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides rated fire barrier
* provides flood protection barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier In ALRA Table 2.4.A.8-1, the applicant identified the following RSSB component types that are within the scope of license renewal and subject to an AMR:
* concrete & grout
* concrete caissons
* concrete curbs
* concrete floors
* concrete slabs
* concrete walls
* doors and framing/hardware
* embedded structural plates
* masonry walls
* penetration sleeves
* pipe tunnels
* radwaste building foundation
* radwaste building sump
* roof hatch
* roof plug lifting pins
* seals and gaskets
* steel liner
* steel shield wall 2.4A.1.8.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.8 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had not omitted from the scope of license renewal any components with intended 2-267 functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4A.1.8.3  Conclusion
 
The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the RSSB components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the RSSB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.9  NMP1 Screen and Pump House Building 2.4A.1.9.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.9, the applicant described the screen and pump house (SPH) building.
The SPH building is a seismic Class I and Class II structure which is adjacent to the north wall
 
of the RB and TB. The Class II superstructure is framed structural steel supported on a Class I
 
reinforced concrete substructure that is founded on bedrock. The exterior wall is
 
internally-insulated precast concrete panels. The SPH building comprises channels for the flow
 
of very large quantities of raw lake water, gates, stop logs for control of the flow, racks, screens
 
for cleaning the water, and pumps.
The SPH building contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the SPH building could potentially prevent the
 
satisfactory accomplishment of an SR function. In addition, the SPH building performs functions
 
that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides rated fire barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides source of cooling water for plant shutdown
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.9-1, the applicant identified the following SPH building component types that are within the scope of license renewal and subject to an AMR:
2-268
* building foundation
* concrete and grout
* concrete curbs
* concrete floors
* concrete piers
* concrete slab
* concrete walls
* crane rails and girders
* doors and framing/hardware
* expansion/grouted anchors
* intake structure
* intake structure structural fasteners
* intake structure structural steel
* intake tunnel
* masonry walls
* miscellaneous structural steel
* structural beams
* structural columns
* structural fasteners
* wall shoring 2.4A.1.9.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.9 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be 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.A.9 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.A-7 dated December 9, 2004, the staff requested that the applicant confirm for the NMP1 screen and pump house that such items as hatches and plugs, structural steel
 
embedments, reinforced concrete foundation footings, grouted concrete, and water proofing
 
membrane materials are within the scope of license renewal and require AMR. For such items
 
within the scope of license renewal the staff requested that the applicant provide additional
 
information in the format of LRA Table 2.4.A.9-1. For such items not within the scope of license
 
renewal the applicant was asked to provide the basis for omission.
2-269 In its response by letter dated January 10, 2005, the applicant stated that the items listed in the RAI are within the scope of license renewal, subject to an AMR, and represented by the
 
component types listed in LRA Table 2.4.A.9-1:  (1)There are no "hatches" in the NMP1 Screen and Pump House.    (2)All doors are included under the component type "Door."
  (3)Plugs are concrete and included in the component type "Concrete in Air."
  (4)Embedded portions of structural steel embedments are integral with the concrete and included with the component type "Concrete in Air" or "Concrete in Raw Water"
 
depending on the location of the embedment.  (5)Structural steel exposed to atmosphere is included under the component type "Structural Steel (Carbon and Low Alloy Steel) in Air" or "Structural Steel (Carbon and Low Alloy
 
Steel) in Raw Water" depending on the location of the embedment.  (6)Reinforced concrete foundation footings are included in the component type "Concrete in Soil Above the Ground Water Table" (GWT) or "Concrete in Soil Below the GWT"
 
depending on the footing depth.  (7)Grouted concrete is not used at NMP1.
  (8)Structural concrete is included in the various concrete component types depending on environment.  (9)Waterproofing membranes are not included because they are applied as coatings.
NMPNS does not credit coatings to mitigate aging effects.
The staff found the above applicant's response complete and adequate. Therefore, the staff's concern described in RAI 2.4A.-7 is resolved.
2.4A.1.9.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the SPH building
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the SPH building components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.10  NMP1 Turbine Building 2.4A.1.10.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.10, the applicant described the TB. The TB is a Class II structure with integrated seismic Class I areas. The reinforced concrete turbine generator foundation pedestal
 
is isolated from the floors of the building to minimize transmission of vibration to the floors. The
 
reinforced concrete TB foundations are supported by concrete column piers founded on
 
bedrock 15 to 25 feet below grade. The TB superstructure consists of an enclosed structural 2-270 steel frame. The roof is covered with metal decking, insulation, and tar roofing material. Located within the TB are the generating area, the auxiliary equipment area, the feedwater heater area, the auxiliary extension building, and the control room.
The TB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the TB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the TB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides over-pressure protection
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.10-1, the applicant identified the following TB component types that are within the scope of license renewal and subject to an AMR:
* auxiliary control room concrete curbs
* auxiliary control room concrete floors
* auxiliary control room concrete walls
* auxiliary control room masonry walls
* beam seats
* bearing plates
* compressible joints and seals
* concrete and grout
* concrete columns
* concrete floors
* concrete slabs
* concrete walls
* control room concrete floors
* control room concrete walls
* control room metal partition wall
* control room structural beams
* control room structural columns 2-271
* control room structural fasteners
* control room/auxiliary control room penetration seals
* control room/auxiliary control room penetration sleeves
* diesel generator foundations
* diesel generator room ceiling
* diesel generator room concrete floors
* diesel generator room concrete slabs
* diesel generator room concrete walls
* diesel generator room protection panels
* diesel generator room 102 missile shield
* doors and framing/hardware
* embedded structural plates
* expansion/grouted anchors
* main steam tunnel
* monorail beams
* penetration sleeves
* removable concrete slabs
* removable masonry wall framing
* removable masonry walls
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, and mezzanines
* turbine building blowout panels
* turbine building foundation slab
* turbine building manhole cover and frame
* turbine building overhead crane rail and embedded plate
* turbine building overhead crane rail clips and fasteners
* turbine building sump liner fasteners
* turbine building sump liners
* turbine building sump sleeves
* turbine building sumps
* turbine support structure 2.4A.1.10.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.10 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-272 The staff's review of LRA Section 2.4.A.10 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.A-6 dated December 9, 2004, the staff stated that in some of the LRA Section 2.4.A tables the staff could not identify the insulation and insulation jacketing included in the license
 
renewal scope nor the specific subsets of insulation and insulation jacketing included in the LRA
 
Section 2.4.A tables. It was also unclear whether insulation and jacketing on the reactor coolant
 
system had been included. Insulation and jacketing are commodities that may perform SR
 
functions as per 10 CFR 50.54(a)(1). Therefore, the staff requested that the applicant:  a.Identify the structures and structural components within the scope of license renewal with insulation and/or insulation jacketing. b.List all insulation and insulation jacketing materials associated with such structures and structural components that require AMR and the AMR results for each. c.For insulation and insulation jacketing materials associated with such structures and structural components not requiring aging management, submit the technical basis for
 
this conclusion, including plant-specific operating experience. d.For insulation and insulation jacketing materials associated with such structures and structural components that require aging management indicate the applicable LRA
 
sections that identify the AMP(s) credited.
In its response by letter dated January 10, 2005, the applicant stated that NMP1 has no structures or structural components within the scope of LR with insulation or insulation
 
jacketing. Therefore, insulation was not included in any LRA Section 2.4.A table. The NMP1
 
design does not require insulation of structural steel and/or concrete according to CLB
 
documents including safety analyses and plant evaluations. The staff found this plant-specific
 
configuration-based response adequate. Therefore, the staff's concern described in RAI 2.4A-6
 
is resolved.
2.4A.1.10.3  Conclusion
 
The staff reviewed the ALRA, RAI response, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the TB
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the TB components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4A.1.11  NMP1 Vent Stack 2.4A.1.11.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.11, the applicant described the vent stack. The vent stack is a seismic Class I reinforced-concrete chimney, 350 feet high, located 100 feet east of the northeast corner 2-273 of the RB. The height of the stack and the velocity of discharge provide a high degree of dilution for station effluents. The vent stack's foundation is on a massive reinforced concrete base which
 
extends to bedrock. From this base, it rises through the turbine auxiliary building extension from which it is completely structurally isolated.
The vent stack contains SR components that are relied upon to remain functional during and following DBEs. In addition, the vent stack performs functions that support fire protection.
The intended functions within the scope of license renewal include the following:
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides path for release of filtered and unfiltered gaseous discharge
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.11-1, the applicant identified the following vent stack component types that are within the scope of license renewal and subject to an AMR:
* compressible joints and seals
* concrete chimney shell
* concrete floors
* vent duct framing
* vent stack foundation 2.4A.1.11.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.11 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4A.1.11.3  Conclusion
 
The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the vent stack components
 
that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the vent stack
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2-2742.4A.1.12  NMP1 Waste Disposal Building 2.4A.1.12.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.A.12, the applicant described the WDB. The WDB and WDB extension are seismic Class I structures located between and adjacent to the RSSB and the turbine auxiliary
 
extension building. The WDB and extension consist of reinforced concrete substructures with
 
steel framed superstructures from grade to their respective roof elevations. The interior walls of
 
the substructure are reinforced concrete. The superstructure walls are also reinforced concrete
 
or concrete masonry units. The reinforced concrete building substructure is founded on
 
bedrock.The WDB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the WDB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the WDB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.A.12-1, the applicant identified the following WDB component types that are within the scope of license renewal and subject to an AMR:
* building foundation
* compressible joints and seals
* concrete and grout
* concrete curbs
* concrete floors
* concrete sumps
* concrete walls
* doors and framing/hardware
* expansion/grouted anchors
* masonry fasteners
* masonry walls
* miscellaneous structural steel
* steel curbs
* steel sump liner
* steel troughs 2-275
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines 2.4A.1.12.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.4.A.12 and the UFSAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and UFSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4A.1.12.3  Conclusion
 
The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the WDB components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the WDB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4B  NMP2 Structures In ALRA Section 2.4.B, the applicant identified the NMP2 structures that are subject to an AMR
 
for license renewal.
The applicant described, in the ALRA, the following sections for supporting systems and structures for the NMP2 structures:
* 2.4.B.1NMP2 primary containment structure
* 2.4.B.2NMP2 reactor building
* 2.4.B.3NMP2 auxiliary service building
* 2.4.B.4NMP2 control room building
* 2.4.B.5NMP2 diesel generator building
* 2.4.B.6NMP2 essential yard structures
* 2.4.B.7NMP2 fuel handling system
* 2.4.B.8NMP2 main stack
* 2.4.B.9NMP2 material handling system
* 2.4.B.10NMP2 motor operated doors system
* 2.4.B.11NMP2 radwaste building 2-276
* 2.4.B.12NMP2 screenwell building
* 2.4.B.13NMP2 standby gas treatment building
* 2.4.B.14NMP2 turbine building The staff's review findings regarding the above ALRA Sections 2.4.B.1 through 2.4.B.14 are presented in SER Sections 2.4B.1 through 2.4B.14, respectively.2.4B.1  NMP2 Primary Containment Structure 2.4B.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.1, the applicant described the primary containment structure (PCS). The PCS is a seismic Category I structure consisting of a drywell chamber, located above a
 
suppression chamber, and a drywell floor, which separates the drywell chamber from the
 
suppression chamber. It also includes the structural portions of primary containment
 
penetrations. The PCS is supported on a 10-ft thick reinforced concrete mat, which also
 
supports the reactor building (RB). A series of 24-in diameter downcomer vent pipes penetrates
 
the drywell floor. The drywell is a steellined reinforced concrete vessel in the shape of a frustum
 
of two cones, closed by a dome with a torispherical head. The PCS contains a Mark II pressure
 
suppression system. The pressure suppression cham ber is a cylindrical stainless steel clad steel-lined reinforced concrete vessel located below the drywell. The PCS houses the RPV, the
 
reactor recirculation system, and other branch connections of the RCPB.
The PCS contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the PCS could potentially prevent the satisfactory
 
accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides shielding against high energy line breaks
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pipe whip restraint
* provides pressure retaining boundary
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.1-1, the applicant identified the following PCS component types that are within the scope of license renewal and subject to an AMR:
2-277
* beam seats
* bearing plates
* biological shield wall
* biological shield wall door radiation shields
* biological shield wall doors
* concrete & grout
* concrete slabs
* containment penetrations (electrical)
* containment penetrations (instrument)
* containment penetrations (mechanical)
* control rod drive removal hatch
* downcomers
* drywell
* drywell coating
* drywell emergency escape lock
* drywell equipment hatch
* drywell floor
* drywell floor concrete insulation
* drywell floor supplementary steel
* drywell head
* drywell head closure pins
* drywell head fasteners
* drywell head stainless steel elements
* drywell liner
* drywell personnel airlock
* embedded structural plates
* equipment hatch ring beam
* impingement and jet shielding
* inner refueling seal
* insulation support framing
* lubrite plate
* monorail beams
* pipe whip restraint fasteners
* pipe whip restraints
* precast concrete beams
* radiation shields
* reactor pedestal
* reactor pedestal anchor bolts
* reactor stabilizers
* refueling bulkhead
* sealing compounds
* seals and gaskets
* star truss
* structural beams
* structural columns
* structural fasteners
* structural girders
* structural insulation liner
* structural plates 2-278
* structural steel: platforms, stairways, mezzanines, removable curbs
* suppression chamber seal
* suppression pool
* suppression pool access hatches
* suppression pool liner
* water level indicator shields 2.4B.1.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.1 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The staff's review of the original LRA Section 2.4.B.1 identified areas in which additional information was necessary to complete review of the applicant's scoping and screening results.
 
The applicant responded to the staff's RAIs as discussed below.
In RAI 2.4.B-1 dated December 9, 2004, the staff stated that the NMP2 PCS encloses the reactor vessel and such structures as the biological shield wall, concrete pedestal, and the
 
barrier floor between the drywell and the suppression chamber. The original LRA
 
Table 2.4.B.1-1 does not include these structures in the scope of license renewal though they
 
perform SR functions per 10 CFR 50.54(a)(1). Therefore, the staff requested, if they were not
 
included by oversight, that the applicant describe its scoping and AMR or indicate their location
 
in the LRA if somewhere else. The staff further requested that, if omitted from the scope of
 
license renewal, the applicant provide the basis for omitting these items.
The applicant responded by letter dated January 10, 2005, and stated that the components listed in the staff RAI are within the scope of license renewal and are subject to AMR, they are
 
included in the original LRA Table 2.4.B.1-1. Since the structures in question are comprised of
 
multiple materials, they have been captured in the LRA Table 2.4.B.1-1 as a function of their
 
materials of construction intead of their functional names. This information has been
 
incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the staff found the above response acceptable because the applicant correctly identified these structures and components within the scope of license
 
renewal and included them in ALRA Table 2.4.B.1-1. Therefore, the staff's concern described in
 
RAI 2.4.B-1 is resolved.
In RAI 2.4.B-2 dated December 9, 2004, the staff noted that the Group 2 structures defined in GALL Report Chapter III include the BWR RB with steel superstructure (enclosure building) and
 
should be within the scope of license renewal. LRA Table 2.4.B.1-1 was unclear whether the 2-279 entire enclosure building (including the concrete structure, metal panels) is within the scope of license renewal. The staff requested that the applicant clarify the extent to which the enclosure
 
building is within the scope of license renewal and the locations where its components are
 
included in AMR in Table 3.5.2.B-2. The applicant's response by letter dated January 10, 2005, has been incorporated in the ALRA as discussed below.
In its ALRA dated July 14, 2005, the applicant included the essential components of the enclosure building in ALRA Table 2.4.B.1-1. Therefore, the staff's concern described in
 
RAI 2.4.B-2 is resolved.
2.4B.1.3  Conclusion The staff reviewed the ALRA, RAI responses, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the PCS
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the PCS components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4B.2  NMP2 Reactor Building 2.4B.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.2, the applicant described the RB. The RB is a seismic Category I structure that encloses the PCS. The RB wall is a reinforced concrete cylinder with varying wall
 
thickness, extending from the top of the mat to the polar crane level. The wall from the crane rail
 
elevation to the roof is steel framing with insulated metal siding. The metal siding panels have
 
sealed joints to minimize air leakage. The RB, including the auxiliary bays, is founded on a
 
rock-bearing, reinforced concrete mat. The mat acts to support the RB, auxiliary bays, and the
 
primary containment. The auxiliary bays are rigi dly attached to the RB and considered part of the secondary containment structure. The RB houses the refueling and reactor servicing
 
equipment, new and spent fuel storage facilitie s, and other reactor auxiliary or service equipment, including the RCIC system, RWCU sy stem, standby liquid control system, CRD system equipment, core standby cooling syst ems, RHR systems, and electrical equipment components. Included within the RB for the purposes of license renewal are the secondary
 
containment, the north and south auxiliary bays, and the main steam tunnel east of the turbine
 
building. Civil/structural components from the fuel nuclear transfer system and the vents -
turbine and RB system are also evaluated as part of the RB.
The RB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the RB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow 2-280
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides shielding against high energy line breaks
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pipe whip restraint
* provides over-pressure protection
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.2-1, the applicant identified the following RB component types that are within the scope of license renewal and subject to an AMR:
* auxiliary bay foundations
* auxiliary bay sumps
* beam pockets
* bearing plates
* cask pit cavity
* cask pit cavity liner
* cask washdown pit
* cask washdown pit liner
* compressible joints and seals
* concrete and grout
* concrete columns
* concrete curbs
* concrete floors
* concrete lean fill
* concrete slabs
* concrete walls
* doors and framing/hardware
* embedded structural plates
* expansion/grouted anchors
* fuel pool canal
* fuel pool canal liner
* fuel pool gates
* fuel transfer shielding bridge
* main steam tunnel
* miscellaneous structural steel framing
* monorail beams 2-281
* overpressurization vent panel fasteners
* overpressurization vent panels
* penetration seal clamps
* penetration seals
* penetration sleeves
* pipe whip restraint fasteners
* pipe whip restraints
* porous concrete pipe
* radiation shields
* rail track and support beams
* reactor building foundation mat
* reactor building metal siding
* reactor building metal siding fasteners
* reactor building polar crane rail and embedded plate
* reactor building polar crane rail clips and fasteners
* reactor building sumps
* reactor head cavity pit
* reactor head cavity pit liner
* reactor head cavity plug liners
* reactor head cavity plugs
* reactor internal storage pool
* reactor internal storage pool liner
* refueling bridge crane rail and embedded plate
* refueling bridge crane rail clips and fasteners
* refueling canal/dryer-separator canal plug liners
* refueling canal/dryer-separator canal plugs
* removable concrete slabs
* removable masonry wall anchors
* removable masonry wall framing
* sealing compounds
* seals and gaskets
* spent fuel pool girders
* spent fuel pool structural steel framing
* spent fuel storage pool
* spent fuel storage pool liner
* spent fuel storage pool structural fasteners
* structural beams
* structural columns
* structural fasteners
* structural plates
* structural steel: platforms, stairways, mezzanines
* sump liner fasteners (reactor building and auxiliary bay)
* sump liners (reactor building and auxiliary bay) 2.4B.2.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.2 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
2-282 In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be 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.B.2 identified areas in which additional information was necessary to complete evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.4.B-3 dated December 9, 2004, the staff stated that it was not clear from LRA Table 2.4.B.2-1 whether the entire enclosure building (including the steel framing, metal siding, sealer materials, the overhead crane, and its railing) is within the scope of license renewal.
 
Therefore, the staff requested that the applicant clarify the extent to which items of the
 
enclosure building above the operating floor are within the scope of license renewal and
 
describe in the format of LRA Table 2.4.B.2-1 scoping and AMR for the applicable components.
In its response by letter dated January 10, 2005, the applicant stated that the RB is a concrete structure up to the refueling floor elevation and above this elevation a steel-framed structure
 
with metal wall panels. The steel framing members above the refueling floor are included in LRA
 
Table 2.4.B.2-1 in the component type "Structural Steel (Carbon and Low Alloy Steel) in Air."
 
The metal panels are included in LRA Table 2.4.B.2-1 in the component type "Metal Siding in
 
Air." Sealer materials are included in the component type "Polymer in Air" in LRA
 
Table 2.4.B.2-1. The RB overhead crane is included in LRA Table 2.4.B.9-1 as the component
 
type "Polar Crane." The crane rails are included in LRA Table 2.4.B.2-1 in the component type
 
"Structural Steel (Carbon and Low Alloy Steel) in Air." The applicant stated that these
 
components and component types are within the scope of LR and subject to AMR. The
 
applicant also pointed it out that the last sentence on LRA page 2.4-28 states: "The entire RB is
 
made up of components that require an AMR," indicating that all components that comprise the
 
RB are within the scope of license renewal and subject to AMR.
The staff found the applicant's response adequate and acceptable and its concern described in RAI 2.4B.2-3 is resolved.
In RAI 2.4.B-6 dated December 9, 2004, the staff stated that it could not identify from some of the tables of LRA Section 2.4.B the insulation and insulation jacketing included within the scope
 
of license renewal nor the specific subsets of insulation and insulation jacketing included in the
 
Section 2.4.B tables. It was also unclear whether insulation and jacketing on the reactor coolant
 
system had been included. Therefore, the staff requested that the applicant:
* Identify the structures and structural components within the scope of license renewal with insulation and/or insulation jacketing.
* List all insulation and insulation jacketing materials associated with such structures and structural components that require aging management review and the results of aging
 
management review for each.
2-283
* For insulation and insulation jacketing materials associated with such structures and structural components that do not require aging management submit the technical basis
 
for this omission including plant-specific operating experience.
* For insulation and insulation jacketing materials associated with such structures and structural components that require aging management indicate the LRA sections that
 
identify the AMPs credited to manage aging.
The applicant responded that NMP2 has no structures or structural components within the scope of license renewal with insulation and/or insulation jacketing. Therefore, the applicant did
 
not include insulation in any LRA Section 2.4.B table. The NMP2 design does not require
 
insulation of structural steel or concrete according to current licensing basis documents
 
including safety analyses and plant evaluations.
Since NMP2 has no structures or structural components within the scope of license renewal with insulation and/or insulation jacketing, the staff found the applicant's response acceptable.
 
Therefore, the staff's concern described in RAI 2.4.B-6 is resolved.
2.4B.2.3  Conclusion The staff reviewed the ALRA, RAI responses, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the RB
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the RB components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4B.3  NMP2 Auxiliary Service Building 2.4B.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.3, the applicant described the auxiliary service building (ASB). The ASB is a reinforced concrete and steel-framed structure. The ASB is surrounded by the RB, TB, and
 
CRB. The ASB below elevation 261 ft is classified as seismic Category I. The basement floor is
 
a reinforced concrete slab poured over electrical tunnels. The floor at elevation 261 ft is a
 
concrete slab on steel deck supported by structural steel. The ASB contains the HVAC room, instrument calibration facility, and decontamination and shower facilities for personnel.
The ASB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the ASB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the ASB performs functions that support fire
 
protection.
2-284 The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.3-1, the applicant identified the following ASB component types that are within the scope of license renewal and subject to an AMR:
* ASB foundation
* compressible joints and seals
* concrete & grout
* concrete curbs
* concrete floors
* concrete slabs
* concrete walls
* doors and framing/hardware
* penetration seals
* penetration sleeves
* removable concrete slabs
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines 2.4B.3.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.3 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-285 2.4B.3.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the ASB components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the ASB components
 
that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4B.4  NMP2 Control Room Building 2.4B.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.4, the applicant described the control room building (CRB). The CRB is a seismic Category I structure. It is a five-story reinforced concrete and steel structure. The
 
exterior walls and roof are constructed of reinforced concrete. The interior floors are concrete
 
decking supported by steel framing. The building is founded on bedrock and is supported by a
 
reinforced concrete mat. The upper four floors are reinforced concrete slabs on steel deck
 
supported by structural steel. Underground concrete tunnels connect the CRB to the RB. The
 
CRB contains the control room, SR switchgear, batteries, and associated equipment.
The CRB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the CRB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the CRB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.4-1, the applicant identified the following CRB component types that are within the scope of license renewal and subject to an AMR:
2-286
* compressible joints and seals
* concrete and grout
* concrete columns
* concrete curbs
* concrete floors
* concrete lean fill
* concrete slabs
* concrete walls
* control room building foundation
* control room building sump
* doors and framing/hardware
* embedded structural plates
* expansion/grouted anchors
* miscellaneous structural steel
* penetration seal clamp
* penetration seals
* penetration sleeves
* removable concrete slabs
* sealing compounds
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines
* supplemental structural steel
* suspended seismic support framing
* tornado-proof steel duct
* ventilation duct framing 2.4B.4.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.4 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.4.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is 2-287 reasonable assurance that the applicant had adequately identified the CRB components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the CRB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4B.5  NMP2 Diesel Generator Building 2.4B.5.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.5, the applicant described the diesel generator building (DGB). The DGB is a seismic Category I reinforced concrete structure enclosing the three diesel generators (DGs) and their associated equipment. The DGs are supported on reinforced concrete
 
pedestals. The building is divided into three rooms separated by fire walls, each housing one
 
DG. Fuel oil storage tanks are located below the building, with their fuel oil pumps housed in the
 
individual DG rooms. The DGB is founded on bedrock and supported by reinforced concrete
 
wall footings.
The DGB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the DGB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the DGB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.5-1, the applicant identified the following DGB component types that are within the scope of license renewal and subject to an AMR:
* compressible joints and seals
* concrete & grout
* concrete curbs
* concrete floors
* concrete slabs
* concrete walls
* concrete lean fill
* crane rails/girders
* diesel generator building foundation 2-288
* diesel generator pedestals
* diesel generator tank foundations and encasements
* doors and framing/hardware
* expansion/grouted anchors
* manhole cover and frame
* missile logs
* penetration seal clamp
* penetration seals
* penetration sleeves
* oil sump
* sealing compounds
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, mezzanines 2.4B.5.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.5 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.5.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the DGB components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the DGB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4B.6  NMP2 Essential Yard Structures 2.4B.6.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.6, the applicant described the EYS. The EYS include, but are not limited to, electrical, piping, and vent tunnels; manholes; underground duct banks; and earth berms and
 
ditches used for flood control. Seismic Category I electrical tunnels and piping tunnels contain
 
Category I systems and are constructed of reinforced concrete. Included in the essential yard 2-289 structures are all Class 1E duct banks and manholes. Earthen berms are located around the perimeter of the site to provide flood protection to the site. A stone-faced dike was constructed
 
along the shoreline. The dike prevents flooding of the plant from high lake water levels and the
 
effects of the probable maximum windstorm. The EYS also include the structures that support
 
the equipment and high voltage lines in the 115KV switchyard and Scriba substation for SBO.
 
The SBO components are evaluated in the switchyard system.
The EYS contain SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the EYS could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the EYS perform functions that support fire
 
protection and SBO.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides path for release of filtered and unfiltered gaseous discharge
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.6-1, the applicant identified the following EYS component types that are within the scope of license renewal and subject to an AMR:
* bus duct enclosure
* Class 1E manhole sumps
* compressible joints and seals
* concrete and grout
* concrete encasement of ductlines
* concrete lean fill
* doors and framing/hardware
* earthen berm
* electrical and radwaste tunnels removable concrete
* slabs
* electrical and radwaste tunnels steel beams
* electrical and radwaste tunnels steel columns
* electrical and radwaste tunnels
* embedded structural plates
* expansion/grouted anchors 2-290
* manhole covers and frames
* manholes
* penetration seal clamp
* penetration seals
* penetration sleeves
* pipe tunnel structural framing
* pipe tunnels
* pipe tunnel sumps
* revetment ditch
* sealing compounds
* service water tunnel
* service water tunnel removable concrete slabs
* service water valve pit
* service water valve pit removable concrete slabs
* service water valve pit sealants
* stone-faced dike
* structural fasteners
* structural steel: platforms, stairways, and mezzanines
* transformer area walls
* transformer curbs
* transformer foundation pads
* vent tunnel
* vent tunnel fill concrete
* 115 KV steel transmission towers
* 115 KV steel transmission tower foundations
* 115 KV wooden transmission towers 2.4B.6.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.6 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be 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.B.6 identified an area in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAI as discussed below.
In RAI 2.4.B-4 dated December 9, 2004, the staff stated that LRA Section 2.4.B.6 states that the NMP2 EYS include electrical equipment, piping, vent tunnels, manholes, underground duct
 
banks, and earth berms and ditches used for flood control. The EYS also are said to include
 
structures that support the equipment and high voltage lines in the switchyard and Scriba 2-291 substation for SBO. LRA Table 2.4.B.6-1 does not indicate that some associated structural steel supports or embedments are in the scope of lic ense renewal though they perform SR functions per 10 CFR 50.54(a)(1). Therefore, the staff requested that, if they were within the scope of
 
license renewal, the applicant provide a description of its scoping and include the structural
 
steel items in the format of LRA Table 2.4.B.6-1. The staff also requested that the applicant
 
provide the basis for omission from the scope of license renewal.
In its response by letter dated January 10, 2005, the applicant stated that the equipment and high voltage line supports in the switchyard and Scriba substation are within the scope of
 
license renewal under 10 CFR 54.4(a)(3) for SBO. In LRA Section 2.4.B.6 and Table 2.4.B.6-1, structures that support the equipment and high voltage lines in the switchyard and the Scriba
 
substation are included in the component types "Structural Steel (Carbon and Low Alloy Steel)
 
in Air," "Treated Wood in Air," "Treated Wood in Soil Above the GWT," and "Treated Wood in
 
Soil Below the GWT." Embedments are included as part of the "Concrete in Air" component type
 
with the exposed portions of anchor bolts included in the component type "Fasteners (Carbon
 
and Low Alloy Steel) in Air." Hilti bolts are included in the "Expansion/Grouted Anchors (Carbon
 
and Low Alloy Steel) in Air" component type.
The staff found the applicant's explanation adequate and acceptable. Therefore, the staff's concern described in RAI 2.4.B-4 is resolved.
2.4B.6.3  Conclusion The staff reviewed the ALRA, RAI response, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the EYS
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the EYS components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4B.7  NMP2 Fuel Handling System 2.4B.7.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.7 the applicant described the fuel handling system. The fuel handling system involves those components used to move fuel from the time of receipt of new fuel to the
 
storage of spent fuel in the spent fuel storage pool. Components that are evaluated in the fuel
 
handling system include the channel handling boom, the fuel preparation machines, the fuel
 
transfer shielding bridge, the refueling crane platform and equipment, the new fuel storage
 
vault, lifting and handling equipment, and spent fuel pool storage racks. Although the RB polar
 
crane handles fuel, it is analyzed in the material handling system. Civil/structural components
 
from the fuel nuclear refueling, the fuel nuclear storage, and the materials handling fuel storage
 
area subsystems are also evaluated as part of the fuel handling system.
The fuel handling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the fuel handling system could
 
potentially prevent the satisfactory accomplishment of an SR function.
2-292 The intended functions within the scope of license renewal include the following:
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.7-1, the applicant identified the following fuel handling system component types that are within the scope of license renewal and subject to an AMR:
* channel handling boom
* control blade storage frame
* fuel preparation machines
* fuel storage racks
* head strongback carousel
* in-vessel storage rack
* new fuel storage rack
* new fuel storage vault cover
* recirculation pump motor lifting lugs
* refueling crane and platform equipment
* steam dryer primary lifting beam 2.4B.7.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.7 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.7.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the fuel handling system
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the fuel handling system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).
2.4B.8  NMP2 Main Stack 2-293 2.4B.8.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.8, the applicant described the main stack. The main stack is a seismic Category I reinforced-concrete chimney, approximately 430-ft high, located on the northeast
 
side of the power station. The main stack is designed and constructed to provide elevated
 
release of offgas, standby gas treatment, turb ine building ventilation, and other systems. The main stack foundation is a on a reinforced concrete base, which extends to bedrock.
The main stack contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the main stack could potentially prevent the
 
satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides flood protection barrier
* provides path for release of filtered and unfiltered gaseous discharge
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.8-1, the applicant identified the following main stack component types that are within the scope of license renewal and subject to an AMR:
* compressible joints and seals
* concrete chimney shell
* concrete curbs
* concrete floors
* concrete slabs
* concrete lean fill
* embedded steel
* expansion/grouted anchors
* main stack foundation
* penetration seal clamp
* penetration seals
* penetration sleeves
* structural fasteners
* structural steel: platforms, stairways, and mezzanines 2.4B.8.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.8 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
2-294 In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.8.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the main stack components
 
that are within the scope of license renewal, as required by 10 CFR 54.4(a), and the main stack
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4B.9  NMP2 Material Handling System 2.4B.9.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.9, the applicant described the material handling system. The material handling system consists of overhead traveli ng cranes, monorail hoists, platform cranes, jib cranes, and associated mechanical and electrical components. For license renewal purposes, the crane girders and rails are included in the structural steel asset of the structure in which the
 
crane is located.
The material handling system contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the material handling system could
 
potentially prevent the satisfactory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.9-1, the applicant identified the following material handling system
 
component types that are within the scope of license renewal and subject to an AMR:
* control building equipment hoist (el. 306)
* emergency diesel generator cranes
* main steam isolation valve crane
* main steam isolation valve hoist
* main turbine area traveling crane
* reactor building polar crane
* recirculation motor handling cranes 2-295
* safety relief valve hoists
* screenwell area traveling crane
* stop log area crane 2.4B.9.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.9 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.9.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the material handling system
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the material handling system components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).2.4B.10  NMP2 Motor Operated Doors System 2.4B.10.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.10, the applicant described the motor operated doors system. The motor operated doors system consists of various motor operated doors and the associated electronic
 
equipment that monitors their positions.
The motor operated doors system contains SR components that are relied upon to remain functional during and following DBEs. In addition, the motor operated doors system performs
 
functions that support fire protection.
All doors have been identified and are addressed in appropriate tables describing structures in which the doors are physically located. The remaining electrical components are active
 
components. There are no other components subject to an AMR for this system.
2-296 2.4B.10.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.10 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant had
 
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
 
had identified as being within the scope of license renewal to verify that the applicant had not
 
omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.10.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the motor operated doors
 
system components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the motor operated doors system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4B.11  NMP2 Radwaste Building 2.4B.11.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.11, the applicant described the radwaste building (RWB). The RWB is a seismic Category I structure and contains the radioactive waste system. It is a five-story, concrete and steel building. The exterior walls are reinforced concrete. A rolling steel door is
 
provided in the north wall for truck access into the building. The basement floor is a concrete
 
mat on bedrock. The upper four floors are concrete supported by steel deck and beams. The
 
roof consists of steel framing with steel deck, insulation, and four-ply, built-up roofing. The
 
decontamination area is located south of the RWB, and is an extension of the TB and the RWB.
The RWB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the RWB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the RWB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier 2-297
* provides flood protection barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides shielding against radiation
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.11-1, the applicant identified the following RWB component types that are within the scope of license renewal and subject to an AMR:
* concrete and grout
* concrete floors
* concrete lean fill
* concrete slabs
* concrete walls
* decontamination area compressible joints and seals
* decontamination area concrete floors
* decontamination area concrete lean fill
* decontamination area concrete slabs
* decontamination area concrete walls
* decontamination area foundation
* doors and framing/hardware
* embedded structural plates
* expansion/grouted anchors
* hotline trough
* penetration seal clamp
* penetration seals
* penetration sleeves
* radwaste building foundation
* radwaste building sump
* radwaste building sump flange plate
* steel liner
* structural beams
* structural columns
* structural fasteners 2.4B.11.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.11 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had not omitted from the scope of license renewal any components with intended 2-298 functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.11.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the RWB components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the RWB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4B.12  NMP2 Screenwell Building 2.4B.12.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.12, the applicant described the screenwell building (SWB). The SWB consists of a concrete substructure and a steel frame superstructure. The substructure, below
 
grade elevation 261'-0", including the service water pump room, is designated seismic
 
Category I, whereas the steel frame superstructure, including the circulating water pump and
 
water treatment area, is designed as a non-Category I area. The SWB includes the service
 
water pump rooms, the diesel and electric fire pump rooms, the water treatment area, the
 
circulating water pump area, and other associated equipment. Stop logs, traveling screens, trash rakes, etc., are set in the concrete walls, as required to divert the flow of water. These
 
components are built-up structures of steel and concrete guided and supported by the
 
reinforced concrete walls and floors. For license renewal purposes, the SWB also includes the
 
intake structures and the intake/discharge tunnels.
The SWB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the SWB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the SWB performs functions that support fire
 
protection, ATWS, and SBO.
The intended functions within the scope of license renewal include the following:
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides filtration
* provides rated fire barrier
* provides flood protection barrier
* provides missile barrier 2-299
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides shelter/protection to SR components
* provides source of cooling water for plant shutdown
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.12-1, the applicant identified the following SWB component types that are within the scope of license renewal and subject to an AMR:
* compressible joints and seals
* concrete and grout
* concrete curbs
* concrete floors
* concrete slabs
* concrete walls
* crane rails/girders
* doors and framing/hardware
* embedded structural plates
* expansion/grouted anchors
* hot line tunnel
* intake shaft access door and framing
* intake shaft concrete lean fill
* intake shafts
* intake structure anchor bolts
* intake structure bar racks
* intake structure concrete and grout
* intake structure fasteners
* intake structure hatch cover and manhole
* intake structure structural steel and embedments
* intake structure Tremie concrete
* intake structures
* intake tunnel compressible material
* intake tunnel concrete lean fill
* intake tunnels
* masonry walls
* penetration seal clamp
* penetration seals
* penetration sleeves
* removable concrete slabs
* removable steel nose piece
* screenwell building sumps
* screenwell building foundation
* service water pump bay sumps
* service water tunnel
* service water valve missile protection
* stop log fasteners
* stop log seals 2-300
* stop logs and guides
* structural beams
* structural columns
* structural fasteners
* structural foundation piles
* structural steel: platforms, stairways, and mezzanines
* trash racks and guides 2.4B.12.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.12 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be 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.B.12 identified areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The
 
applicant responded to the staff's RAIs as discussed below.
In RAI 2.4.B-5 dated December 9, 2004, the staff stated that LRA Table 2.4.B.11-1 lists structural steel foundation piles (carbon and low alloy steel) in undisturbed soil as one of the
 
component types in the NMP2 screenwell building requiring AMR. Because these piles are
 
inaccessible, the staff requested that the applicant discuss results of the AMR of the piles and
 
indicate where in the LRA the aging management of the piles is addressed.
In its response by letter dated January 10, 2005, the applicant stated that the structural steel foundation piles in undisturbed soil are subj ect to AMR; however, the component type "Structural Steel Foundation Piles (Carbon and Low Alloy Steel) in Undisturbed Soil" has no
 
aging effects and, as stated in Section 4.3.1.1 of EPRI TR-103842, undisturbed soils are so
 
deficient in oxygen at levels a few feet below the surface or the water table that steel piles are
 
not appreciably affected by corrosion regardless of the soil type or properties. The NMPNS site
 
ground water and soil are both non-aggressive in nature as defined by SRP-LR. The applicant
 
indicated that previous LRAs (e.g., Fort Calhoun) that the staff had reviewed have also not
 
identified any aging effects requiring management for carbon steel foundation piles.
The staff found the above response adequate. Therefore, the concern described in RAI 2.4.B-5 is resolved.
In RAI 2.4.B-7 dated December 9, 2004, the staff requested that the applicant confirm that such Screenwell Building items as hatches and plugs, structural steel embedments, reinforced
 
concrete foundation footings, grouted concrete, and water proofing membrane materials are
 
within the scope of license renewal and require AMR and, if within the scope of license renewal, 2-301 that the applicant provide additional information in the format of LRA Table 2.4.B.11-1. If not within the scope of license renewal, the applicant was to provide the basis for their omission.
In its response by letter dated January 10, 2005, the applicant responded that the items listed in the RAI are within the scope of license renewal and subject to AMR with the exception of the
 
waterproofing membranes, which are not included because they are applied as coatings.
 
NMPNS does not credit coatings to mitigate aging effects. The LRA lists in Table 2.4.B.11-1
 
component types that represent these items:
* There are no "hatches" in the NMP2 Screenwell Building. All doors are included in the component type "Door."
* Plugs are concrete and included in the component type "Concrete in Air."
* Embedded portions of structural steel embedments are integral with the concrete and included in the component type "Concrete in Air" or "Concrete in Raw Water" depending
 
on location. Structural steel exposed to atmosphere is included in the component type
 
"Structural Steel (Carbon and Low Alloy Steel) in Air" or "Structural Steel (Carbon and
 
Low Alloy Steel) in Raw Water" depending on location.
* Reinforced concrete foundation footings are included in the component type "Concrete in Soil Above the GWT" or "Concrete in Soil Below the GWT" depending on footing depth.
* Grouted concrete is not used at NMP2. Structural concrete is included in the various concrete component types depending on its environment.
The staff found the applicant's response complete and adequate. Therefore, the concern described in RAI 2.4.B-7 is resolved.
2.4B.12.3  Conclusion The staff reviewed the ALRA, RAI responses, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the SWB
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the SWB components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).2.4B.13  NMP2 Standby Gas Treatment Building 2.4B.13.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.13, the applicant described the standby gas treatment building (SGTB).
The SGTB and railroad access area contain the standby gas treatment (SGT) filters and
 
associated equipment and allow access for spent fuel shipping. This structure is classified a
 
seismic Category I structure up to elevation 286 ft. The portion of the building above elevation
 
286 ft is classified as nonseismic. The SGTB is a two-story, reinforced concrete and
 
steel-framed structure. The structure shares a common wall with the railroad access lock
 
adjacent to the RB. The reinforced concrete floor slab is provided at the grade level of elevation 2-302 261 ft. A railroad access lock approximately 25 x 90 ft is provided adjacent to the RB. This building is a reinforced concrete and steel-framed structure and shares a common wall with the
 
SGTB.The SGTB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the SGTB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the SGTB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides shielding against high energy line breaks
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pressure retaining boundary
* provides shelter/protection to SR components
* provides pressure boundary or essentially leaktight barrier
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.13-1, the applicant identified the following SGTB component types that are within the scope of license renewal and subject to an AMR:
* compressible joints and seals
* concrete and grout
* concrete floors
* concrete lean fill
* concrete slabs
* concrete walls
* doors and framing/hardware
* embedded rail girders
* embedded structural plates
* penetration seals
* penetration sleeves
* SGTB foundation
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, and mezzanines 2-303 2.4B.13.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.13 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.13.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the SGTB components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the SGTB
 
components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4B.14  NMP2 Turbine Building 2.4B.14.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.B.14, the applicant described the TB. The TB complex includes the TB, heater bays, main steam tunnel, and condensate demineralizer regenerative and offgas area. A
 
portion of the TB, main steam tunnel area, and offgas area are analyzed to seismic conditions, whereas the remaining portions are designed as nonseismic. The complex houses the turbine
 
generator, condenser, moisture separator, etc., in the TB areas, heaters and related pumps and
 
accessories in heater bay areas, and offgas system equipment and tanks in offgas areas. The
 
main steam tunnel connects the TB with the RB. The TB complex is constructed partially on
 
spread footings and partially on a mat foundation. This building complex is constructed of
 
reinforced concrete floors and walls up to the operating floor level. The TB's operating floor is
 
concrete supported by steel deck and beams. The structure above the operating floor level is
 
constructed of a structural steel framing sy stem braced by vertical and horizontal bracing systems up to roof level, enclosed by metal siding. A steel roof deck with roofing is provided at
 
the top of the structure.
The TB contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the TB could potentially prevent the satisfactory
 
accomplishment of an SR function. In addition, the TB performs functions that support fire
 
protection.
The intended functions within the scope of license renewal include the following:
2-304
* provides spray shield or curbs for directing flow
* provides for thermal expansion and/or seismic separation
* provides rated fire barrier
* provides flood protection barrier
* provides shielding against high energy line breaks
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides pipe whip restraint
* provides shelter/protection to SR components
* provides shielding against radiation
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.B.14-1, the applicant identified the following TB component types that are within the scope of license renewal and subject to an AMR:
* compressible joints and seals
* concrete and grout
* concrete columns
* concrete curbs
* concrete floors
* concrete slabs
* concrete walls
* concrete lean fill
* crane rails/girders
* doors and framing/hardware
* embedded structural plates
* expansion/grouted anchors
* main steam tunnel
* masonry walls
* penetration seal clamp
* penetration seals
* penetration sleeves
* pipe whip restraints
* pipe whip restraint fasteners
* removable concrete slabs
* removable masonry wall framing
* removable masonry walls
* structural beams
* structural columns
* structural fasteners
* structural steel: platforms, stairways, and mezzanines
* TB foundation
* TB sumps
* turbine support mat 2-305
* turbine support structure 2.4B.14.2  Staff Evaluation The staff reviewed ALRA Section 2.4.B.14 and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with the guidance
 
described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4B.14.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the TB components that are
 
within the scope of license renewal, as required by 10 CFR 54.4(a), and the TB components
 
that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
2.4C  NMPNS Structural Commodities In ALRA Section 2.4.C, the applicant identified the NMPNS structural commodities that are
 
subject to an AMR for license renewal.
The applicant described the supporting structures and components of the structural commodities in the following sections of the ALRA:
* 2.4.C.1component supports
* 2.4.C.2fire stops and seals The staff's review findings regarding ALRA Sections 2.4.C.1 and 2.4.C.2 are presented in SER Sections 2.4A.2.1 and 2.4A.2.2, respectively.
2.4C.1  Component Supports 2.4C.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.C.1, the applicant described the component supports commodity.
Component supports are connections between a system component and a plant structural member such as a concrete wall or floor or structural steel beam or column. Supports for both
 
the distributive portions of systems and equi pment like pumps and pressure vessels are 2-306 included as parts of this commodity group. Supported components include vessels, piping, passive pump components, and heat exchangers. Supports for electrical cables, cable trays, cable tray missile shields, conduits, HVAC ducting, motor control center cabinets, electrical
 
enclosures, fans, filters, and heaters are also included in this commodity. Seismic restraints, which may or may not provide support during normal operation, are also considered parts of this
 
commodity.
The component supports commodity contains SR components that are relied upon to remain functional during and following DBEs. The failure of NSR SSCs in the component supports
 
commodity could potentially prevent the satisf actory accomplishment of an SR function.
The intended functions within the scope of license renewal include the following:
* provides missile barrier
* provides structural support to NSR components whose failure could prevent accomplishment of SR function(s)
* provides structural and/or functional support to SR equipment In ALRA Table 2.4.C.1-1, the applicant identified the following component supports commodity component types that are within the scope of license renewal and subject to an AMR:
* ASME Class 1, 2, 3 and MC hangers and supports
* cable trays and supports
* cable tray missile shields (NMP1 only)
* conduit
* electrical panels, racks, cabinets, and other enclosures
* equipment supports and foundations
* instrumentation racks, frames, panels, enclosures
* lubrite plates
* non-ASME class hangers and supports
* tube track
* vibration isolating elements 2.4C.1.2  Staff Evaluation The staff reviewed ALRA Section 2.4.C.1, the UFSAR, and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the system functions described in the ALRA, UFSAR, and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-307 The staff's review of LRA Section 2.4.C.1 identified an area in which additional information was necessary to complete review of the applicant's scoping and screening results. The applicant
 
responded to the staff's RAI as discussed below.
In RAI 2.4.C.1-1 dated October 11, 2005, the staff stated that in ALRA Table 2.4.C-1 the applicant included ASME Classes 1, 2, 3, and MC hangers and supports. The staff assumed
 
that the drywell and torus external supports were included within the Class MC supports.
 
Therefore, the staff requested that the applicant confirm the staff's assumption.
In its response by letter dated October 28, 2005, the applicant clarified:
  (1)The drywell supports are included in ALRA Section 2.4.C.1, "Component Supports,"
under the Component Type "ASME Class 1, 2, 3, and MC Hangers and Supports" in
 
Table 2.4.C.1-1.    (2)The torus supports are included in ALRA Section 2.4.A.2, "NMP1 Reactor Building."
They are listed in Table 2.4.A.2-1 under the Component Type "Torus Support Columns."
 
The applicant explained that these two com ponent types encompass all drywell and torus supports.The applicant further stated that the aging management of the drywell supports is addressed under the Component Type "Structural Steel (Carbon and Low Alloy Steel) in Air" in ALRA Table 3.5.2.C-1. These supports are managed by the ASME Section XI Inservice Inspection (Subsection IWF) Program consistent with GALL Report Item III.B1.3.1-a.
The applicant finally stated that the aging management of the Torus Support Columns is addressed in ALRA Table 3.5.2.A-2 under the Component Type "Torus Support Columns."
These supports are managed by the ASME Section XI Inservice Inspection (Subsection IWF)
 
Program consistent with GALL Report Item III.B1.3.1-a.
The staff found the clarification provided by the applicant consistent with the staff's assumption and with GALL item III.B1.3.1-a. Therefore, the staff's concern described in RAI 2.4.C.1-1 is
 
resolved.2.4C.1.3  Conclusion The staff reviewed the ALRA, RAI response, and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by
 
the applicant. No omissions were identified. In addition, the staff performed a review to
 
determine whether any components that should be subject to an AMR had not been identified
 
by the applicant. No omissions were identified. On the basis of its review, the staff concludes
 
that there is reasonable assurance that the applicant had adequately identified the component
 
supports commodity components that are within the scope of license renewal, as required by
 
10 CFR 54.4(a), and the component supports commodity components that are subject to an
 
AMR, as required by 10 CFR 54.21(a)(1).
2.4C.2  Fire Stops and Seals 2-308 2.4C.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.4.C.2 the applicant described the fire stops and seals commodity. The fire stops and seals commodity addresses penetration fire stop/seal and structural fire seal
 
materials. The following items are not included under this commodity: (1) process piping, electrical cables, or conduits running through the fire penetration (included under the associated
 
mechanical or electrical systems), (2) cast in place penetration sleeves and any flanges or
 
welds (evaluated as part of the structural steel asset associated with the structure), (3)
 
embedded portions of cast-in-place sleeves (included under the concrete asset for the
 
structure), and (4) fire barrier walls, which are included under the structure.
The fire stops and seals commodity contains SR components that are relied upon to remain functional during and following DBEs. In addition, the fire stops and seals commodity performs
 
functions that support fire protection.
The intended function within the scope of license renewal is to provide rated fire barrier.
 
In ALRA Table 2.4.C.2-1, the applicant identified the following fire stops and seals commodity component types that are within the scope of license renewal and subject to an AMR:
* aluminum spacers
* stainless steel clamps
* fire stop materials
* fire wrap materials
* penetration extensions 2.4C.2.2  Staff Evaluation The staff reviewed ALRA Section 2.4.C.2, the UFSAR, and the USAR using the evaluation methodology described in SER Section 2.4. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.4.
In conducting its review, the staff evaluated the structural component functions described in the ALRA, UFSAR, and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that
 
the applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2.4C.2.3  Conclusion The staff reviewed the ALRA and related structural components to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No
 
omissions were identified. In addition, the staff performed a review to determine whether any
 
components that should be subject to an AMR had not been identified by the applicant. No
 
omissions were identified. On the basis of its review, the staff concludes that there is
 
reasonable assurance that the applicant had adequately identified the fire stops and seals
 
commodity components that are within the scope of license renewal, as required by 2-309 10 CFR 54.4(a), and the fire stops and seals commodity components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
 
===2.5 Scoping===
and Screening Results: Elect rical and Instrumentation and ControlsSystems This section documents the staff's review of the applicant's scoping and screening results for electrical systems and instrumentation and c ontrols (I&C) systems. Specifically, ALRA Section 2.5 discusses the following electrical and I&C systems that are within the scope of
 
license renewal:
* NMP1 24V DC electrical distribution system
* NMP1 125V DC electrical distribution system
* NMP1 120V AC electrical distribution system
* NMP1 600V AC electrical distribution system
* NMP1 4.16KV AC electrical distribution system
* NMP1 115KV AC electrical distribution system
* NMP1 anticipated transients without scram system
* NMP1 communications system
* NMP1 plant lighting system
* NMP1 plant process computer system
* NMP1 reactor protection system
* NMP1 remote shutdown system
* NMP1 Neutron monitoring system
* NMP2 13.8KV AC electrical distribution system
* NMP2 4.16KV AC electrical distribution system
* NMP2 battery-24V-station system
* NMP2 common electrical system
* NMP2 communications paging system
* NMP2 communications telephone system
* NMP2 emergency DC distribution system
* NMP2 emergency uninterruptible power supplies system
* NMP2 feedwater control system
* NMP2 heat tracing system
* NMP2 information handling annunciator system
* NMP2 motor control center emergency system
* NMP2 normal AC high voltage distribution system
* NMP2 normal DC distribution system
* NMP2 normal UPS system
* NMP2 process computer system
* NMP2 reactor protection motor generator system
* NMP2 reactor protection system
* NMP2 redundant reactivity control system
* NMP2 remote shutdown system
* NMP2 reserve station service transformers system
* NMP2 standby and emergency AC distribution system
* NMP2 standby diesel generator protection (breaker) system
* NMP2 startup transient analysis system
* NMP2 station control bus nonvital AC supply system 2-310
* NMP2 station control bus vital AC supply system
* NMP2 station lighting system
* NMP2 switchyard system
* NMP2 synchronizing - diesel generator system
* NMP2 unit substation emergency AC controls and heater supply
* NMP2 unit substation emergency system
* NMP2 unit substation system
* NMP2 uninterruptible power supplies distribution system
* NMP2 standby diesel generator protection (generator) system In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant identified and listed passive, long-lived SCs that are within the scope of license renewal and subject to an AMR. To
 
verify that the applicant properly implemented it s methodology, the staff focused its review on the implementation results. This approach allowed the staff to confirm that there were no
 
omissions of electrical and I&C system com ponents that meet the scoping criteria and are subject to an AMR.
Staff Evaluation Methodology. The staff's evaluation of the information provided in the ALRA was performed in the same manner for all el ectrical and I&C systems and commodities. The objective of the review was to determine if the components and supporting structures for a
 
specific electrical and I&C system or comm odity, that appeared to meet the scoping criteria specified in 10 CFR Part 54, were identified by the applicant as within the scope of license
 
renewal, in accordance with 10 CFR 54.4. Similarly, the staff evaluated the applicant's
 
screening results to verify that all long-lived, passive components were subject to an AMR in
 
accordance with 10 CFR 54.21(a)(1).
Scoping. To perform its evaluation, the staff reviewed the applicable ALRA section and associated component drawings, focusing its review on components that had not been identified
 
as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the UFSAR and USAR, for each electrical and I&C system component to determine if
 
the applicant had omitted components with intended functions delineated under 10 CFR 54.4(a)
 
from the scope of license renewal. The staff also reviewed the licensing basis documents to
 
determine if all intended functions delineated under 10 CFR 54.4(a) were specified in the ALRA.
 
If omissions were identified, the staff requested additional information to resolve the
 
discrepancies.
Screening. Once the staff completed its review of the scoping results, the staff evaluated the applicant's screening results. For those systems and components with intended functions, the
 
staff sought to determine: (1) if the functions are performed with moving parts or a change in
 
configuration or properties, or (2) if they are subject to replacement based on a qualified life or
 
specified time period, as described in 10 CFR 54.21(a)(1). For those that did not meet either of
 
these criteria, the staff sought to confirm that these electrical and I&C systems and components
 
were subject to an AMR as required by 10 CFR 54.21(a)(1). If discrepancies were identified, the
 
staff requested additional information to resolve them.
2-311 2.5.1  NMPNS Electrical Commodities In LRA Section 2.5.C, the applicant described the components and systems included in the commodity group:
* 2.5.C.1Cables and Connectors
* 2.5.C.2Non-Segregated/switchyard Bus
* 2.5.C.3Containment Electrical Penetrations
* 2.5.C.4Switchyard Components The commodity group is within the scope of license renewal under 10 CFR 54.4(a)(1) because it provides electrical power to safety Class 1, 2, and 3 components. Some SSCs in the system are considered within the scope of license renewal because their failure could affect the capability
 
of safety-related SSCs per 10 CFR 54.4(a)(2). Others are within the scope of license renewal
 
because they support fire protection, anticipated transient without scram, and station blackout
 
per 10 CFR 54.4(a)(3). An intended function within the scope of license renewal is to electrically
 
connect specified sections of an electrical circuit to deliver voltage, current, or signal. Additional
 
intended functions are to isolate electrically and provide structural support to transmission
 
conductors, phase buses, and switchyard buses.
In ALRA Tables 2.5.C.1-1, 2.5.C.2-1, 2.5.C.3-1, and 2.5.C.4-1, the applicant identified the following commodity group component types within the scope of license renewal and subject to
 
an AMR:
* conductor insulation for electrical cables and connector
* conductor insulation for electrical cabl es used in circuits sensitive to reduction in conductor insulation resistance (IR)
* fuse holders (not part of a larger assembly)
* insulators
* non-segregated busses
* switchyard busses
* electrical penetrations
* high-voltage insulators
* transmission conductors
* transmission conductor connectors In ALRA Section 2.5.C the applicant identified the NMPNS electrical commodities subject to an AMR for license renewal.
After applying the scoping and screening methodology the applicant categorized the components requiring AMR into passive commodity groups. In ALRA Section 2.5.C, the
 
applicant identified the SCs of the electrical and I&C systems subject to an AMR for license
 
renewal. The staff's review findings regarding ALRA Sections 2.5.C.1 through 2.5.C.4 are
 
presented in SER Sections 2.5.1.1 through 2.5.1.4, respectively, for both NMP1 and NMP2.
2-312 2.5.1.1  Cables and Connectors 2.5.1.1.1  Summary of Technical Information in the Amended Application In ALRA Section 2.5.C.1, the applicant described the cables and connectors commodity. The components addressed in this commodity are electrical cables, connectors, splices, terminal
 
blocks, and fuse blocks. Cables are identified on a plant-wide basis, and are not identified as
 
being associated with a particular system.
The intended function, within the scope of license renewal, is to provide continuity to deliver electrical signals or power (includes insulation).
In ALRA Table 2.5.C.1-1, the applicant identified the following cables and connectors commodity component types that are within the scope of license renewal and subject to an
 
AMR:
* conductor insulation for electrical cables and connectors
* conductor insulation for electrical cables used in circuits that are to reduction in conductor insulation resistance (IR)
* fuse holders (not part of a larger assembly) 2.5.1.1.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.5.C.1, UFSAR, and USAR using the evaluation methodology described in SER Section 2.5. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.5.
In conducting its review, the staff evaluated the commodity functions described in the ALRA, UFSAR, and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The applicant evaluated the cables and connectors plant-wide as commodities across system boundaries. In ALRA Section 2.5.C.1 the applicant stated that the components addressed in this
 
commodity are electrical cables, connectors, splices, terminal blocks, and fuse blocks. Cables
 
are identified plant-wide and are not identified as associated with particular systems. Cables
 
and their associated connectors provide electrical c ontinuity to specified sections of an electrical circuit to deliver voltage, current, and signals to various equipment and components throughout
 
the plant to enable them to perform their intended functions.
The staff found that the applicant correctly identified the cables and connectors as components that perform their functions without moving parts or change in configuration or properties (passive and long-lived) and, therefore, subject to AMR.
2-313 2.5.1.1.3  Conclusion The staff reviewed the ALRA, UFSAR, and USAR to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions
 
were identified. In addition, the staff performed a review to determine whether any components
 
that should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the cables and connectors commodity components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the cables and
 
connectors commodity components that are subject to an AMR, as required by
 
10 CFR 54.21(a)(1).
2.5.1.2  Non-Segregated/Switchyard Bus 2.5.1.2.1  Summary of Technical Information in the Amended Application In ALRA Section 2.5.C.2, the applicant described the non-segregated/switchyard bus commodity. The components evaluated in this comm odity encompass the electrical switchyard and non-segregated busses, as well as their associated insulators. Electrical busses perform
 
the function of providing electrical continuity to specified sections of an electrical circuit voltage and current to various equipment and components throughout the plant to enable them to
 
perform their intended functions.
The intended functions within the scope of license renewal include the following:
* provides continuity to deliver electrical signals or power (includes insulation)
* insulates and supports an electrical conductor In ALRA Table 2.5.C.2-1, the applicant identified the following non-segregated/switchyard bus commodity component types that are within the scope of license renewal and subject to an
 
AMR:
* insulators
* non-segregated bus
* switchyard bus 2.5.1.2.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.5.C.2, UFSAR, and USAR using the evaluation methodology described in SER Section 2.5. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.5.
In conducting its review, the staff evaluated the commodity functions described in the ALRA, UFSAR, and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
2-314 The non-segregated/switchyard bus identified by the applicant requiring an AMR includes insulators, a non-segregated bus, and a switchyard bus. Electrical busses provide electrical
 
continuity to an electrical circuit and voltage and current to equipment and components
 
throughout the plant to enable them to perform their intended functions. The intended function
 
of the insulators is electrical insulation and NSR functional support through separation of busses
 
and conductors from other components and structures.
The staff reviewed these component categories and found them subject to10 CFR 54.4(a)(1) and 10 CFR 54.4(b) requirements. The staff reviewed the information in the UFSAR and USAR
 
and found that the applicant had identified correctly the non-segregated/switchyard bus
 
commodity component types that perform intended functions without moving parts or change in
 
configuration or properties (passive and long lived) and are, therefore, subject to an AMR.
2.5.1.2.3  Conclusion
 
The staff reviewed the ALRA, UFSAR, and USAR to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions
 
were identified. In addition, the staff performed a review to determine whether any components
 
that should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the non-segregated/switchyard bus commodity
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the non-segregated/switchyard bus commodity components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).
2.5.1.3  Containment Electrical Penetrations 2.5.1.3.1  Summary of Technical Information in the Amended Application In ALRA Section 2.5.C.3, the applicant described the containment electrical penetrations commodity. The components evaluated in this commodity encompass the non-EQ electrical penetrations that form part of the containment pressure boundary. An electrical penetration
 
provides an electrical connection between two sections of the electrical/I&C circuit. The pigtail at
 
each end of the penetration is connected to the field cable in various ways and is included in
 
this evaluation. The connector or connection method is included in the cables and connectors
 
commodity group. The structural steel portion of the primary containment electrical penetrations
 
is evaluated in the NMP1 primary containment structure and the NMP2 primary containment structure.
The intended functions within the scope of license renewal include the following:
* provides continuity to deliver electrical signals or power (includes insulation)
* provides pressure retaining boundary In ALRA Table 2.5.C.3-1, the applicant identified that the electrical penetrations component type of the containment electrical penetrations commodity is within the scope of license renewal and
 
subject to an AMR.
2-315 2.5.1.3.2  Staff Evaluation The staff reviewed ALRA Section 2.5.C.3, UFSAR, and USAR using the evaluation methodology described in SER Section 2.5. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.5.
In conducting its review, the staff evaluated the commodity functions described in the ALRA, UFSAR, and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
The containment electrical penetrations identified by the applicant are non-EQ and form part of the containment pressure boundary. They also provide electrical continuity to an electrical
 
circuit to deliver voltage, current, and signals across the containment boundary (either
 
continuously or intermittently) to equipment and components throughout the plant to enable
 
them to perform their intended functions. An electrical penetration is a device used to provide an
 
electrical connection between two sections of the electrical/I&C circuit, inside and outside of the
 
containment. This evaluation includes the pigtail located at each end of the penetration. The
 
pigtail connects the end of the penetration to the field cable in various ways. The connector or
 
connection method is addressed in the cables and connectors commodity group section.
The staff reviewed these component categories and found them subject to 10 CFR 54.4(a)(1) and 10 CFR 54.4(b) requirements. The staff reviewed the information in the UFSAR and USAR
 
and found that the applicant had identified correctly the containment electrical penetrations that
 
perform their intended functions without moving parts or change in configuration or properties (passive and long lived) and are, therefore, subject to an AMR.
2.5.1.3.3  Conclusion
 
The staff reviewed the ALRA, UFSAR, and USAR to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions
 
were identified. In addition, the staff performed a review to determine whether any components
 
that should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the containment electrical penetrations commodity
 
components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and
 
the containment electrical penetrations commodity components that are subject to an AMR, as
 
required by 10 CFR 54.21(a)(1).
2.5.1.4  Switchyard Components 2.5.1.4.1  Summary of Technical Information in the Amended Application In ALRA Section 2.5.C.4, the applicant described the switchyard components commodity. The switchyard components commodity was developed to address the addition of the 115KV 2-316 switchyards for SBO recovery to the scope of license renewal. Cables, connectors, and busbars are evaluated in their respective commodity groups.
The intended functions within the scope of license renewal include the following:
* provides continuity to deliver electrical signals or power (includes insulation)
* insulates and supports an electrical conductor In ALRA Table 2.5.C.4-1, the applicant identified the following switchyard components commodity component types that are within the scope of license renewal and subject to an
 
AMR:
* high voltage insulators
* transmission conductors
* transmission conductor connectors 2.5.1.4.2  Staff Evaluation
 
The staff reviewed ALRA Section 2.5.C.4, UFSAR, and USAR using the evaluation methodology described in SER Section 2.5. The staff conducted its review in accordance with
 
the guidance described in SRP-LR Section 2.5.
In conducting its review, the staff evaluated the commodity functions described in the ALRA, UFSAR, and USAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the
 
applicant had 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 had identified as being within the scope of license renewal to verify that the applicant
 
had not omitted any passive and long-lived components that should be subject to an AMR in
 
accordance with the requirements of 10 CFR 54.21(a)(1).
As identified by the applicant the switchya rd component commodity was developed to address the addition of the 115kV switchyard for SBO recovery to the scope of license renewal. The
 
components subject to AMR within the yard are the transmission conductors, insulators, and
 
associated connectors. Cables, connectors, and bus bars are evaluated in their respective
 
commodity group sections. Switchyard transmission conductors and associated connectors
 
provide electrical connections to electrical circuits to deliver voltage, current, and signals to
 
equipment and components throughout the switchyard to enable them to perform their intended
 
functions. The intended function of the high-voltage insulators is electrical insulation and NSR
 
function support through separation of the busses and conductors from other components and
 
structures.
The staff reviewed these component categories and found them subject to 10 CFR 54.4(a)(1) and 10 CFR 54.4(b) requirements. The staff reviewed the information in the UFSAR and USAR
 
and found that the applicant had identified correctly the switchyard components that perform
 
their intended functions without moving parts or change in configuration or properties (passive
 
and long lived) and are, therefore, subject to an AMR.
2-317 2.5.1.4.3  Conclusion The staff reviewed the ALRA, UFSAR, and USAR to determine whether any SSCs that should be within the scope of license renewal had not been identified by the applicant. No omissions
 
were identified. In addition, the staff performed a review to determine whether any components
 
that should be subject to an AMR had not been identified by the applicant. No omissions were
 
identified. On the basis of its review, the staff concludes that there is reasonable assurance that
 
the applicant had adequately identified the switchyard components commodity components that
 
are within the scope of license renewal, as required by 10 CFR 54.4(a), and the switchyard
 
components commodity components that are 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 ALRA Section 2, "Scoping and Screening Methodology for
 
Identifying Structures and Components Subject to Aging Management Review, and
 
Implementation Results." The staff determined that the applicant's scoping and screening, including its supplement 10 CFR 54.4(a)(2) review, which brought additional NSR piping
 
segments and associated components within the scope of license renewal, was consistent with
 
the requirements of 10 CFR 54.21(a)(1) and the staff's position on the treatment of SR and NSR
 
SSCs within the scope of license renewal and the structures and components requiring 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 there is reasonable assurance that the applicant had adequately identified those systems and components that are within the scope of
 
license renewal, as required by 10 CFR 54.4(a), and those systems and components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).
the staff concludes that there is reasonable assurance that the activities authorized by the renewed licenses will continue to be conducted in accordance with the CLB, and any changes
 
made to the CLB, in order to comply with 10 CFR 54.29(a), are in accordance with the Atomic
 
Energy Act of 1954 and the NRC's regulations.
THIS PAGE IS INTENTIONALLY LEFT BLANK.
3-1 SECTION 3 AGING MANAGEMENT REVIEW RESULTS This section of the safety evaluation report (SER) contains the staff's evaluation of the applicant's aging management programs (AMPs) and aging management reviews (AMRs). In amended license renewal application (ALRA) Appendix B, the applicant described the 43 AMPs
 
that it relies on to manage or monitor the aging of long-lived, passive components and
 
structures.
In ALRA Section 3, the applicant provided the results of the AMRs for those structures and components that were identified in ALRA Section 2 as being within the scope of license renewal
 
and subject to an AMR.
 
===3.0 Applicant's===
Use of the Generic Aging Lessons Learned Report In preparing its ALRA, Constellation Energy Group, LLC (CEG or the applicant) credited
 
NUREG-1801, Revision 0, "Generic Aging Lessons Learned (GALL) Report," The GALL Report
 
contains the staff's generic evaluation of t he existing plant programs, and it documents the technical basis for determining when existing programs are adequate without modification, and
 
when existing programs should be augmented for the extended period of operation. The
 
evaluation results documented in the GALL Report i ndicate that many of the existing programs are adequate to manage the aging effects for particular structures or components for license
 
renewal without change. 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 the programs at its facility correspond to those
 
reviewed and approved in the report.
The purpose of the GALL Report is to provide the staff with a summary of staff-approved AMPs to manage or monitor the aging of structures and components that are subject to an AMR. If an
 
applicant commits to implementing these staff-approved AMPs, the time, effort, and resources
 
used to review an applicant's LRA will likely be reduced, thereby improving the efficiency and
 
effectiveness of the license renewal review process. The GALL Report also serves as a
 
reference for applicants and staff reviewers to quickly identify those 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, stru ctures, and components (SSCs); (2) structure and component (SC) materials; (3) the environments to which the SCs are exposed; (4) the aging
 
effects associated with the materials and environments; (5) the AMPs that are 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 using the GALL Report would improve the efficiency of the license renewal review, the staff conducted a demonstration project to exercise the GALL process and
 
to determine the format and content of a safety evaluation based on this process. The results of
 
the demonstration project confirmed that t he GALL process will improve the efficiency and effectiveness of the LRA review, while maintaining the staff's focus on public health and safety.
3-2 NUREG-1800, Revision 0, "Standard Review Plan for the Review of License Renewal Applications" (SRP-LR) was prepared based on both the GALL Report model and lessons
 
learned from the demonstration project.
The staff performed its review in accordance with the requirements of Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," the guidance provided in the SRP-LR, and the guidance
 
provided in the GALL Report.
In addition to its review of the ALRA, the staff conducted an onsite audit of selected AMRs and associated AMPs, as described in the "Audit and Review Plan for Plant Aging Management
 
Reviews and Programs, Nine Mile Point Nuclear Power Station, Units 1 and 2," (Audit and
 
Review Report) dated January 18, 2006. The onsite audits and reviews are designed to
 
maximize the efficiency of the staff's review of the LRA. The need for formal correspondence
 
between the staff and the applicant is reduced, thereby resulting in an improvement in the
 
review's efficiency. Also, the applicant could respond to questions and the staff could readily
 
evaluate the applicant's responses.3.0.1  Format of the License Renewal Application The applicant submitted an application that followed the standard LRA format, which was agreed to by the Nuclear Regulatory Commission (NRC or the staff) and the Nuclear Energy
 
Institute (NEI) (see letter dated April 7, 2003, ML030990052). This revised LRA format
 
incorporates lessons learned from the staff's re views of the previous five LRAs. These previous applications used a format developed from information gained during an NRC staff and NEI
 
demonstration project that was conducted to evaluate the use of the GALL Report in the staff's
 
review process.
The organization of the amended LRA (ALRA) Section 3 parallels SRP-LR Chapter 3. The AMR results information in ALRA Section 3 is presented in the following two table types:
* Table 1: Table 3.x.1.A or 3.x.1.B - where "3" indicates the ALRA section number, "x" indicates the subsection number from the GALL Report, "1" indicates that this is the first
 
table type in ALRA Section 3; "A" and "B" indicate that the table applies to Nine Mile Point Unit 1 (NMP1) or Nine Mile Point Unit 2 (NMP2), respectively.
* Table 2: Table 3.x.2.A-y or 3.x.2.B-y - where "3" indicates the ALRA section number; "x" indicates the subsection number from the GALL Report; "2" indicates that this is the
 
second table type in ALRA Section 3; "A" and "B" indicate that the table applies to NMP1
 
or NMP2, respectively; and "y" i ndicates the system table number.
The content of the original LRA and the Nine Mile Point Nuclear Station (NMPNS) ALRA is essentially the same. The intent of the ALRA revised format was to modify the tables in LRA
 
Section 3 to provide additional information that would assist the staff in its review. Table 1 of
 
ALRA Section 3, summarizes portions of the application that it is considered to be consistent
 
with the GALL Report. In Table 2 of ALRA Section 3, the applicant identified the linkage
 
between the scoping and screening results in ALRA Section 2 and the AMRs in ALRA
 
Section 3.
3-3 3.0.1.1  Overview of Table 1 Table 3.x.1.A or 3.x.1.B (Table 1) provides a summary comparison of how the facility aligns with the corresponding tables of the GALL Report, Volume 1. The table is essentially the same as
 
Tables 1 through 6 provided in the GALL Report, Volume 1, except that the "Type" column has
 
been replaced by an "Item Number" column and the "Item Number in GALL" column has been
 
replaced by a "Discussion" column. The "Item Number" column provides the reviewer with a
 
means to cross-reference from Table 2 to Table 1. The "Discussion" column is used by the
 
applicant to provide clarifying and amplifying 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 being used
* exceptions to the GALL Report assumptions
* a discussion of how the line is consistent with the corresponding line item in the GALL Report when this may not be intuitively obvious
* a discussion of how the item is different from the corresponding line item in the GALL Report (e.g., when there is exception taken to a GALL AMP)
The format of Table 1 allows the staff to align a specific Table 1 row with the corresponding GALL Report, Volume 1, table row so that the consistency can be verified.
3.0.1.2  Overview of Table 2 Table 3.x.2.A-y or 3.x.2.B-y (Table 2) provides the detailed results of the AMRs for those components identified in ALRA Section 2 as being subject to an AMR. The ALRA contains a
 
Table 2 for each of the systems or components wi thin a system grouping (e.g., reactor coolant systems, engineered safety features, auxiliary systems, etc.). For example, the engineered safety features group contains tables specific to the core spray system, high pressure coolant
 
injection system, and residual heat removal system. Table 2 consists of the following nine columns:  (1)Component Type - The first column identifies the component types from ALRA Section 2 that are subject to aging management review. The component types are listed
 
in alphabetical order.  (2)Intended Function - The second column contains the license renewal intended functions (including abbreviations, where applicable) for the listed component types. Definitions
 
and abbreviations of intended functions are contained within ALRA Table 2.0-1.  (3)Material - The third column lists the particular materials of construction for the component type.  (4)Environment - The fourth column lists the environment to which the component types are exposed. Internal and external service environments are indicated and a list of these environments is provided in ALRA Table 3.0-1.
3-4  (5)Aging Effect Requiring Management - The fifth column lists aging effects requiring management (AERMs). As part of the aging management review process, the applicant
 
determined any AERMs for each combination of material and environment.  (6)Aging Management Programs - The sixth column lists the AMPs that the applicant used to manage the identified aging effects.  (7)NUREG-1801 Volume 2 Item - The seventh column lists the GALL Report item(s) that the applicant identified as being similar to the AMR results in the ALRA. The applicant
 
compared each combination of component type, material, environment, AERM, and
 
AMP in Table 2 of the ALRA to the items in the GALL Report. If there were no
 
corresponding items in the GALL Report, the applicant left the column blank. In this way, the applicant identified the AMR results in the ALRA tables that corresponded to the
 
items in the GALL Report tables.  (8)Table 1 Item - The eighth column lists the corresponding summary item number from Table 1. If the applicant identifies AMR results in Table 2 that are consistent with the
 
GALL Report, then the associated Table 1 line summary item number should be listed in
 
Table 2. If there is no corresponding item in the GALL Report, then column eight is left
 
blank. That way, the information from the two tables can be correlated.  (9)Notes - The ninth column lists the corresponding notes that the applicant used to identify how the information in Table 2 aligns with the information in the GALL Report.
 
The notes, identified by letters, were developed by an NEI working group and will be
 
used in future license renewal applications. Any plant-specific notes are identified by a
 
number and provide additional information concerning the consistency of the line item
 
with the GALL Report.3.0.2  Staff's Review Process The staff conducted the following three types of evaluations of the AMRs and associated 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 with the GALL
 
Report.  (2)For items that the applicant stated were consistent with the GALL Report with exceptions and/or enhancements, the staff conducted either an audit or a technical review of the
 
item to determine consistency with the GALL Report. In addition, the staff conducted
 
either an audit or a technical review of the applicant's technical justification for the
 
exceptions and the adequacy of the enhancements.  (3)For other items, the staff conducted a technical review.
The staff performed audits and technical reviews of the license renewal applicant's AMPs and AMRs. These audit and technical reviews are to determine whether the effects of aging on
 
structures and components can be adequately managed so that their intended functions can be
 
maintained consistently with the plant's current licensing basis (CLB) for the period of extended
 
operation, as required by 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for
 
Nuclear Power Plants."
3-53.0.2.1  Review of AMPs For those AMPs for which the applicant claimed consistency with the GALL AMPs, the staff conducted either an audit or a technical review to verify that the applicant's AMPs were
 
consistent with the AMPs in the GALL Report. For each AMP that had one or more deviations, the staff evaluated each deviation to determine: (1) whether the deviation was acceptable; and
 
(2) whether the AMP, as modified, would adequately manage the aging effect(s) for which it was
 
credited. For AMPs that were not evaluated in the GALL Report, the staff performed a full
 
review to determine the adequacy of the AMPs. The staff evaluated the AMPs against the
 
following 10 program elements defined in SRP-LR Appendix A.  (1)Scope of Program - Scope of the program should include the specific structures and components subject to an AMR for license renewal.  (2)Preventive Actions - Preventive acti ons 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 a 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 a formal review and approval process.  (10)Operating Experience - Operating ex perience 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 staff's audit evaluation of program elements (1) through (6) are documented in the Audit and Review Report dated January 18, 2006, and are summarized in SER Section 3.0.3.
The staff reviewed the applicant's corrective action program (CAP) and documented its evaluations in SER Section 3.0.4. The staff's evaluation of the CAP included assessment of the 3-6 following program elements: (7) corrective actions, (8) confirmation process, and (9) administrative controls.
The staff reviewed the information concerning the (10) operating experience program element and documented its evaluation in the Audit and Review Report. The staff also included a
 
summary of the program in SER Section 3.0.3.
The staff reviewed the respective NMP1 updated final safety analysis report (UFSAR) and NMP2 updated safety analysis report (USAR) supplements for each AMP to determine if it
 
provided an adequate description of the program or activity, as required by 10 CFR 54.21(d).3.0.2.2  Review of AMR Results ALRA Table 2 contains information concerning whether or not the AMRs align with the AMRs identified in the GALL Report. For a given AMR in Table 2, the staff reviewed the intended
 
function, material, environment, AERM, and AMP combination for a particular component type
 
within a system. The AMRs that correlate between a combination in Table 2 and a combination
 
in the GALL Report were identified by a referenced item number in column seven, "NUREG-1801 Volume 2 Item." The staff also conducted onsite audits to verify the correlation. A
 
blank column seven indicates that the applicant was unable to locate an appropriate
 
corresponding combination in the GALL Report. The staff conducted a technical review of these
 
combinations that were not consistent with the GALL Report. The next column, "Table 1 Item,"
 
provided a reference number that indicated the corresponding row in Table 1.
3.0.2.3  UFSAR and USAR Supplements Consistent with the SRP-LR, for the AMRs and associated AMPs that it reviewed, the staff also reviewed the UFSAR and USAR supplements that summarize the applicant's programs and
 
activities for managing the effects of aging for the period of extended operation, as required by
 
10 CFR 54.21(d).
3.0.2.4  Documentation and Documents Reviewed In performing its review, the staff used the ALRA, ALRA supplements, SRP-LR, and the GALL Report.Also, during the onsite audit, the staff examined the applicant's justification, as documented in the staff's Audit and Review Report, to verify that the applicant's activities and programs will
 
adequately manage the effects of aging on SCs. The staff also conducted detailed discussions
 
and interviews with the applicant's 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 ALRA Appendix B. The table also indicates the GALL AMP that the applicant claimed its AMP was
 
consistent with (if applicable) and the SSCs it monitors and manages. The section of the SER, in which the staff's evaluation of the program is documented, is also provided.
3-7 Table 3.0.3-1  NMPNS's Aging Management ProgramsNMPNS's AMP(ALRA Section)GALL ComparisonGALLAMP(s)ALRA Systems orStructuresThat Credit the AMP Staff's SER SectionExisting AMPsASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1)Consistent with exceptionXI.M1NMP1:
reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems NMP2: reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems 3.0.3.2.1Water Chemistry Control Program (B2.1.2)Consistent with exceptionXI.M2reactor vessel, internals, andreactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems;
 
structures and component
 
supports 3.0.3.2.2 Reactor Head Closure Studs Program (B2.1.3)Consistent with exceptionXI.M3reactor vessel, internals, andreactor coolant systems 3.0.3.2.3 BWR Vessel ID Attachment Welds
 
Program (B2.1.4)ConsistentXI.M4reactor vessel, internals, andreactor coolant systems 3.0.3.1.1BWR Feedwater Nozzle Program (B2.1.5)Consistent with exceptionXI.M5reactor vessel, internals, andreactor coolant systems 3.0.3.2.4 BWR Stress Corrosion Cracking Program (B2.1.6)Consistent with exceptionXI.M7NMP1:
reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems NMP2: reactor vessel, internals, and reactor coolant systems; engineered safety features 3.0.3.2.5BWR Penetrations Program (B2.1.7)ConsistentXI.M8reactor vessel, internals, andreactor coolant systems 3.0.3.1.2 NMPNS's AMP(ALRA Section)GALL ComparisonGALLAMP(s)ALRA Systems orStructuresThat Credit the AMP Staff's SER Section 3-8 BWR Vessel Internals Program (B2.1.8)Consistent with enhancementsXI.M9reactor vessel, internals, andreactor coolant systems 3.0.3.2.6Flow-Accelerated Corrosion Program (B2.1.9)ConsistentXI.M17reactor vessel, internals, andreactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems 3.0.3.1.3Open-Cycle CoolingWater System Program (B2.1.10)Consistent with enhancementsXI.M20engineered safety features;auxiliary systems 3.0.3.2.7Closed-Cycle CoolingWater System Program (B2.1.11)Consistent with enhancementsXI.M21NMP1:auxiliary systems; steam and power conversion systems NMP2:auxiliary systems 3.0.3.2.8 Boraflex Monitoring Program, NMP1 Only (B2.1.12)Consistent with enhancementsXI.M22structures and component supports 3.0.3.2.9 Inspection of OverheadHeavy Load and Light Load Handling Systems
 
Program (B2.1.13)Consistent with enhancementsXI.M23structures and component supports 3.0.3.2.10 Compressed Air Monitoring Program, NMP1 Only (B2.1.14)Consistent with exceptions and
 
enhancementsXI.M24auxiliary systems 3.0.3.2.11 BWR Reactor WaterCleanup System
 
Program (B2.1.15)Consistent with exceptionXI.M25NMP1auxiliary systems 3.0.3.2.12Fire Protection Program (B2.1.16)Consistent with exceptions and
 
enhancementsXI.M26auxiliary systems; structures and component supports 3.0.3.2.13Fire Water System Program (B2.1.17)Consistent with enhancementsXI.M27auxiliary systems 3.0.3.2.14Fuel Oil Chemistry Program (B2.1.18)Consistent with exceptions and
 
enhancementsXI.M30auxiliary systems 3.0.3.2.15 Reactor Vessel Surveillance Program (B2.1.19)Consistent with enhancementsXI.M31reactor vessel, internals, andreactor coolant systems 3.0.3.2.16 NMPNS's AMP(ALRA Section)GALL ComparisonGALLAMP(s)ALRA Systems orStructuresThat Credit the AMP Staff's SER Section 3-9ASME Section XI Inservice Inspection (Subsection IWE)
 
Program (B2.1.23)Consistent with exceptionXI.S1structures and component supports; electrical and
 
instrumentation and controls systems 3.0.3.2.17ASME Section XI Inservice Inspection (Subsection IWL)
 
Program, NMP2 Only (B2.1.24)Consistent with exceptionXI.S2structures and component supports 3.0.3.2.18ASME Section XI Inservice Inspection (Subsection IWF)
 
Program (B2.1.25)Consistent with exceptionXI.S3structures and component supports 3.0.3.2.1910 CFR 50 Appendix J Program (B2.1.26)ConsistentXI.S4auxiliary systems; structures and component supports;
 
electrical and instrumentation and controls systems 3.0.3.1.7Masonry Wall Program (B2.1.27)Consistent with enhancementsXI.S5structures and component supports 3.0.3.2.20 Structures Monitoring Program (B2.1.28)Consistent with enhancementsXI.S6structures and component supports 3.0.3.2.21 Non-EQ Electrical Cables and Connections
 
Used in Instrumentation
 
Circuits Program (B2.1.30)Consistent with enhancementsXI.E2electrical and instrumentationand controls systems 3.0.3.2.22 Non-EQ Inaccessible Medium-Voltage Cables
 
Program, NMP2 Only (B2.1.31)Consistent with enhancementsXI.E3electrical and instrumentationand controls systems 3.0.3.2.27 Preventive Maintenance Program (B2.1.32)Plant-specificengineered safety features;auxiliary systems; steam and power conversion systems;
 
electrical and instrumentation and controls systems 3.0.3.3.1Systems Walkdown Program (B2.1.33)Plant-specificreactor vessel, internals, andreactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems 3.0.3.3.2 Non-Segregated Bus Inspection Program (B2.1.34)Plant-specificelectrical and instrumentationand controls systems 3.0.3.3.3 NMPNS's AMP(ALRA Section)GALL ComparisonGALLAMP(s)ALRA Systems orStructuresThat Credit the AMP Staff's SER Section 3-10Bolting Integrity Program (B2.1.36)Consistent with exception and
 
enhancementsXI.M18NMP1:
reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems NMP2: reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems;
 
structures and component
 
supports 3.0.3.2.23 BWR Control Rod Drive Return Line (CRDRL)
 
Nozzle Program (B2.1.37)Consistent with exceptionsXI.M6reactor vessel, internals, andreactor coolant systems 3.0.3.2.24 Protective Coating Monitoring and
 
Maintenance Program (B2.1.38)Consistent with exceptions and
 
enhancementsXI.S8structures and component supports 3.0.3.2.25 Environmental Qualification Program (B3.1)ConsistentX.E1reactor vessel, internals, andreactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems;
 
structures and component
 
supports 3.0.3.1.9Fatigue Monitoring Program (B3.2)Consistent with enhancementsX.M1reactor vessel, internals, andreactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems;
 
structures and component
 
supports 3.0.3.2.26Torus Corrosion Monitoring Program, NMP1 Only (B3.3)Plant-specificstru ctures and component supports 3.0.3.3.7New AMPs NMPNS's AMP(ALRA Section)GALL ComparisonGALLAMP(s)ALRA Systems orStructuresThat Credit the AMP Staff's SER Section 3-11One-Time Inspection Program (B2.1.20)ConsistentXI.M32NMP1:
reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems;
 
structures and component
 
supports NMP2: reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems 3.0.3.1.4 Selective Leaching of Materials Program (B2.1.21)ConsistentXI.M33NMP1:
reactor vessel, internals, and reactor coolant systems; engineered safety features; auxiliary systems; steam and power conversion systems NMP2:auxiliary systems 3.0.3.1.5Buried Piping and Tanks Inspection Program (B2.1.22)ConsistentXI.M34auxiliary systems 3.0.3.1.6 Non-EQ Electrical Cables and Connections
 
Program (B2.1.29)ConsistentXI.E1electri cal and instrumentationand controls systems 3.0.3.1.8Fuse Holder Inspection Program (B2.1.35)Plant-specificelectrical and instrumentationand controls systems 3.0.3.3.4 Non-EQ Electrical Cable Metallic Connections
 
Inspection Program (B2.1.39)Plant-specificelectrical and instrumentationand controls systems 3.0.3.3.5Wooden Power Pole Inspection Program, NMP2 Only (B2.1.40)Plant-specificstru ctures and component supports 3.0.3.3.6 3-123.0.3.1  AMPs That Are Consistent with the GALL Report In ALRA Appendix B, the applicant identified that the following AMPs were consistent with the GALL Report:
* BWR Vessel ID Attachment Welds Program
* BWR Penetrations Program
* Flow-Accelerated Corrosion Program
* One-Time Inspection Program
* Selective Leaching of Materials Program
* Buried Piping and Tanks Inspection Program
* 10 CFR 50 Appendix J Program
* Non-EQ Electrical Cables and Connections Program
* Environmental Qualification Program 3.0.3.1.1  BWR Vessel ID Attachment Welds Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.4, the applicant described the BWR Vessel ID Attachment Welds Program, stating that this is an
 
existing program that is consistent with GALL AMP XI.M4, "BWR Vessel ID Attachment Welds."
The BWR Vessel ID Attachment Welds Program manages the effects of cracking in reactor
 
pressure vessel inside diameter attachment welds. The BWR Vessel ID Attachment Welds
 
Program is based on industry guidelines issued by the Boiling Water Reactor Vessel Internals
 
Project (BWRVIP) and approved by the staff. Impl ementation of the BWR Vessel ID Attachment Welds Program is discussed in the program description for the BWR Vessel Internals Program (ALRA Section B2.1.8). The attributes of the BWR Vessel ID Attachment Welds Program related
 
to maintaining reactor coolant water chemistry are discussed in the program description for the
 
Water Chemistry Control Program (ALRA Section B2.1.2).
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
As documented in the Audit and Review Report, the staff noted that NMP credited Revisions 1 and 2 of the Electric Power Research Institute (EPRI) TR-103515 guidelines for its reactor
 
coolant water chemistry instead of the GALL Report recommended guidelines in BWRVIP-29.
 
The applicant stated that the "preventive actions" program element is addressed in its Water
 
Chemistry Control Program. The staff's review and evaluation of the applicant's Water
 
Chemistry Control Program are in SER Section 3.0.3.2.2. The staff found this method
 
acceptable.
The staff reviewed those portions of the BWR Vessel ID Attachment Welds Program for whichthe applicant claimed consistency with GALL AMP XI.M4 and found them consistent.
Operating Experience. As documented in the Audit and Review Report, the applicant explained that no industry operating experience with vessel ID attachment weld flaws has emerged since
 
the release of BWRVIP-48; therefore, there is no recent applicable operating experience. The
 
applicant also stated that program changes and updates have resulted from the ongoing review 3-13 of regulatory notices for applicability to the reactor vessel internals. NMP closely monitors theactivity of the BWR Vessel Internals Program and ASME Section XI Code Committees. In these
 
ways, the applicant addresses vessel internal degradation noted at other BWRs systematically
 
and revises BWR Vessel Internals Program inspections accordingly. Operating experience
 
issues affecting NMP1 include core shroud cracking, shroud support weld cracking, control rod
 
drive (CRD) stub tube intergranular stress corrosion cracking (IGSCC) and leakage and top
 
guide cracking. Operating experience issues identified at NMP2 include core shroud cracking
 
and jet pump wedge wear. No other cracking has been identified for vessel internals at either
 
unit.The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that plant-specific operating experience revealed no degradation not
 
bounded by industry experience.
After review of industry and plant-specific experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the applicant's BWR
 
Vessel ID Attachment Welds Program will adequately manage the aging effects and aging
 
effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.11 and A2.1.12, the applicant provided the respective UFSAR and USAR supplements for the BWR Vessel ID Attachment
 
Welds Program. The staff reviewed these sections and determined that the information in the
 
supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWR Vessel ID Attachment Welds Program, the staff determined that those program elements for which the applicant
 
claimed consistency with the GALL Report are consistent with the GALL Report.The staff
 
concludes that there is reasonable assurance that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR 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  BWR Penetrations Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.7, the applicant described the BWR Penetrations Program, stating that this is an existing program that is consistent with GALL AMP XI.M8, "BWR Penetrations." The BWR Penetrations Program
 
manages the effects of cracking in the various penetrations of the reactor pressure vessels. The
 
BWR Penetrations Program is based on guidelines issued by the BWRVIP and approved by the
 
NRC. Implementation of the BWR Penetrations Program is discussed in the program description
 
for the BWR Vessel Internals Program (ALRA Section B2.1.8). The attributes of the BWR
 
Penetrations Program related to maintaining reactor coolant water chemistry are included in the
 
Water Chemistry Control Program (ALRA Section B2.1.2).
3-14 Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
As documented in the Audit and Review Report, the staff noted that NMP credited Revision 1 and Revision 2 of the EPRI TR-103515 guidelines for its reactor coolant water chemistry instead
 
of the GALL Report recommended guidelines in BWRVIP-29. The applicant stated that the
 
"preventive actions" program element is address ed in its Water Chemistry Control Program. The staff's review and evaluation reviewed the applicant's Water Chemistry Control Program are
 
documented in SER Section 3.0.3.2.2. The staff found this method acceptable.
The staff reviewed those portions of the BWR Penetrations Program for which the applicantclaimed consistency with GALL AMP XI.M8 and found them consistent. The staff found the
 
applicant's BWR Penetrations Program acceptable because it conforms to the recommended GALL AMP XI.M8.
Operating Experience. As documented in the Audit and Review Report, the applicant explained that operating experience issues affecting NMP1 include core shroud cracking, shroud support
 
weld cracking, CRD stub tube penetration IGSCC and leakage, and top guide cracking.
 
Operating experience issues identified at NMP2 include core shroud cracking and jet pump
 
wedge wear. No other cracking has been identified for vessel internals at either unit. The
 
applicant also stated that program changes and updates have resulted from the ongoing review
 
of industry operating experience and regulatory notices for applicability to the reactor vessel internals. NMP closely monitors the activity in the BWRVIP and ASME Section XI Code
 
Committees. In these ways the applicant addressed vessel internal degradation noted at other
 
BWRs in a systematic manner and revised the BWRVIP inspections accordingly.
The staff reviewed the operating experience referenced in the ALRA and interviewed the applicant's technical staff to confirm that (1) the plant-specific operating experience did not
 
reveal any degradation not bounded by industry experience and (2) no industry operating
 
experience with penetration and nozzle cracking has emerged since the release of BWRVIP-49
 
and BWRVIP-27.
The staff recognized that the CAP, which captures internal and external plant operating experience issues, ensures operating experience review and incorporation of objective
 
evidence to support the conclusion that the effects of aging will be adequately managed.
UFSAR and USAR Supplements. In ALRA Sections A1.1.8 and A2.1.9, the applicant provided the respective UFSAR and USAR supplements for the BWR Penetrations Program. The staff
 
reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWR Penetrations Program, the staff determined that those program elements for which the applicant claimed consistency
 
with the GALL Report are consistent with the GALL Report. The staff concludes that there is
 
reasonable assurance that the applicant has demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 3-15 the UFSAR 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  Flow-Accelerated Corrosion Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.9, the applicant described the Flow-Accelerated Corrosion (FAC) Program, stating that this is an existing program that is consistent with GALL AMP XI.M17, "Flow-Accelerated Corrosion." The
 
FAC Program, also referred to as the Erosion/Corrosion Program, manages aging effects due to
 
flow-accelerated corrosion in carbon steel and low alloy steel piping containing single-phase
 
and two-phase high-energy fluids. Program activities include: (1) analysis using a predictive
 
code (CHECWORKS) to determine critical locations, (2) baseline inspections to determine the
 
extent of thinning at the selected locations, (3) follow-up inspections to confirm the predictions, and (4) repair or replacement of components, as necessary. The inspection results provide
 
input to the predictive computer code to calcul ate the number of refueling or operating cycles remaining before the component reaches the minimum allowable wall thickness. If the
 
component trend indicates that an area will reach the minimum allowed thickness before the
 
next scheduled outage, the component is repaired, replaced, or re-evaluated. The program
 
considers the recommended actions in NRC Bulletin 87-01 and Information Notice (IN) 91-18, and implements the guidelines for an effect ive FAC program presented in EPRI Report NSAC-202L-R2. The program also implements the recommendations provided in NRC generic letter (GL) 89-08, "Erosion/Corrosion Induced Pipe Wall Thinning."
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
As documented in the Audit and Review Report, the staff requested that the applicant clarify the minimum acceptable wall thickness defined in its FAC Program. The applicant stated that its
 
FAC Program minimum acceptable wall thickness is the thickness required by the design code
 
to withstand design loads. The applicant's FAC Program uses 87.5 percent of the nominal wall
 
thickness as the first threshold for minimum wall thickness because newly purchased pipe to a
 
nominal design specification could have actual wall thickness as low as 87.5 percent of the
 
nominal wall thickness. The applicant also explained that if degradation is detected such that
 
the measured wall thickness is less than the minimum predicted thickness it will take additional
 
examinations in adjacent areas and at similar locations in sister trains/parallel lines to bound the
 
thinning and ensure that the actual minimum wall is measured. Because the applicant is using
 
an industry-accepted 87.5 percent of the nominal pipe wall thickness based on the piping
 
manufacturer's design tolerance for the minimum acceptable wall thickness determination and
 
because the applicant is following the EPRI Report NSAC-202L-R2, "Recommendations for an
 
Effective Flow Accelerated Corrosion Program," for selection of the sampling size the staff found
 
this explanation satisfactory.
The staff found the applicant's FAC Program acceptable because it conforms to therecommended GALL XI.M17 as claimed by the applicant in the ALRA.
3-16 Operating Experience. In ALRA Section B2.1.9, the applicant explained that wall thinning problems in single- and two-phase systems have occurred throughout the industry, as documented in various NRC Bulletins and INs. NMPNS reviewed both industry and
 
plant-specific operating experience in establishing the basis for the FAC Program, which is
 
continually adjusted to account for further industry experience and research.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience did not reveal any
 
degradation not bounded by industry experience.
As documented in the Audit and Review Report, the staff asked the applicant how well the CHECWORKS model predictions compared with the actual field measurements. The applicant
 
informed the staff that the specific software inputs pertaining to the NMP application have been
 
verified properly and tested satisfactorily. Although minor changes in wall thickness were
 
detected the measurements confirmed that ov erall the CHECWORKS model was conservative.
The applicant also stated that the model will be updated periodically, refined, and calibrated
 
based on the comparison of inspection data with predicted wear rates.
As documented in the Audit and Review Report, the staff reviewed the applicant's carbon steel piping erosion/corrosion program review plan fo r high energy systems. This procedure lists all NMP1 SSCs inspected in the applicant's FAC Program. The staff noted that plant-specific
 
operating experience has been incorporated into this procedure. The staff also sampled several
 
condition reports (CRs) that resulted from flow-accelerated corrosion inspections. The staff
 
noted that these inspection results were evaluated and documented properly. The staff also
 
noted that the applicant's FAC Program resulted in the identification and replacement of
 
susceptible piping sections with materials more resistant to FAC. For example, in 1997, at NMP, the reheater drain line inlet nozzles to the fifth point feedwater heat exchangers were found to
 
be degrading due to FAC. As a corrective measure FAC-resistent materials were used to
 
replace these piping components and in 2002 at NMP2 a second point feedwater heat
 
exchanger low pressure drain line leaked before its scheduled FAC inspection. The degraded
 
low pressure heater drain lines were replaced with FAC-resistent chrome-moly piping material.
 
Based on this review, the staff concludes that continued review of operating experience will
 
ensure that FAC aging effects will be adequately managed.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's FAC Program will adequately manage the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.19 and A2.1.19, the applicant provided the respective UFSAR and USAR supplements for the FAC Program. The staff
 
reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's FAC Program, the staff determined that those program elements for which the applicant claimed consistency with the
 
GALL Report are consistent with the GALL Report.The staff concludes that there is reasonable
 
assurance that the applicant demonstrated that the effects of aging will be adequately managed
 
so that the intended functions will be maintained consistent with the CLB for the period of 3-17 extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR 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  One-Time Inspection Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.20, the applicant described the One-Time Inspection Program, stating that this is a new program that is consistent with GALL AMP XI.M32, "One-Time Inspection." The One-Time Inspection Program
 
manages aging effects with potentially long incubation periods for susceptible components
 
within the scope of license renewal. Program activities include visual, volumetric, and other
 
established inspection techniques consistent wi th industry practice to provide a means of verifying that an aging effect is either not occurring or progressing so slowly that it has a
 
negligible effect on the intended function of the structure or component. The program also
 
provides measures for verifying the effectiv eness of existing AMPs. If a one-time inspection reveals an AERM, an evaluation is required to determine the ability of the affected component to
 
perform its intended function(s) during the period of extended operation and any appropriate
 
corrective action. For stagnant or low flow areas in treated-water systems, the One-Time
 
Inspection Program will determine the effectivene ss of the Water Chemistry Control Program in managing the effects of aging. For Class 1 piping less than four inches in diameter (nominal
 
pipe size) that is directly connected to the reactor coolant pressure boundary, the One-Time
 
Inspection Program will determine if cracking is occurring. If a flaw is detected, appropriate
 
additional examinations will be performed usi ng methods currently employed for similarcomponents within the scope of the ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program. Selective leaching is also part of the One-Time Inspection Program. It is
 
an aging effect that occurs very slowly, and NMPNS has identified potentially susceptible
 
components in various systems.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
The staff reviewed those portions of the One-Time Inspection Program for which the applicantclaimed consistency with GALL AMP XI.M32 and found them consistent. The staff found the
 
applicant's One-Time Inspection Program acceptable because it conforms to the recommended GALL AMP XI.M32.
Operating Experience. In ALRA Section B2.1.20, the applicant explained that the One-Time Inspection Program is a new program at NMPNS; therefore, no programmatic operating
 
experience is available.
The staff recognized that the CAP captures internal and external plant operating experience issues and ensures review and incorporation of operating experience for objective evidence to
 
support the conclusion that the effects of aging are adequately managed.
UFSAR and USAR Supplements. In ALRA Sections A1.1.28 and A2.1.28, the applicant provided the respective UFSAR and USAR supplements for the One-Time Inspection Program.
3-18 The staff reviewed these sections and determined that the information in the supplements provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's One-Time Inspection Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report.The staff concludes that there is reasonable assurance that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR 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  Selective Leaching of Materials Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.21, the applicant described the Selective Leaching of Materials Program, stating that this is a new program that is consistent with GALL AMP XI.M33, "Selective Leaching of Materials." The
 
Selective Leaching of Materials Program manages aging of components susceptible to selective leaching. The potentially susceptible components include valve bodies, valve bonnets, pump
 
casings, and heat exchanger components in various systems. Implementation of the Selective Leaching of Materials Program is discussed in the program description for the One-Time
 
Inspection Program.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute. The staff
 
found the applicant's Selective Leaching of Materials Program acceptable because it conforms to the recommended GALL AMP XI.M33.
Operating Experience. In ALRA Section B2.1.21, the applicant explained that the Selective Leaching of Materials Program is implement ed through its One-Time Inspection Program.
However, the applicant has had plant-specific operating experience with selective leaching.
As documented in the Audit and Review Report, the staff reviewed the operating experience in the ALRA for the applicant's Selective Leaching of Materials Program and interviewed the
 
applicant's technical staff. The staff determined that the plant-specific operating experience
 
revealed no degradation not bounded by industry experience.
UFSAR and USAR Supplements. In ALRA Sections A1.1.33 and A2.1.33, the applicant provided the respective UFSAR and USAR supplements for the Selective Leaching of Materials
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Selective Leaching of Materials Program, the staff determined that those program elements for which the applicant
 
claimed consistency with the GALL Report are consistent with the GALL Report.The staff
 
concludes that there is reasonable assurance that the applicant demonstrated that the effects of 3-19 aging will be adequately managed so that the intended functions 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 UFSAR 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 Amended Application. In ALRA Section B2.1.22, the applicant described the Buried Piping and Tanks Inspection Program, stating that this is a new program that is consistent with GALL AMP XI.M34, "Buried Piping and Tanks Inspection." The
 
Buried Piping and Tanks Inspection Program will manage the aging effects on the external
 
surfaces of carbon steel, low-alloy steel, and cast iron components (e.g., tanks, piping) that are
 
buried in soil. Program activities will include visual inspections of external coatings and
 
wrappings to detect damage and degradation. Periodicity of inspections will be based on plant
 
operating experience and opportunities for inspection due to maintenance. If an opportunistic
 
inspection does not occur within the first ten years of extended operation, NMPNS will excavate a representative sample for the purpose of inspection.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
In ALRA Section B2.1.22 the applicant stated that its new Buried Piping and Tanks Inspection Program will manage the aging effects and aging effects mechanisms on the external surfaces
 
of carbon steel, low-alloy steel, and cast iron components buried in soil. However, GALL AMP XI.M.34 states that the program manages the effects of corrosion on the
 
pressure-retaining capacity of buried carbon steel piping and tanks. During the staff audit and
 
review of the original LRA documented in the March 3, 2005, initial Audit and Review Report (ML050660380) the staff asked the applicant to explain how aging effects and aging effects
 
mechanisms of cast iron and low-alloy components will be managed, e.g., how selective
 
leaching for cast iron will be detected and managed. The applicant responded that low alloy
 
steel and malleable cast iron are in the same material group as carbon steel with similar AERM.
 
Selective leaching is a gray cast iron AERM that will be diagnosed by visual inspection and
 
hardness measurement of selected samp les. These hardness measurements will be administered under the Selective Leaching of Materials Program.
The staff found the applicant's response acceptable. Low alloy steel and malleable cast iron have similar aging effects and aging effects mechanisms as carbon steel and selective leaching
 
for cast iron components will be discovered by hardness testing. These hardness
 
measurements will be administered under the Selective Leaching of Materials Program.
The following sentence has been added to ALRA Section B2.1.22, Buried Piping and Tanks Inspection Program, under the program description (Page B2-51): "If an opportunistic inspection
 
does not occur within the first ten years of extended operation, NMPNS will excavate a
 
representative sample for the purpose of inspection." The staff asked the applicant to explain
 
why the program description in the ALRA for its Buried Piping and Tanks Inspection Program
 
was revised to address the possible need for focused inspections for only the first 10-year
 
period of extended operation and not also for the 10-year period prior to extended operation.
3-20 The applicant responded that its Buried Piping and Tanks Inspection Program was incomplete and that the ALRA will be amended to address the need for possible focused inspections during
 
the 10-year period prior to extended operation.
In its letter dated December 1, 2005, the applicant stated that Sections A1.1.6, A2.1.7, and B2.1.22 under the program description of the ALRA will be revised to read as follows:
The Buried Piping and Tanks Inspection Program is a new program that will manage the aging effects/mechanisms on the external surfaces of carbon steel, low-alloy steel, and cast iron components (e.g. tanks, piping) that are buried in
 
soil. Program activities will include visual inspections of external coatings and
 
wrappings to detect damage and degradation. Prior to entering the period of
 
extended operation, NMP will verify that there has been at least one opportunistic
 
or focused inspection within the past ten years. Upon entering the period of
 
extended operation, NMP will perform a focused inspection within ten years, unless an opportunistic inspection occurred within this ten year period. All
 
credited inspections will be performed in areas with the highest likelihood of
 
corrosion problems, and in areas with a history of corrosion problems.
Sections A1.1.6 and A2.1.7 include the following additional last sentence:
This program will be implemented prior to the period of extended operation.
The staff found the applicant's response acceptable. With the clarification statements added by the applicant to the ALRA to perform focused inspections as needed 10 years prior and within
 
the first 10 years of license extension, the applicant's Buried Piping and Tank Inspection Program is now consistent with Element 4 of GALL AMP XI.M34.
The staff reviewed those portions of the Buried Piping and Tanks Inspection Program for whichthe applicant claimed consistency with GALL AMP XI.M34 and found them consistent. The staff
 
found the applicant's Buried Piping and Tanks Inspection Program acceptable because it conformed to the recommended GALL AMP XI.M34.
Operating Experience. In ALRA Section B2.1.22, the applicant explained that the Buried Piping and Tanks Inspection Program is a new program at NMPNS; therefore, no programmatic
 
operating experience is available.
The staff reviewed the operating experience provi ded in the ALRA (however, only information about related plant-specific and industry experience was available) and interviewed the
 
applicant's technical staff to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
The staff recognized that the CAP, which captures internal and external plant operating experience issues, ensures operating experience review and incorporation for objective
 
evidence to support the conclusion that the effects of aging are adequately managed.
UFSAR and USAR Supplements. In ALRA Sections A1.1.6 and A2.1.7, the applicant provided the respective UFSAR and USAR supplements for the Buried Piping and Tanks Inspection
 
Program. The staff reviewed these sections and determined that the information in the 3-21 supplements provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Buried Piping and Tanks Inspection Program, the staff determined that those program elements for which the applicant
 
claimed consistency with the GALL Report are consistent with the GALL Report.The staff
 
concludes that there is reasonable assurance that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR 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  10 CFR Part 50, Appendix J Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.26, the applicant described the 10 CFR Part 50, Appendix J Program, stating that this is an existing program that is consistent with GALL AMP XI.S4, "10 CFR Part 50, Appendix J." The
 
10 CFR Part 50, Appendix J Program [or Containment Leak Rate Test (LRT) Program] detects
 
degradation of the containment structure and components that comprise the containment
 
pressure boundary, including seals and gaskets. The program is not relied on to detect the
 
onset or progression of degradation prior to it resulting in leakage. Containment leak rate tests
 
are performed to assure that leakage through the primary containment and systems and
 
components penetrating primary containment does not exceed allowable leakage limits specified in the technical specifications (TSs). Type A tests measure the primary reactor
 
containment overall integrated leakage rate, and include visual examination of the interior and
 
exterior surfaces of the containment for evidence of structural deterioration. Type B tests
 
measure leakage across each pressure-containing or leakage-limiting boundary, including: (1)
 
containment penetrations whose design incorporates resilient seals, gaskets, or sealant
 
compounds; (2) piping penetrations fitted with expansion bellows; (3) electrical penetrations
 
fitted with flexible metal seal assemblies; (4) air lock door seals; and (5) doors with resilient
 
seals or gaskets. Type C tests measure the leakage rates for containment isolation valves.
Staff Evaluation. During its audit and review, the staff reviewed those portions of the 10 CFR Part 50, Appendix J, Program for which the applicant claimed consistency with GALL AMP XI.S4 to confirm the applicant's claim of consistency with the GALL Report. Details of the
 
staff's evaluation of this AMP are documented in the Audit and Review Report dated January 18
 
2006. The staff determined that this AMP is consistent with the AMP described in the GALL
 
Report, including the associated operating experience attribute.
Operating Experience. In ALRA Section B2.1.26, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Containment LRT Program.
 
Neither NMP1 nor NMP2 has experienced in the past two refueling outages a total leakage rate
 
above Containment LRT Program acceptance criteria.
As documented in the Audit and Review Report, in response to the staff's inquiry the applicant stated that during the past two refueling outages the CAP identified no problems affecting its
 
Appendix J Program. In March-May 2004 the Appendix J Program was appraised to be sound
 
by the applicant's self-assessment and by an external independent organization. The staff noted
 
that the applicant has demonstrated good operating experience in maintaining the integrity of 3-22 the primary containment boundaries as shown by the selection of Option B of 10 CFR Part 50, Appendix J leakage testing requirements at established frequencies consistent with plant
 
experience.
The staff sampled several items on the CR list that were associated with the containment LRT testing and did not identify any items related to the 10 CFR Part 50, Appendix J Program that
 
would necessitate a change to NMP AMP B2.1.26.
The staff reviewed the operating experience provided in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
The staff found that based on the review of operating history, corrective actions, and self-assessments the applicant's 10 CFR Part 50 Appendix J Program is monitored continually
 
and enhanced to incorporate the results of operating experience; as such it provides an
 
effective means of managing aging affecting the structural integrity and leakproof tightness of
 
the NMP containments.
After review of plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the applicant's 10 CFR 50
 
Appendix J Program will adequately manage the aging effects and aging effects mechanisms
 
identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.1 and A2.1.1, the applicant provided the respective UFSAR and USAR supplements for the 10 CFR Part 50, Appendix J Program.
 
The staff reviewed these sections and determined that the information in the supplements
 
provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's 10 CFR Part 50, Appendix J Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report.The staff concludes that there is reasonable assurance that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR 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  Non-EQ Electrical Cables and Connections Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.29, the applicant described the Non-EQ Electrical Cables and Connections Program, stating that this is a new program that is consistent with GALL AMP XI.E1, "Electrical Cables and Connections Not
 
Subject to 10 CFR 50.49 Environmental Qualification Requirements." The Non-EQ Electrical
 
Cables and Connections Program manages aging of cables and connectors within the scope of
 
license renewal exposed to adverse localized tem perature, moisture, or radiation environments.
Program activities include visual inspection of susceptible cables for evidence of cable and
 
connection jacket surface anomalies. Inspections are conducted at least once every ten years, with the first representative sample of susceptible cables inspected prior to expiration of the
 
current NMPNS licenses.
3-23 Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
The staff reviewed those portions of the Non-EQ Electrical Cables and Connections Program forwhich the applicant claimed consistency with GALL AMP XI.E1 and found them consistent. The
 
staff found the applicant's Non-EQ Electrical Cables and Connections Program acceptable because it conformed to the recommended GALL AMP XI.E1.
Operating Experience. In ALRA Section B2.1.29, the applicant explained that the Non-EQ Electrical Cables and Connections Program is a new program at NMPNS; therefore, no programmatic operating experience is available.
The staff reviewed the plant-specific operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
As stated in the Audit and Review Report, the applicant will thoroughly review accessible non-EQ cables and connections documents (e.g., bulletins, letters, notices, advisories, et
 
cetera) for applicability. If these documents are affecting or thought to affect NMP, the applicant
 
will enter these documents into its CAP for resolution. Other nuclear power plants operating
 
experience reports are reviewed to assess pot ential impact to NMP. Operating experience found to be applicable to NMP is added to its CAP for resolution.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's Non-EQ Electrical Cables and Connections Program will adequately manage the aging effects and aging effects mechanisms identified in the ALRA for which this AMP is
 
credited.The staff recognizes that the CAP captures internal and external plant operating experience issues and ensures operating experience review and incorporation for objective evidence to
 
support the conclusion that the effects of aging are adequately managed.
UFSAR and USAR Supplements. In ALRA Sections A1.1.24 and A2.1.24, the applicant provided the respective UFSAR and USAR supplem ents for the Non-EQ Electrical Cables and Connections Program. The staff reviewed these sections and determined that the information in
 
the supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Non-EQ Electrical Cables and Connections Program, the staff determined that those program elements for which the applicant
 
claimed consistency with the GALL Report are consistent with the GALL Report.The staff
 
concludes that there is reasonable assurance that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR supplement for this AMP and concludes that it provides an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3-24 3.0.3.1.9  Environmental Qualification Program Summary of Technical Information in the Amended Application. In ALRA Section B3.1, the applicant described the Environmental Qualification Program, stating that this is an existing program that is consistent with GALL AMP X.E1 , "Environmental Qualification (EQ) of Electric Components." The Environmental Qualification (EQ) Program manages thermal, radiation, and
 
cyclical aging for electrical equipment important to safety and located in harsh plant
 
environments at NMPNS. At NMP2, the EQ Pr ogram also manages these effects for active safety-related mechanical equipment located in har sh plant environments. EQ program activities (1) identify applicable equipment and environmental requirements; (2) establish, demonstrate, and document the level of qualification (including configuration, maintenance, surveillance, and
 
replacement requirements); and (3) maintain (or preserve) qualification. The EQ Program
 
employs aging evaluations based on 10 CFR 50.49(f) qualification methods. Components in the
 
EQ Program must be refurbished, replaced, or have their qualification extended prior to
 
reaching the aging limits established in the eval uation. Aging evaluations for environmentally qualified components that specify a qualification of at least 40 years are considered time-limited
 
aging analysis (TLAAs) for license renewal. The EQ Program ensures that these SSCs are
 
maintained within the bounds of their qualification bases.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's evaluation of this AMP are documented
 
in the Audit and Review Report. The staff determined that this AMP is consistent with the AMP
 
described in the GALL Report, including the associated operating experience attribute.
As documented in the Audit and Review Report, the staff identified one difference between the GALL AMP and the NMP EQ Program description.
EQ of electrical equipment in ALRA Section 4.4 indicates that the aging effects and aging effects mechanisms of the EQ of electrical
 
equipment identified in the TLAA will be managed during the extended period of operation under
 
10 CFR 54.21(c)(1)(iii). However, as documented in the Audit and Review Report, no
 
information is provided on reanalysis of an aging evaluation to extend the qualification life of
 
electrical equipment identified in the TLAA. Important attributes of a reanalysis are analytical
 
methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions. GALL AMP X.E1 under the EQ component reanalysis attributes
 
describes each attribute under the program description. The EQ Program does not include this
 
information.
As documented in the Audit and Review Report, the staff requested that the applicant addressthe reanalysis attributes listed in GALL AMP X.E1 or justify why this information was not
 
included. In response to this request, the applicant informed the staff that it agreed to include
 
the detailed EQ component reanalysis attributes in its NMP AMP. The staff concludes that the
 
applicant's response is acceptable because the NMP AMP will be consistent with the GALL
 
Report AMP program description. In its letter dated December 1, 2005, the applicant revised its
 
ALRA to included a detailed description of reanalysis attributes.
As documented in the Audit and Review Report, the staff also asked if the applicant has plans to monitor temperature in order to extend t he qualified life of components if the EQ reanalysis option is chosen. The applicant's response recognized that thermal aging is limiting component
 
life. It plans to incorporate actual plant temperature monitoring data into the aging evaluation
 
reanalysis for EQ components with a qualified life greater than 40 years similar to the 3-25 temperature monitoring data used to assess equipment qualified life during the current operation period to represent existing plant thermal conditions accurately.
The staff reviewed those portions of the EQ Program for which the applicant claimedconsistency with GALL AMP X.E1 and found them consistent. The staff found the applicant's EQ Program acceptable because it conforms to the recommended GALL AMP X.E1.
Operating Experience. In ALRA Section B3.1, the applicant explained that the EQ Program started in 1980 as a project at NMP1, and was developed as an integral part of construction at
 
NMP2. Since its inception, consideration of plant and industry operating experience has been
 
an important element of the EQ Program. Re corded measurements of ambient temperature have been used to define conditions for some harsh environments, and records of
 
representative actual temperatures have been used as preliminary data to resolve concerns forcertain terminal blocks installed in the NMP1 drywell. Qualified life evaluations for certain
 
sealing materials and lamp assemblies were reevaluated to remove excess conservatism and
 
eliminate unnecessary maintenance activities.
The program is evolving as administrative improvements have been identified to addre ss issues such as communication and organizational transitions. A major program reconstitution effort began in 2003, in response to
 
internal assessments, to improve the overa ll strength of the EQ Program. With additional operating experience lessons learned will be used to adjust this program as needed. The
 
applicant's EQ Program has been effective in m anaging thermal, radiative, and cyclical aging of components within the scope of 10 CFR 50.49.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's EQ Program will adequately manage the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.15 and A2.1.15, the applicant provided the respective UFSAR and USAR supplements for the Environmental Qualification
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Environmental Qualification Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report.The staff concludes that there is reasonable assurance that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR 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 That Are Consistent with the GALL Report with Exceptions or Enhancements 3-26 In ALRA Appendix B, the applicant identified that the following AMPs were, or will be, consistent with the GALL Report, with exception(s) or enhancement(s):
* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Water Chemistry Control Program
* Reactor Head Closure Studs Program
* BWR Feedwater Nozzle Program
* BWR Stress Corrosion Cracking Program
* BWR Vessel Internals Program
* Open-Cycle Cooling Water System Program
* Closed-Cycle Cooling Water System Program
* Boraflex Monitoring Program (NMP1 Only)
* Inspection of Overhead Heavy Load and Light Load Handling Systems Program
* Compressed Air Monitoring Program (NMP1 Only)
* BWR Reactor Water Cleanup System Program
* Fire Protection Program
* Fire Water System Program
* Fuel Oil Chemistry Program
* Reactor Vessel Surveillance Program
* ASME Section XI Inservice Inspection (Subsection IWE) Program
* ASME Section XI Inservice Inspection (Subsection IWL) Program (NMP2 Only)
* ASME Section XI Inservice Inspection (Subsection IWF) Program
* Masonry Wall Program
* Structures Monitoring Program
* Non-EQ Electrical Cables and Connecti ons Used in Instrumentation Circuits Program
* Bolting Integrity Program
* BWR Control Rod Drive Return Line (CRDRL) Nozzle Program
* Protective Coating Monitoring and Maintenance Program
* Fatigue Monitoring Program
* Non-EQ Inaccessible Medium Voltage Cables Program (NMP2 Only)
For AMPs that the applicant claimed are consistent with the GALL Report, with exceptions or enhancements, the staff performed an audit to confirm that those attributes or features of the
 
program for which the applicant claimed consistency with the GALL Report were indeed
 
consistent. The staff also reviewed the exceptions and enhancements to the GALL Report to
 
determine whether they were adequate and acceptable. The results of the staff's audit and
 
reviews are documented in the following sections.3.0.3.2.1  ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.1, theapplicant described the ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD)
 
Program, stating that this is an existing program that is 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, IWD) Program (referred to
 
herein as the IWB/C/D ISI Program) manages aging of Class 1, 2, and 3 pressure-retaining
 
components and their integral attachments. Program activities include periodic visual, surface, and/or volumetric examination and pressure tests of Class 1, 2, and 3 pressure-retaining components. The IWB/C/D ISI Program is based on ASME Section XI, 1989 edition, with no 3-27Addenda and ASME Section XI, Appendix VIII, 1995 Edition through 1996 Addenda.
Examination categories B-F, B-J, C-F-1, C-F- 2 and IGSCC Category A are inspected using the
 
EPRI risk-informed methodology and implement ed in accordance with ASME Code Case N-578-1 as approved by NRC plant-specific Relief Request.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exception and the
 
associated justifications to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.
The staff reviewed those portions of the IWB/C/D ISI Program for which the applicant claimedconsistency with GALL AMP XI.M1 and found them consistent. The staff found the applicant's IWB/C/D ISI Program acceptable because it conforms to the recommended GALL AMP XI.M1
 
with exception.
In the ALRA the applicant stated that its IWB/C/D ISI Program is consistent with the GALL Report with exception in the "detection of aging effects" and "monitoring and trending" program elements. The program is based on the 1989 Edition of ASME Section XI with no addenda.
 
Examination categories B-F, B-J, C-F-1, and C-F-2 and IGSCC Category A are inspected per
 
the requirements of the EPRI risk-informed methodology and ASME Code Case N-578-1.
In addition in the ALRA the applicant stated that its IWB/C/D ISI Program based on the 1989 Edition with no addenda was found acceptable by the NRC in safety evaluations (SEs) dated
 
October 5, 2000 and March 3, 2000, and that the IWB/C/D ISI Program for NMP1 and NMP2
 
implement the EPRI risk-informed methodology and ASME Code Case N-578-1 as approved by the staff in an NRC plant-specific relief request.
The GALL Report states that the 1989 Code Edition covers all examination categories identified in the 1995 Edition through the 1996 Addenda and that the 1995 ASME Code Edition eliminates
 
the hydrostatic test because equivalent results are obtained from the leakage test. The staff
 
also compared the acceptance criteria differences between the 1989 and 1995 Editions through the 1996 Addenda of ASME Section XI. The staff found the acceptance criteria of the 1989
 
Edition more conservative than those of the 1995 Edition through the 1996 Addenda.
 
Subsection IWB-3640 in the 1989 Edition sets the acceptable flaw depth upper limit as 60
 
percent of wall thickness whereas Subsection IWB-3640 in the 1995 Edition through the 1996
 
Addenda sets the acceptable flaw depth upper limit as 75 percent of wall thickness for shielded
 
metal-arc welds and submerged arc welds. The staff also reviewed the SERs for the NMP ISI plans based on the ASME Section XI 1989 Edition. On this basis, the staff finds the code edition
 
exception acceptable.
As documented in the Audit and Review Report, the staff noted that the applicant's risk-informed Inservice inspection (RI-ISI) relief request is valid for a 10-year inspection interval under the CLB and requested that the applicant provide additional justification for extending this
 
risk-informed relief request for the period of extended operation. In its letter dated
 
December 1, 2005, the applicant stated that the program description had been revised by
 
deleting "using the EPRI risk-informed methodology and implemented in accordance with ASME
 
Code Case N-578-1 as approved by the NRC plant-specific Relief Request" and inserting "using
 
NRC approved Risk-Informed Methodology." Prior to the period of extended operation, the ISI 3-28Program will be updated to the latest Edition and Addenda of ASME Section XI as mandated by 10 CFR 50.55a and 10 CFR Part 54 requirements." At present, an RI-ISI program is approved
 
for use on an ASME Code 10-year ISI for specific intervals. However, the applicant will have to request approval to use the RI-ISI program for spec ific intervals 12 months prior to each interval during the period of extended operation under 10 CFR 50.55a. Therefore, the staff determined that the ASME Section XI code in effect referenced in 10 CFR 50.55a, for which the applicant
 
will request approval 12 months prior to each inspection interval, is acceptable for the period of
 
extended operation. The staff concludes that the applicant's response is acceptable.
The staff determined that although the number of the examinations is reduced, the risk from implementation of RI-ISI is expected to decrease slightly from that estimated from the current requirements. The primary reason for the risk reduc tion is that examinations will be required for piping segments of safety significance that may not be inspected per the existing ASME Section XI Program. In addition the RI-ISI program is on ongoing program that requires update
 
and expansion based on industry and site-specific in spection findings. On this basis the staff finds this exception acceptable.
Operating Experience. In ALRA Section B2.1.1, the applicant explained it has reviewed both industry and plant-specific operating experience relating to the IWB/C/D ISI Program. Review of
 
plant-specific operating experience revealed CRs documenting indications of flaws in
 
recirculation components, piping, and various nozzle connection welds. Deficiencies identified
 
by IWB/C/D ISI Program activities have been repaired, replaced, or evaluated as acceptable in accordance with ASME Section XI and station implementing procedures.
The staff reviewed the applicant's supporting documents that evaluate industry experiences as identified in General Electric (GE) service info rmation letters (SILs) against the applicant's ISI Program. The staff determined that the applicant continuously evaluates industry operating
 
experience and adjusts its inspection plans accordingly.
The staff also reviewed the applicant's CAP, which revealed that CRs were initiated when ISI inspections found stress corrosion cracking (SCC) in the reactor coolant system. The staff
 
reviewed the applicant's CRs as described in the Audit and Review Report and found that the
 
applicant's ISI Program is effective in identifying degradation and implementing repairs.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's IWB/C/D ISI Program will adequately manage the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. The applicant provided its UFSAR and USAR supplements for the IWB/C/D ISI Program in ALRA Section A1.1.4 for NMP1 and Section A2.1.5 for NMP2
 
stating that the program manages aging of Class 1, 2, or 3 pressure-retaining components and
 
their integral attachments. Program activities include periodic visual surface or volumetric
 
examinations and pressure tests of Class 1, 2, and 3 pressure-retaining components. The applicant also stated that its IWB/C/D ISI Program is based on the ASME Section XI 1989 3-29Edition with no Addenda and ASME Section XI, Appendix VIII, 1995 Edition through 1996 Addenda. Examination categories B-F, B-J, C-F-1, and C-F-2 and IGSCC Category A are
 
inspected using EPRI risk-informed methodology and implemented in accordance with ASME Code Case N-578-1 as approved by an NRC plant-specific relief request. These are program exceptions described in the GALL Report (which cites ASME Section XI requirements covered
 
in the 1995 Edition through the 1996 Addenda).
As documented in the Audit and Review Report, the staff noted that the applicant's RI-ISI relief request is valid for a 10-year inspection interval under the CLB and requested that the applicant
 
provide additional justification for extending this risk-informed relief request for the period of
 
extended operation. The applicant stated that it would revise Appendix A to remove that relief
 
request. In its letter dated December 1, 2005, the applicant stated that ALRA Sections A1.1.4
 
and A2.1.5 have been revised by deleting "using the EPRI risk-informed methodology and
 
implemented in accordance with ASME Code Case N-578-1 as approved by the NRC
 
plant-specific Relief Request" and replacing it with "using NRC approved Risk-Informed
 
Methodology." Prior to the period of extended operation, the ISI Program will be updated to the latest Edition and Addenda of ASME Section XI as mandated by 10 CFR 50.55a and 10 CFR 54
 
requirements." The staff reviewed the applicant's response, found the revised information to be
 
adequate, and concludes that it is acceptable. The staff reviewed these sections and
 
determined that the information in the UFSAR and USAR supplements also provides adequate
 
summary program descriptions required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's IWB/C/D ISI Program, the staff determined that those program elements for which the applicant claimed consistency with
 
the GALL Report are consistent with the GALL Report. In addition, the staff reviewed the
 
exception and the associated justifications, and determined that the AMP, with the exception, is
 
adequate to manage the aging effects for which it is credited.The staff concludes that there is
 
reasonable assurance that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR and USAR supplements for this AMP and concludes that the supplements provide
 
an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.2  Water Chemistry Control Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.2, the applicant described the Water Chemistry Control Program, stating that this is an existing
 
program that is consistent, with exceptions, with GALL AMP XI.M2, "Water Chemistry." The Water Chemistry Control Program manages aging effects by controlling the internal
 
environment of the reactor water, feedwater, condensate, and control rod drive systems, and related auxiliaries (such as the NMP1 torus, NMP2 suppression pool, condensate storage tank, and spent fuel pool). The aging effects of concern are loss of material and crack initiation and
 
growth. Program activities include monitoring and controlling concentrations of known
 
detrimental chemical species below the levels known to cause degradation. The Water
 
Chemistry Control Program implements the gui delines for BWR water chemistry presented in Electric Power Research Institute (EPRI) Reports TR-103515-R1 and TR-103515-R2. The
 
Water Chemistry Control Program credits activities performed under the direction of the ASME Section XI Inservice Inspection (IWB, IWC, IWD) Program and the One-Time Inspection
 
Program to verify program effectiveness, including areas of low flow or stagnant water.
3-30 Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exceptions and the
 
associated justifications to determine whether the AMP, with the exceptions, remains adequate
 
to manage the aging effects for which it is credited.
The staff reviewed those portions of the Water Chemistry Control Program for which theapplicant claimed consistency with GALL AMP XI.M2 and found them consistent. The staff
 
found the applicant's Water Chemistry Control Program acceptable because it conforms to the recommended GALL AMP XI.M2 with exceptions.
In the ALRA the applicant stated that its Water Chemistry Control Program is consistent with the GALL Report with an exception to the "scope of program" program element. The program described in GALL AMP XI.M2 identifies the EPRI TR-103515-R0 report as the basis for BWR
 
water chemistry programs. EPRI periodically updates the water chemistry guidelines as new industry experience becomes available. Revisions 1 and 2 of the EPRI report incorporate
 
industry experience and are the basis for the NM P1 Water Chemistry Control Program whereas NMP2 uses only TR-103515 Revision 2.
The specific impacts of this scope of program exception are addressed with the program elements affected by the use of later revisions of the EPRI TR-103515 so no evaluation is
 
provided for the "scope of program" element.
The applicant also stated in the ALRA that its Water Chemistry Control Program has an exception to the "parameters monitored/ins pected" program element. The program described inGALL AMP XI.M2 identifies the EPRI TR-103515-R0 report as the basis for BWR water
 
chemistry programs. EPRI TR-103515-R0 recommends that electrochemical potential (ECP) be monitored during power operations and does not distinguish between normal water chemistry
 
and hydrogen water chemistry (HWC). The NMP1 pr ogram takes an exception in that ECP is monitored only under HWC operation. The NMP2 program also takes an exception by not
 
monitoring ECP directly but the molar ratio of hydrogen-to-oxygen as an acceptable alternative.
The GALL Report also recommends that hydr ogen peroxide be monitored to manage stress corrosion cracking and corrosion in BWR plants. Both NMP1 and NMP2 programs takes
 
exceptions to this recommendation because accurate measurement of this chemical is
 
extremely difficult due to its rapid decomposition in the sample lines. As an alternative
 
consistent with Revision 2 of the EPRI report NMP1 measures ECP and NMP2 measures the
 
molar ratio of hydrogen to oxygen.
With regard to the NMP1 exception of monitoring ECP only when under HWC, EPRI TR-10315 Revision 2 recommends, based on the latest industry experience, that ECP be monitored only if
 
plants implement HWC or HWC with noble metal chemical addition (NMCA). Based on the
 
latest industry information the staff found this practice acceptable. In regard to NMP2 the
 
applicant stated in the ALRA that it does not monitor ECP directly but rather the molar ratio of
 
hydrogen to oxygen as an acceptable alternative based on the latest industry guidance of EPRI
 
TR-10315 Revision 2. The staff found acceptable this use of an alternative measurement
 
providing the same level of effectiveness.
From review of the information provided in the ALRA the staff determined that the applicant proposed acceptable alternative methods for both NMP1 and NMP2 for measuring the level of 3-31 hydrogen peroxide in the coolant. As descr ibed in the exception, NMP1 measures electrochemical potential. The molar ratio of hy drogen to oxygen is used by NMP2 to monitor the presence of excessive hydrogen peroxide. The staff found these exceptions acceptable.
In addition, in the ALRA the applicant stated that its Water Chemistry Control Program also takes an exception to the "monitoring and trendi ng" program element. The program described inGALL AMP XI.M2 identifies the EPRI TR-103515-R0 report as the basis for BWR water
 
chemistry programs. EPRI TR-103515-R0 recommends that chlorides and sulfates in reactor
 
water be sampled daily. NMP2 takes an exception to this recommendation by sampling for
 
these chemical species only three times per week. EPRI TR-103515-R0 also recommends that
 
ECP be monitored continuously for reactor water. NMP2 takes an exception to this
 
recommendation by not monitoring ECP. EPRI TR-103515-R0 recommends that the sampling
 
frequencies and action levels for feedwater iron and copper commence at > 10 percent power.
 
Both NMP1 and NMP2 takes exceptions to this recommendation by not commencing these sampling activities until 25 percent power.
With regard to the NMP2 exception to daily monitoring of chlorides and sulfates, the applicant stated in the ALRA that these species are part of the conductivity measurement monitored
 
continuously and any increase in conductivity above Action Level 1 requires daily sampling to determine the concentration of monitored species. The applicant further stated that this
 
sampling plan is consistent with the guidance of Revisions 0 and 2 of the EPRI report. Because
 
the program does not reduce the effectiveness of the NMP2 Water Chemistry Control Program, the staff found this exception acceptable.
With regard to NMP2 not continuously monitoring ECP the applicant stated in the ALRA that the molar ratio of hydrogen to oxygen is used as an acceptable alternative. Furthermore, the
 
applicant stated that BWRVIP-62 provides the technical correlation between these two
 
parameters and establishes an operating goal for the value of hydrogen-to-oxygen molar ratio.
 
Because the use of the BWRVIP-62 correlation does not reduce the effectiveness of the NMP2
 
Water Chemistry Control Program, the staff found this exception acceptable.
With regard to initiating sampling frequencies and action levels for feedwater iron and copper at
> 10 percent power, the applicant states, in the ALRA, that, for both NMP1 and NMP2, the
 
justification for this exception is that the filter samples collected below 25 percent power are not
 
representative and the operating time between 10 and 25 percent power is short enough to be
 
considered insignificant. Because of the limited time between 10 and 25 percent power, the staff
 
concludes that this does not reduce the effectiveness of the applicant's Water Chemistry
 
Control Program. On this basis, the staff found this acceptable.
Furthermore, in the ALRA the applicant stated that its Water Chemistry Control Program takes an exception to the "acceptance criteria" pr ogram element. The program described in GALLAMP XI.M2 identifies the EPRI TR-103515-R0 report as the basis for BWR water chemistry
 
programs. EPRI periodically updates water chem istry guidelines as new industry experience becomes available. Revisions 1 and 2 of the EPRI report incorporating industry experience are
 
the basis for the NMP1 Water Chemistry Cont rol Program whereas NMP2 uses only TR-103515 Revision 2. EPRI TR-103515-R0 recommends that an action level be established for ECP
 
during power operations. NMP1 takes an exception to the establishment of an action level but
 
establishes an administrative goal of the same value. EPRI TR-103515-R0 recommends
 
specific values for action levels 2 and 3 for reactor water chlorides and sulfates under 3-32 HWC/NMCA conditions during power operations. NMP2 takes an exception to these values by using the corresponding values recommended in Revision 2 of the EPRI report.
With regard to NMP1 establishing an action level for ECP in the ALRA, the applicant stated that it establishes a plant-specific administrative goal for ECP and the actions required by the NMP administrative procedure are consistent with the EPRI recommended actions for exceeding the
 
value. The applicant further stated that there is, therefore, no impact on program effectiveness.
 
Because NMP1 has established an administrative procedure that does not reduce the
 
effectiveness of the applicant's Water Chemistry Control Program the staff found this exception acceptable.
With regard to establishing action levels 2 and 3 for reactor water chlorides and sulfates in the ALRA, the applicant stated that the latest industry experience indicates that these higher values
 
do not reduce the effectiveness of the applicant's Water Chemistry Control Program while
 
operating at power using HWC. For maintaining program effectiveness the staff found this
 
exception acceptable.
Operating Experience. In ALRA Section B2.1.2, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Water Chemistry Control
 
Program. As chemistry control guidelines were evolving in the industry, NMP experience with reactor water system chemistry was similar to that of the industry. Review of plant-specific
 
operating experience revealed CRs documenti ng instances where monitored parameters exceeded specified action levels or goals. In t hose instances where a chemistry action level was exceeded, prompt corrective actions were taken to re-establish proper chemistry.
As documented in the Audit and Review Report dated January 18, 2006, the staff reviewed the summary of specific operating experience for t he applicant's Water Chemistry Control Program.
The staff found a significant number of CRs on water chemistry control limit monitoring, demonstrating the effectiveness of the program in minimizing propagation of aging effects and
 
aging effects mechanisms of concern for SSCs for which water chemistry is controlled.
The staff also reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's Water Chemistry Control Program adequately manages the aging effects and aging
 
effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.37 and A2.1.36, the applicant provided the respective UFSAR and USAR supplements for the Water Chemistry Control
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Water Chemistry Control Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report. In addition, the staff 3-33 reviewed the exceptions and the associated justifications, and determined that the AMP, with the exceptions, is adequate to manage the aging effects for which it is credited.The staff
 
concludes that there is reasonable assurance that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR 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  Reactor Head Closure Studs Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.3, the applicant described the Reactor Head Closure Studs Program, stating that this is an existing program that is consistent, with exception, with GALL AMP XI.M3, "Reactor Head Closure
 
Studs." The Reactor Head Closure Studs Program manages cracking of and loss of material
 
from the reactor pressure vessel closure studs. The Reactor Head Closure Studs Program
 
implements the preventive measur es of Regulatory Guide 1.65. Inservice examinations are performed in accordance with the 1989 edition of the ASME Boiler and Pressure Vessel Code with no Addenda, and ASME Section XI, Appendix VIII, "Performance Demonstration for
 
Ultrasonic Examination Systems," 1995 Edit ion through 1996 Addenda as approved by the NRC in plant-specific exemptions.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exception and the
 
associated justifications to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.
The staff reviewed portions of the Reactor Head Closure Studs Program for which the applicantclaimed consistency with GALL AMP XI.M3 and found them consistent. The staff found the
 
applicant's Reactor Head Closure Studs Program acceptable because it conforms to the recommended GALL AMP XI.M3.
In the ALRA, the applicant stated that its Reactor Head Closure Studs Program is consistent with the GALL Report with an exception to the program description. The program described in GALL AMP XI.M3 cites ASME Section XI requirements covered in the 1995 Edition through the
 
1996 Addenda. The IWB/C/D ISI Programs for NMP1 and NMP2 are based on the 1989 Edition
 
with no addenda.
The staff noted that the code of record is updated and approved by the staff for each inspection interval in accordance with 10 CFR 50.55a and that this regulation mandates the application of ASME Section XI, Appendix VIII, "Performance Demonstration for Ultrasonic Examination
 
Systems," (1995 Edition with the 1996 Addenda). On this basis, the staff found this exception
 
acceptable.
Operating Experience. In ALRA Section B2.1.3, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Reactor Head Closure
 
Studs Program. NMP reactor vessel studs have ex perienced very little degradation. A review of plant-specific operating experience revealed only a few CRs initiated as a result of inspections
 
of the studs, associated nuts, and washers. The review demonstrated that the CRs were related 3-34 to normal maintenance issues and not to age-related defects. There are no existing defects in the head studs or nuts.
The staff determined that the applicant's inspection program is adequate to detect timely indications of aging to allow for repair or replacement prior to bolting failure.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that the applicant's Reactor Head Closure Studs
 
Program will adequately manage the aging effects and aging effects mechanisms identified in
 
the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.31 and A2.1.31, the applicant provided the respective UFSAR and USAR supplements for the Reactor Head Closure Studs
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Reactor Head Closure Studs Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report. In addition, the staff
 
reviewed the exception and the associated justifications, and determined that the AMP, with the
 
exception, is adequate to manage the aging effects for which it is credited.The staff concludes
 
that there is reasonable assurance that the applicant demonstrated that the effects of aging will
 
be adequately managed so that the intended functions 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 UFSAR 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  BWR Feedwater Nozzle Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.5, the applicant described the BWR Feedwater Nozzle Program, stating that this is an existing
 
program that is consistent, with exception, with GALL AMP XI.M5, "BWR Feedwater Nozzle."
The NMP1 and NMP2 Feedwater Nozzle Programs are existing programs that require ultrasonic testing (UT) inspections of the feedwater nozzles every 10 years to verify the nozzles are
 
acceptable for continued service. The Feedwat er Nozzle Programs are implemented through the ISI Program which at the time the original LRA was submitted conformed to the requirements in ASME Code, Section XI, Subsection IWB, Table IWB 2500-1 (1989 Edition, no Addenda), and ASME Section XI, Appendix VIII, 1995 Edition through 1996 Addenda, "Performance Demonstration for Ultrasonic Examination Systems," to ASME Section XI, Division 1. UT and PT inspections discussed in NUREG-0619 have been superseded because the inspections are now performed in accordance with ASME Section XI, Appendix VIII.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are 3-35 documented in the Audit and Review Report. The staff reviewed the exception and the associated justifications to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.
The staff reviewed those portions of the BWR Feedwater Nozzle Program for which theapplicant claimed consistency with GALL AMP XI.M5 and found them consistent. The staff
 
found the applicant's BWR Feedwater Nozzle Program acceptable because it conforms to the recommended GALL AMP XI.M5 with an exception.
In the ALRA, the applicant stated that its BWR Feedwater Nozzle Program is consistent with the GALL Report with an exception to the program description. The NMP Inservice Inspection Program does not comply with the specific edition and addenda of ASME Section XI cited in the
 
GALL Report because prior to the start of each inspection interval, the program is updated to the latest edition and addenda of ASME Section XI as mandated by 10 CFR 50.55a. This exception (i.e., updating the ISI Program to the latest edition and addenda of ASME Section XI
 
as mandated by 10 CFR 50.55a) is acceptable because the NMP ISI Programs are consistent with the recommendation of GALL AMP XI.M5 in that the feedwater nozzles are subject to ASME Section XI requirements.In the ALRA, the applicant further stated that the program described in GALL AMP XI.M5 citesASME Section XI requirements covered in the 1995 Edition through the 1996 Addenda. The
 
IWB/C/D ISI Programs for NMP are based on the 1989 Edition with no addenda and ASME Section XI, Appendix VIII, 1995 Edition through 1996 Addenda. As documented in the Audit and
 
Review Report, the staff noted that the code of record is updated and approved by the NRC
 
staff for each inspection interval under 10 CFR 50.55a. On this basis the staff found this
 
exception acceptable.
Operating Experience. In ALRA Section B2.1.5, the applicant explained that no industry experience was identified that indicates that ex isting programs and practices will not be effective in the timely identification of feedwater nozzle cracking.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that the applicant's BWR Feedwater Nozzle
 
Program will adequately manage the aging effects and aging effects mechanisms identified in
 
the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.7 and A2.1.8, the applicant provided the respective UFSAR and USAR supplements for the BWR Feedwater Nozzle Program. The
 
staff reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWR Feedwater Nozzle Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report. In addition, the staff
 
reviewed the exception and the associated justifications, and determined that the AMP, with the 3-36 exception, is adequate to manage the aging effects for which it is credited.The staff concludes that there is reasonable assurance that the applicant demonstrated that the effects of aging will
 
be adequately managed so that the intended functions 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 UFSAR 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  BWR Stress Corrosion Cracking Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.6, the applicant described the BWR SCC Program, stating that this is an existing program that is consistent, with exception, with GALL AMP XI.M7, "BWR Stress Corrosion Cracking." The BWR
 
SCC Program manages intergranular stress corrosion cracking in reactor coolant pressure
 
boundary piping made of stainless steel as delineated in NUREG-0313, Revision 2, and Generic
 
Letter 88-01 and its Supplement 1, as modified by BWRVIP-75. Augmented inspections are performed in accordance with these documents. The attributes of the BWR SCC Program
 
related to maintaining reactor coolant water chemistry are included in the Water Chemistry
 
Control Program.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exception and the
 
associated justifications to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.
As documented in the Audit and Review Report, the staff noted that NMP credited Revision 1 and Revision 2 of the EPRI TR-103515 guidelines for its reactor coolant water chemistry instead
 
of the GALL Report recommended guidelines in BWRVIP-29. The applicant stated that the
 
"preventive actions" program element is address ed in its Water Chemistry Control Program. The staff reviewed the applicant's Water Chemistr y Control Program and documented its evaluation in SER Section 3.0.3.2.2. The staff found this exception acceptable.
The staff reviewed those portions of the BWR SCC Program for which the applicant claimedconsistency with GALL AMP XI.M7 and found them consistent. The staff found the applicant's BWR SCC Program acceptable because it conforms to the recommended GALL AMP XI.M7
 
with an exception.
In the ALRA, the applicant stated that its BWR SCC Program is consistent with the GALL Report with an exception to the "acceptance criteria" program element. The current NMP licensing is based on the 1989 Edition of ASME Section XI whereas the GALL Report cites the 1995 Edition with the 1996 Addenda of the ASME Section XI Code.
The staff compared the 1989 Edition to the 1995 Edition through 1996 Addenda of ASMESection XI Subsection IWB-3640. The staff found the acceptance criteria in the 1989 Edition
 
more conservative than those in the 1995 Edition through 1996 Addenda. Subsection IWB-3640
 
in the 1989 Edition sets the acceptable flaw depth upper limit as 60 percent of the wall thickness
 
whereas IWB-3640 in the 1995 Edition through 1996 Addenda sets the acceptable flaw depth
 
upper limit as 75 percent of the wall thickness for the shielded metal-arc welds and submerged
 
arc welds. On this basis the staff found the exception acceptable.
3-37 Operating Experience. In ALRA Section B2.1.6, the applicant explained it has reviewed both industry and plant-specific operating experience relating to BWR stress corrosion cracking.
 
Along with other plants in the BWR fleet, NMP1 has found indications of IGSCC in recirculation
 
system piping and welds that were evaluated and dispositioned in accordance with the
 
applicable ISI Program plan.
The staff reviewed the applicant's CAP, which shows that CRs were initiated when ISI inspections found SCC in the reactor coolant system.
The staff reviewed the applicant's CRs as described in the Audit and Review Report and found that operating experience indicates that the BWR SCC Program at NMP1 has been generally
 
effective in managing aging effects and aging effects mechanisms in BWR coolant
 
pressure-retaining boundary piping.
The staff also reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's BWR SCC Program adequately manages the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.10 and A2.1.11, the applicant provided the respective UFSAR and USAR supplements for the BWR SCC Program. The staff
 
reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWR SCC Program, the staff determined that those program elements for which the applicant claimed consistency with the
 
GALL Report are consistent with the GALL Report. In addition, the staff reviewed the exception
 
and the associated justifications, and determined that the AMP, with the exception, is adequate
 
to manage the aging effects for which it is credited.The staff concludes that there is reasonable
 
assurance that the applicant demonstrated that the effects of aging will be adequately managed
 
so that the intended functions 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 UFSAR
 
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  BWR Vessel Internals Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.8, the applicant described the BWR Vessel Internals Program, stating that this is an existing program that is consistent, with enhancements, with GALL AMP XI.M9, "BWR Vessel Internals." The
 
BWR Vessel Internals Program manages aging of materials inside the reactor vessel. Program
 
activities include: (1) inspections for the presence and effects of cracking and (2) monitoring and
 
control of water chemistry. This program is based on guidelines issued by the BWRVIP and
 
approved (or pending approval) by the NRC. The attributes of the BWR Vessel Internals
 
Program related to maintaining reactor coolant water chemistry are included in the Water 3-38 Chemistry Control Program. Inspections and eval uations of reactor vessel internal components are consistent with the guidelines provided in the following BWRVIP reports:
* BWRVIP-18, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines
* BWRVIP-25, BWR Core Plate Inspection and Flaw Evaluation Guidelines
* BWRVIP-26, BWR Top Guide Inspection and Flaw Evaluation Guidelines
* BWRVIP-27, BWR Standby Liquid Control System/Core Plate P Inspection and Flaw Evaluation Guidelines
* BWRVIP-38, BWR Shroud Support Inspection and Flaw Evaluation Guidelines
* BWRVIP-41, BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines (NMP2 only)
* BWRVIP-42, LPCI Coupling Inspection and Flaw Evaluation Guidelines (NMP2 only)
* BWRVIP-47, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines
* BWRVIP-48, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines
* BWRVIP-49, Instrument Penetration Inspection and Flaw Evaluation Guidelines
* BWRVIP-74, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines
* BWRVIP-76, BWR Core Shroud Inspection and Flaw Evaluation Guidelines Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
As documented in the Audit and Review Report, the staff noted that the applicant credited Revisions 1 and 2 of EPRI TR-103515, "BWR Water Chemistry Guidelines - 1996," for its
 
reactor coolant water chemistry instead of the GALL Report recommended guidelines in
 
BWRVIP-29. The applicant stated that the "prev entive actions" program element is addressed in its Water Chemistry Control Program. The staff reviewed the applicant's Water Chemistry
 
Control Program and documented its evaluation in SER Section 3.0.3.2.2. The staff found this
 
method acceptable.
As documented in the Audit and Review Report, the staff has stated that BWRVIP-62 has not been approved by the NRC, the staff requested that the applicant provide a program with
 
respect to BWRVIP-62. The applicant responded that BWRVIP-62 allows inspection relief for
 
plants using HWC. Furthermore, the applicant responded that NMP2 credited BWRVIP-62 in a
 
shroud evaluation during 2000-2004 but is not invoking BWRVIP-62 currently and that NMP1
 
has never taken credit for HWC in shroud reinspection evaluations. In the future the applicant
 
plans to credit the relief allowed by BWRVIP-62 when the document is approved for license
 
renewal by the staff. The staff found this response acceptable.
3-39 The staff reviewed those portions of the BWR Vessel Internals Program for which the applicantclaimed consistency with GALL AMP XI.M9 and found them consistent. The staff found the
 
applicant's BWR Vessel Internals Program acceptable because it conforms to the recommended GALL AMP XI.M9 with enhancements.
In the ALRA, the applicant stated that its BWR Vessel Internals Program is consistent withGALL AMP XI.M9 with enhancements. As stated in the ALRA, the first enhancement in meeting
 
the GALL Report for the "detection of aging effects" program element is that NMP will address
 
open items identified in the staff's SER for the BWRVIP, herein referred as BWRVIP open
 
items, regarding the inspection of inaccessible welds for core spray, jet pump, and low pressure
 
coolant injection (LPCI) components (NMP1 and NMP2 Commitment 13).
In the ALRA, the applicant also stated that BWRVIP-18, "BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines," BWRVIP-41, "BWR Jet Pump Assembly Inspection and Flaw
 
Evaluation Guidelines (NMP2 Only)," and BWRVIP-42, "LPCI Coupling Inspection and Flaw
 
Evaluation Guidelines (NMP2 Only)" identify BWRVIP open items regarding the inspection of
 
inaccessible welds for core spray, jet pump, and LPCI components respectively. The applicant
 
additionally stated that it will implement t he resolution of these BWRVIP open items as documented in the BWR Vessel Internals Program response to be reviewed and accepted by
 
the NRC. These three BWRVIP open items are applicable to NMP2. For NMP1 only the open
 
item for core spray components is applicable due to the design of the plant. The staff found that
 
this enhancement addresses the renewal application BWRVIP open items. The staff found this
 
enhancement acceptable. These changes to the applicant's program will provide assurance that
 
aging effects will be adequately managed.
In the ALRA, the applicant further stated that its BWR Vessel Internals Program is consistent with the GALL Report with the second enhancement in meeting the "detection of aging effects"
 
program element by the steam dryers in spection (NMP1 and NMP2 Commitment 13). The applicant stated that the inspection and evaluation guidelines for steam dryers are currently
 
under development by the BWR Vessel Internals Program committee. Once these guidelines
 
are documented, reviewed, and accepted by the NRC staff, actions will be implemented at
 
NMP1 and NMP2 according to the BWR Vessel Internals Program. The staff was aware that
 
BWRVIP-139, "BWR Vessel and Internals Project, Steam Dryer Inspection and Flaw Evaluation
 
Guidelines," issued by the BWR Vessel Internals Program is under staff review to address
 
steam dryer inspection activities. The staff found this enhancement consistent with the GALL
 
Report and acceptable. These changes to the applicant's program will provide assurance that
 
aging effects will be adequately managed.
In addition, in the ALRA, the applicant stated that its BWR Vessel Internals Program is consistent with the GALL Report with the third enhancement in meeting the "detection of aging
 
effects" program element, access cover holes inspection.
In the ALRA, the applicant stated that the inspection and evaluation guidelines for access hole covers are currently under development by the BWR Vessel Internals Program committee.
 
Once these guidelines are documented, reviewed, and accepted by the NRC, the actions will be
 
implemented at NMP2 according to the BWR Vessel Internals Program (NMP2
 
Commitment 13). This issue is not applicable to NMP1 due to the design of the plant. The staff
 
found that currently, inspection of access cover holes per a GE SIL and the BWR Vessel
 
Internals Program will develop guidelines for such inspections. Because the applicant's 3-40 enhancement is consistent with the GALL Report, the staff found this enhancement acceptable.
These changes to the applicant's program will provide assurance that aging effects will be
 
adequately managed.
Furthermore, in the ALRA the applicant stated that its BWR Vessel Internals Program is consistent with the GALL Report with the fourth enhancement in meeting the GALL Report
 
"detection of aging effects" program element. The baseline inspections for the BWR lower
 
plenum components will be incorporated into the appropriate program and implementation documents (NMP1 and NMP2 Commitment 13).
In the ALRA, the applicant stated that the baseline inspections recommended in BWRVIP-47 for the BWR lower plenum components will be incorporated into the appropriate program and
 
implementation documents. The staff found that this enhancement meets the recommendation of the BWRVIP-47 report. The staff found this enhancement acceptable because these changes
 
to the applicant's program provide assurance that aging effects will be adequately managed.
Regarding the fifth enhancement, in the ALRA, the applicant also stated that its BWR Vessel Internals Program is consistent with the GALL Report in meeting the "detection of aging effects"
 
program element, top guide inspection regarding BWRVIP-26 (NMP1 and NMP2
 
Commitment 13).
In the ALRA, the applicant stated that a schedule for additional inspections of the top guide locations (using enhanced VT-1 visual inspection (EVT-1) or techniques demonstrated to be
 
appropriate in BWRVIP-03, "BWR Vessel and Internals Project, Reactor Pressure Vessel and
 
Internals Examination Guidelines") will be incorporated into the appropriate program and
 
implementation documents. A minimum of 10 percent of the locations will be inspected within 12
 
years of the beginning of the period of extended operation with at least 5 percent of the
 
inspections completed within six years. As documented in the Audit and Review Report, the
 
staff noted that the inspection commitment (NMP2 Commitment 13) is within 12 years of the
 
beginning of the period of extended operation only. The staff asked the applicant to confirm that
 
the commitment also addressed subsequent intervals. The staff reviewed the latest NMP1 top
 
guide inspection findings and requested that the applicant provide additional plant-specific
 
information regarding the reinspection and scope expansion to additional locations. In its letter
 
dated December 1, 2005, the applicant provided its plant-specific information regarding the top
 
guide inspection summarized as follows:
* Prior to 2003 the NMP1 top guide fluence was estimated, using the latest best estimate transport techniques, to have exceeded the GALL Report identified 5E20 n/cm 2 threshold for irradiation-assisted stress corrosion cracking (IASCC) concerns.
* Consistent with the GALL Report guidance and a GE SIL recommendation, NMP1 implemented the recommended EVT-1 sample inspection in 2003 (Refueling Outage 17 (RFO17)) and found one crack.
* In the subsequent 2005 outage (RFO18), NMP1 expanded the inspection scope to include all accessible top guide grid beam locations using UT inspection methods. The
 
scope expansion achieved essentially 95 percent coverage of the grid beam. This scope
 
expansion and the UT inspection method are fully consistent with the current guidance in
 
BWRVIP-26, "BWR Vessel and Internals Project, Top Guide Inspection and Flaw
 
Evaluation Guidelines," and with a GE SIL specifically issued for the top guide grid 3-41 beam. This UT inspection verified the presence of the crack identified by the 2003 EVT-1 examination and identified five others.
* A CR provides the disposition of the indications identified in the 2005 inspection. The CR disposition references the NMP1 flaw handbook and justifies at least one operating cycle
 
prior to the next inspection. The CR corrective actions include a reanalysis of the
 
as-found condition and the definition of the appropriate inspection scope and frequency.
 
This plan is consistent with the guidance provided in BWRVIP-26 for top guide grid
 
beam flaw analysis (i.e., to perform a plant-specific flaw analysis to define the structural
 
margin and the appropriate inspection interval and scope) to which NMP is committed.
In its letter dated December 1, 2005, the applicant also stated that the top guide grid beam inspection sample plan addressed in the GALL Report is a sample program. At NMP1 the
 
inspection program included a sample inspection similar to the GALL Report recommendation
 
and the program has identified top guide cracking.
BWRVIP-26 does not identify any inspection plan for the top guide. The BWRVIP-47 sample inspection plan was chosen for the top guide grid beam. NMP1 implemented a scope expansion
 
inspection of the grid beam during RFO18 (2005) as a result of the inspection results from
 
RFO17 (2003). This scope expansion was performed using UT inspection methods which
 
achieved approximately 95 percent coverage of the grid beam. The volumetric coverage was
 
capable of detecting flaws through the height of both the upper and lower grid beams and at the
 
intersections. The 2005 UT inspection is the NMP1 top guide grid beam baseline inspection
 
identified in the BWRVIP-47 guidance. The staff determined that the applicant's sample
 
inspection plan was acceptable and concludes that the program identified in the ALRA
 
enhancements needed for its sample inspection plan. As documented in the Audit and Review
 
Report, the applicant stated that NMP will (1) revise its program basis document to address
 
inspection locations and re-inspection frequency, (2) revise ALRA Sections A1.1.12, A1.4, and
 
B2.1.8 to address the top guide inspection enhancement, and (3) revise ALRA
 
Sections A2.1.13, A2.4, and B2.1.8 to address the top guide inspection enhancement. In its
 
letter dated December 1, 2005, the applicant provided its ALRA revisions:
In Sections A1.1.12 and A1.4 the existing enhancement and commitment on top guide inspections for NMP1 will be revised to address re-inspection frequency as
 
follows: The reinspection scope and frequency for the grid beam going forward will be based on BWRVIP-26 guidance for plant-specific flaw analysis and crack growth
 
assessment. The maximum reinspection interval for the grid beam will not
 
exceed 10 years, consistent with standard BWRVIP guidance for the core
 
shroud. The reinspection scope will be equivalent to the UT baseline 2005
 
inspection scope. In addition, the reinspection scope will include an EVT-1
 
sample inspection of at least two locations with accessible indications within the
 
initial six years of the 10 year interval. The intent of the EVT-1 is to monitor the
 
known cracking to confirm flaw analysis crack growth assumptions.
In Sections A2.1.13 and A2.4, the existing enhancement and commitment to perform the top guide inspections for NMP2 will be revised as follows:
3-42 NMP2 will perform inspections of the guide beams similar (in inspection methods, scope and frequency of inspection) to the inspections specified in BWRVIP-47 for
 
the control rod guide tube components. The extent of examination and its
 
frequency will be based on a ten percent sample of the total population, which
 
includes all grid beam and beam-to-crevice slots, being inspected within 12 years
 
of entry into the period of extended operation with five percent of the population
 
being inspected within the first six years. The sample locations selected for
 
examination will be in areas that are exposed to the highest neutron fluence. The
 
top guide grid beam reinspection requirements will depend on the inspection
 
results; however, at a minimum, the applicant's BWRVIP will follow the same
 
guidance for the subsequent 12 year interval as defined for the initial 12 year
 
baseline.In Section B2.1.8, the existing enhancement to the "detection of aging effects" program element to perform the top guide inspections will be revised as follows:
The reinspection scope and frequency for the NMP1 grid beam going forward will be based on BWRVIP-26 guidance for plant-specific flaw analysis and crack
 
growth assessment. The maximum reinspection interval for the grid beam will not
 
exceed 10 years, consistent with standard BWRVIP guidance for the core
 
shroud. The reinspection scope will be equivalent to the UT baseline 2005
 
inspection scope. In addition, the reinspection scope will include an EVT-1
 
sample inspection of at least two locations with accessible indications within the
 
initial six years of the 10 year interval. The intent of the EVT-1 is to monitor the
 
known cracking to confirm flaw analysis crack growth assumptions.
NMP2 will perform inspections of the guide beams similar (in inspection methods, scope and frequency of inspection) to the inspections specified in BWRVIP-47 for
 
the control rod guide tube components. The extent of examination and its
 
frequency will be based on a ten percent sample of the total population, which
 
includes all grid beam and beam-to-crevice slots, being inspected within 12 years
 
of entry into the period of extended operation with five percent of the population
 
being inspected within the first six years. The sample locations selected for
 
examination will be in areas that are exposed to the highest neutron fluence. The
 
top guide grid beam reinspection requirements will depend on the inspection
 
results; however, at a minimum, the applicant's BWR Vessel Internals Program
 
will follow the same guidance for the subsequent 12 year interval as defined for
 
the initial 12 year baseline.
Because the applicant's enhancement is consistent with the GALL Report recommendations, the staff found the enhancement acceptable. These changes to the applicant's program will
 
provide assurance that aging effects will be adequately managed.
In the ALRA, the applicant also stated that its BWR Vessel Internals Program is consistent with the GALL Report with another enhancement in meeting the GALL Report "corrective actions"
 
program element by performing CRD stub tube repair (NMP1 Commitment 36).
In RAI 3.1.2-1 dated January 13, 2005, the staff requested that the applicant address the difference between the alternative repair roll/expansion techniques and the accepted ASME 3-43 Code weld repair for NMP1 CRD stub tube penetration leakage. In a letter dated February 14, 2005, the applicant responded to RAI 3.1.2-1, stating that, "NMP committed to implement a
 
strategy whereby during the period of extended operation a leaking CRD stub tube penetration
 
would be roll repaired. If following the roll repair, this stub tube was to leak within acceptable
 
limits, then a weld repair would be effected no later than one operating cycle following discovery
 
of the leakage." In the ALRA, the applicant stated that it will follow the status of the proposed
 
ASME Code change with respect to allowing roll/expansion techniques for CRD stub tubes and
 
will implement the final code change or provi de an alternative plan for the NMP1 period of extended operation at least one year prior to the expiration of the current operating license.
As documented in the Audit and Review Report, the staff noted that the wording in ALRA Table 3.1.1.A and in the applicant's response to RAI 3.1.2-1 imply that NMP1 will operate with
 
CRD stub tube leakage for one operating cycle (two years). The staff did not consider this
 
implication acceptable for the period of extended operation. The staff's safety evaluation dated
 
March 25, 1987, allowing NMP1 to operate with CRD stub tube leakage was acceptable only as
 
a temporary repair. Specifically, Item (6) of the staff's safety evaluation conclusions stated that, "The proposed leakage criteria provide sufficient time to complete the final development of the
 
prototype mechanical seal and associated tooling and to investigate other methods like weld
 
repair." In a-RAI 3.1.2-1 dated November 2, 2005, the staff requested that the applicant address CRD stub tube leaking for an additional operating cycle.
In its response by letter dated November 30, 2005, the applicant revised ALRA Section 2.1.8 Commitment 36 in ALRA Section A1.4 and ALRA Table 3.1.1.A Item 3.1.1.A-30 to clarify its
 
position related to the use of roll/expansion techniques for the repair of leaking NMP1 CRD stub
 
tubes as follows:
The 2 nd paragraph of ALRA Table 3.1.1.A, LA Item 3.1.1.A-30 (Page 3.1-29), Commitment 36 of ALRA Section A1.4 (Page A1-42), and the Corrective Action
 
bullet in ALRA Section B2.1.8 (Page B2-25) is replaced with:
If the 10/19/05 draft of Code Case N-730 is approved by the ASME, NMP Unit 1 will implement the final code case as
 
conditioned by the NRC. If the code case is not approved by the
 
ASME, NMP1 will seek NRC approval of the 10/19/05 code case
 
draft on a plant specific basis as conditioned by the NRC.
During the period of extended operation, should a CRD stub tube rolled in accordance with the provisions of the code case resume leaking, NMP will
 
implement one of the following zero leakage permanent repair strategies prior to
 
startup from the outage in which the leakage was detected:  (1)A welded repair consistent with BWRVIP-58-A, "BWRVIP Internal access Weld Repair" and Code Case N-606-1, as endorsed by the NRC in
 
Regulatory Guide 1.147.  (2)A variation of the welded repair geometry specified in BWRVIP-58-A subject to the approval of the NRC using Code Case N-606-1.
3-44  (3)A future developed mechanical/welded repair method subject to the approval of the NRC.
The staff found the applicant's response acceptable because it is consistent with the GALL Report recommendation. The staff found this enhancement acceptable. These changes to the
 
applicant's program will provide assurance that aging effects will be adequately managed.
 
Therefore, the staff's concern described in RAI 3.1.2-1 is resolved.
In its letter dated November 17, 2005, the applicant revised its original enhancement in meeting the GALL Report for the "detection of aging effects" program element as follows: add
 
management of fracture toughness of NMP1 and NMP2 Cast Austenitic Stainless Steel (CASS)
 
components (NMP1 Commitment 37 and NNP2 Commitment 35).
In the ALRA, the applicant stated that maintenance procedures for the inspection of the orificed fuel support casting will be enhanced to include a sample VT-1 inspection of the casting and an
 
EVT-1 inspection if any evidence of impact or mishandling is identified. In a letter dated
 
November 17, 2005, the applicant provided its self-identified changes and its basis for change
 
to the ALRA for the management of the fracture toughness of NMP1 and NMP2 CASS
 
components with the BWR Vessel Internals Program as follows:
In Sections A1.1.12, A2.1.13 and B2.1.8, clarify that the program activities include effects on fracture toughness due to neutron fluence and thermal embrittlement by
: 1) replacing the last bullet on Page A1-6 of Section A1.1.12; 2) replacing the last bullet
 
on Page A2.6 of Section A2.1.13; and 3) replacing the text under the "parameters
 
monitored/inspected" program element in NMP AMP B2.1.8 with the following:
Enhance the program to evaluate component susceptibility to loss of fracture toughness. Assessments and inspections will be
 
performed, as necessary to ensure that intended functions are not
 
impacted by the aging effect.
In Sections A1.4 and A2.4, replace the commitments in Item 37 of Section A1.4 and Item 35 in Section A2.4 as follows:
Enhance the program to evaluate component susceptibility to loss of fracture toughness. Assessments and inspections will be
 
performed, as necessary to ensure that intended functions are not
 
impacted by the aging effect.
The staff reviewed the applicant's self-identified ALRA change. The staff found this acceptable since its change meets the GALL Report's recommendation. On this basis, the staff found this
 
enhancement acceptable. These changes to the applicant's program will provide assurance that
 
aging effects will be adequately managed.
In its letter dated December 1, 2005, the applicant provided an additional enhancement to the GALL Report "detection of aging effects" program element: Inspect additional locations to
 
address the aging management for reactor vessel feedwater nozzle thermal sleeves (NMP1
 
Commitment 38 and NMP2 Commitment 37) and control rod drive return line nozzle thermal
 
sleeves (NMP1 Commitment 40). An EVT-1 ex amination of the NMP1 and NMP2 feedwater 3-45 sparger end bracket welds will be performed. The inspection extent and frequency of the endbracket weld inspection will be the same as the ASME Section XI inspection of the feedwater
 
sparger bracket vessel attachment welds. If the final fabrication review of the NMP2 feedwater
 
thermal sleeves concludes that the hidden welds are not IGSCC susceptible the NMP2
 
inspections will be discontinued as appropriate (NMP1 Commitment 38 and NMP2 Commitment
 
37). NMP1 will perform an EVT-1 inspection of the thermal shield to flow shield weld starting
 
2007 and proceed at a 10 year-frequency thereafter consistent with the ISI inspection interval (NMP1 Commitment 40).
In a letter dated September 15, 2005, the applicant stated that its BWR Feedwater Nozzle Program and BWR CRDRL Nozzle Program had been removed as credits for the feedwater
 
nozzle and CRDRL nozzle thermal sleeves. As documented in the Audit and Review Report, the
 
staff asked the applicant to address aging management for the thermal sleeves. In a letter dated
 
December 1, 2005, the applicant stated that it will use inspections performed under its BWR
 
Vessel Internals Program using surrogate component s more readily accessible for examination.
For NMP1 the surrogate components will be the feedwater sparger end bracket welds. In this
 
letter the applicant also provided its basis for choosing the feedwater sparger end bracket
 
welds: The NMP1 feedwater nozzle thermal sleeves are fabricated from nickel-based Alloy 600 (Inconel 600). A full penetration weld joins the thermal sleeve to the
 
outboard end of the carbon steel feedwater sparger. This weld was made with
 
Alloy 82 and Alloy 182 weld fillers. The thermal-sleeve to sparger weld, or the
 
heat affected zone in the Alloy 600 base material, is considered the most likely
 
location for IGSCC in the thermal sleeve.
The applicant added that each feedwater sparger is supported by end brackets providing a spring force that helps hold the thermal sleeve in place. The feedwater sparger end bracket
 
welds consist of three welds, sparger arm to sparger end plate welds (Weld #1), sparger end
 
plate to bracket end plate weld (Weld #2), and sparger bracket end plate to end bracket
 
assembly welds (Weld #3), which are dissimilar metal welds that use Alloy 182 or 82 weld fillers.
In addition the applicant stated that SCC of the feedwater thermal sleeves or the associated welds is possible but considered less likely than for other welds with the same weld filler
 
associated with the feedwater sparger because the inconel to carbon steel welds are
 
heat-treated shop welds and are not creviced. Se rvice experience has demonstrated that Alloy 82 is resistant to IGSCC in BWR coolant. Alloy 182 is less resistant to IGSCC than Alloy 82 but
 
performs acceptably with such aggravating factors as lack of fusion or a creviced condition.
 
These conditions are more likely in field welds. The Alloy 600-to-carbon steel welds in the
 
thermal sleeve are full penetration and do not create a creviced condition. Additionally, the
 
thermal sleeve assembly was heat-treated after welding. The #1 end bracket welds use Alloy
 
182 filler metal in a mildly creviced condition, making them more susceptible to IGSCC than the
 
thermal sleeve-to-sparger welds. Additionally, the #1 welds are exposed to reactor coolant
 
chemistry on the outer diameter, which has a higher ECP, and thus are more likely to cause
 
IGSCC than feedwater, which has a much lower ECP. Therefore, the applicant stated, if
 
cracking is not found in the #1 welds inspection of the thermal sleeve-to-sparger welds is not
 
necessary.
3-46 Furthermore, the applicant stated that the most susceptible of the three feedwater sparger end bracket welds (Weld #2) is subject to EVT-1 under a BWRVIP. If cracking is found in these
 
welds the other end bracket welds (#1 and #3) will be inspected. If cracking is found in the less
 
susceptible end bracket welds the necessity to inspect the thermal sleeve-to-sparger welds will
 
be evaluated. The applicant's BWR Vessel Internals Program will, therefore, be credited with
 
managing cracking bounded of the thermal sleeve as the susceptibility of the critical thermal
 
sleeve weld to IGSCC is covered by other welds inspected under the applicant's BWR Vessel
 
Internals Program. In its letter dated December 1, 2005, the applicant stated that it will revise
 
the ALRA to add an EVT-1 examination of the NMP1 feedwater sparger brackets as a BWR
 
Vessel Internals Program enhancement to address this issue. The staff found the applicant's
 
response acceptable because it demonstrated that inspection of surrogate components includes
 
the NMP1 feedwater nozzle thermal sleeves.
In its letter dated December 1, 2005, the applicant stated that NMP2 also will use inspections performed under the BWR Vessel Internals Program using surrogate components that are more
 
readily accessible for examination. For NM P2 the surrogate components will be the feedwater sparger end bracket welds. In this letter the applicant also provided its basis for choosing the
 
feedwater sparger end bracket welds:
...a similar evaluation of the NMP2 feedwater sparger welds and the selection of surrogate welds that are accessible for inspection would also be acceptable for
 
NMP2. These accessible welds would be used as a leading indicator for potential
 
IGSCC cracking of the thermal sleeve. If cracking is found in these welds, a
 
supplemental evaluation of the thermal sleeve integrity would be required.
The applicant also stated that the review of the NMP2 feedwater thermal sleeve and sparger had been completed and had confirmed that the thermal sleeve material is 316L with several
 
hidden stainless steel welds. The incomplete fabrication method review will determine the
 
welding procedures and whether the welds were stress-relieved. If the hidden welds were
 
stress-relieved they would not be considered susceptible to IGSCC and the cracking aging
 
mechanism would not be considered applicable to NMP2.
In addition the applicant stated that the review of the NMP2 feedwater sparger installation details found that the field installation applied a 20,000 lbs load creating a 0.125" cold spring to
 
the sparger. The sparger end brackets were pinned, locking in the cold spring, and then final
 
field-welded with a fillet weld. The applicant further stated that this installation detail is similar to
 
that of NMP1. The result of the cold spring is a fit-up net tensile stress superimposed on the
 
weld residual stress. The combination of the fit-up stress (cold spring) and the residual stress of
 
the field weld conditions and the fillet weld crevice geometry creates a susceptibility to IGSCC
 
higher than that of the thermal sleeve welds. The corrosion potential of the reactor water in the
 
region of the feedwater sparger end bracket welds is equivalent to if not greater than that of the
 
reactor water in contact with the outside diameter weld of the thermal sleeve. The applicant also
 
stated that an EVT-1 examination of the NMP1 and NMP2 feedwater sparger end bracket welds
 
will be added to its BWR Vessel Internals Program as a program enhancement. The inspection
 
extent and frequency of the end bracket weld inspection will be the same as the ASME Section XI inspection of the feedwater sparger bracket vessel attachment welds. If the final
 
fabrication review of the NMP2 feedwater thermal sleeve finds that the hidden welds are not
 
IGSCC susceptible the NMP2 inspections will be discontinued.
3-47 Furthermore, the applicant stated that examination of the NMP2 feedwater sparger end bracket welds is a representative inspection of the material condition of the hidden thermal sleeve welds
 
regarding potential IGSCC cracking. Therefore, consistent with the discussion between the staff
 
and the applicant documented in the Audit and Review Report, cracking of the NMP2 feedwater
 
nozzle thermal sleeves will be a matter for the applicant's BWR Feedwater Nozzle Program, BWR Vessel Internals Program, and Water Chemistry Control Program. In its letter dated
 
December 1, 2005, the applicant stated that an EVT-1 examination of the NMP1 and NMP2
 
feedwater sparger end bracket welds will be added to its BWR Vessel Internals Program as a
 
program enhancement (NMP1 Commitment 38 and NMP2 Commitment 37). The inspection
 
extent and frequency of the end bracket weld inspection will be the same as for the ASME Section XI inspection of the feedwater sparger bracket vessel attachment welds. If the final
 
fabrication review of the NMP2 feedwater thermal sleeve finds that the hidden welds are not
 
IGSCC susceptible the NMP2 inspections will be discontinued. The staff reviewed the
 
applicant's response and found it acceptable since the applicant's surrogate weld inspection
 
provides adequate aging management for the NMP2 feedwater thermal sleeve. The staff found that the applicant appropriately addressed the aging effect and aging effect mechanism for
 
NMP2 feedwater nozzle thermal sleeves.
In its letter dated December 1, 2005, the applicant also narrated operating experience in addressing the CRDRL nozzle thermal sleeves:
The inspections of the CRDRL nozzle and safe-ends in 1978 identified IGSCC cracking of the safe-end material, but did not identify fatigue-related cracking.
 
The CRDRL safe-end and the thermal sleeve were replaced in 1978 with design
 
changes to improve resistance to both IGSCC and fatigue. The replacement
 
thermal sleeve material is IGSCC resistant low carbon Type 316L stainless steel
 
material. The thermal sleeve is welded to the safe-end with low carbon Type
 
308L weld filler. To reduce the probability of fatigue, the thermal sleeve pipe
 
protrudes 7 inches out from the flow shie ld which promotes mixing away from the vessel wall thus preventing thermal cycling at the vessel wall and at the flow
 
shield.The applicant stated that as a result of industry operating experience from 2002 and 2003, NMP completed detailed thermal fatigue assessments and expanded inspections of the safe-end, the
 
thermal sleeve attachment weld to the safe-end, and the thermal sleeve weld to the flow shield.
 
These inspections were performed in 2004 and 2005. The inspections to date have identified no
 
IGSCC or thermal fatigue-related cracking. Because the 2003 operating experience identified
 
cracking of the thermal shield flow baffle additional EVT-1s of the thermal shield to flow shield
 
weld from the vessel ID are planned for 2007 and at a 10-year frequency thereafter consistent
 
with the ISI inspection interval. This EVT-1 examination of the CRDRL thermal sleeve flow
 
shield weld visible from the vessel ID during each ISI interval is consistent with the frequency
 
that has been adopted for the feedwater nozzle surrogate weld location on the feedwater end
 
brackets.In addition the applicant stated that a one-time UT of the CRDRL safe-end base metal in 2004 was performed under the NMP augmented ISI progr am 26 years of operation after the 1978 replacement (three outages prior to the license renewal term). This inspection identified no
 
IGSCC or thermal fatigue cracking of the safe-end location. The inspection was a manual
 
performance demonstration initiative (PDI) qualified inspection and the PDI mockup included the 3-48 thermal sleeve attachment weld to the safe-end. The inspection records note the presence of the thermal sleeve attachment weld. This inspection is considered sufficient to detect significant
 
circumferential IGSCC cracking of the thermal sleeve at the thermal sleeve attachment weld; however, consistent with the surrogate weld inspection methodology employed for the
 
feedwater nozzle thermal sleeve, the EVT-1 inspection of the thermal sleeve flow shield weld
 
also will be used as a surrogate weld inspection location for the thermal sleeve to safe-end
 
attachment weld.
In addition to the inspections the applicant stated that temperature monitoring for thermal cycling was performed to confirm that the CRD return flow rates were sufficient at NMP1 to
 
ensure that no unstable thermal cycling caused by hot reactor water return flow occurs. The
 
testing and analyses have found the minimum CRD return flow required to ensure stable return
 
line conditions and that no reverse flow.
The applicant's overall assessment is that the safe-end and thermal sleeve replacement with IGSCC-resistant materials and the one-time UT of the thermal sleeve attachment weld after 26
 
years establish that the thermal sleeve attachment weld is not a high risk IGSCC location. In
 
addition the thermal monitoring of this location and the inspection after 26 years of operation
 
also found no high-cycle thermal fatigue conditions at this location that could create high
 
thermal cycle fatigue-related cracking.
Furthermore, the applicant continued, the analyses and one-time inspections performed in 2004 to 2005 are adequate to detect potential cracking of the CRDRL nozzle thermal sleeve to
 
safe-end attachment weld from either IGSCC or fatigue. Even though IGSCC is considered a
 
low probability for this location for materials of construction the BWR Vessel Internals Program
 
will include an enhancement starting in 2007. An EVT-1 inspection of the thermal shield to flow
 
shield weld from the vessel ID will be performed at that time and thereafter at a 10-year
 
frequency consistent with the ISI inspection interval.
The applicant also stated that in addition to determining the condition of the flow shield weld this EVT-1 inspection will be used as a surrogate weld inspection location for the thermal sleeve to
 
the safe-end attachment weld. In its letter dated December 1, 2005, the applicant provided its
 
ALRA revisions:
* Revise ALRA Sections A1.1.12, A1.4, and B2.1.8 to incorporate the commitment to perform the EVT-1 inspection of the thermal shield to flow shield weld starting in 2007
 
and proceeding at a 10 year frequency consistent with the ISI inspection interval
 
thereafter.
* Revise ALRA Table 3.1.1.A-1, Item 3.1.1.A-27 and ALRA Table 3.1.2.A-1 to reflect the changes.The staff reviewed the applicant's response and found it acceptable because the applicant's surrogate weld inspection in addition to the results of its one-time inspections 2004 to 2005
 
provide adequate aging management for the CRDRL thermal sleeve. The staff concludes that
 
the applicant appropriately addressed the aging effect and aging effect mechanism for NMP1
 
CRDRL nozzle thermal sleeves.
3-49 Operating Experience. In ALRA Section B2.1.8, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the BWR Vessel Internals
 
Program. Review of plant-specific operating experience revealed conditions discovered by
 
BWRVIP examinations similar to those identified elsewhere in the BWR fleet. In each case, indications were evaluated and either found acceptable for further service or appropriately
 
repaired. The BWRVIP is continually adjusted to account for industry experience and research (including activities of the BWRVIP and ASME Section XI Code Committees). In 2001, the
 
Institute of Nucear Power Operations (INPO) conducted a review of activities related to BWR
 
Vessel Internals Program at NMP2. Several strengths were identified, and recommendations for
 
improvement were addressed by pr ogram upgrades at NMP1 and NMP2.
The staff reviewed the operating experience provided in the ALRA and the applicant's operating issues related to SCC and determined that the current program has proven to be effective in
 
managing the aging of the vessel internals within the scope of license renewal. The following is
 
a sample list of NMP1 operating experience issues including core shroud cracking, shroud
 
support weld cracking, CRD stub tube IGSCC and leakage, and top guide cracking:
* NMP1 identified CRD stub tube leakage in 1984. The root cause investigation and inspection confirmed IGSCC of the furnace-sensitized 304 CRD stub tubes. The
 
applicant implemented a roll repair of the leakage and a structural evaluation of the
 
tolerability of the cracking. NMP1 is also working through its BWR Vessel Internals Program to obtain approval of an ASME Section XI code case for the roll repair
 
technique for this location.
* NMP1 identified core shroud horizontal weld cracking following the BWRVIP-01, "BWR Vessel and Internals Project, BWR Core Shroud Inspection and Flaw Evaluation
 
Guideline (Revision 2)," baseline inspection in 1995. The corrective action taken was to
 
install a pre-emptive core shroud tie-rod repair which followed the BWRVIP-02, "BWR
 
Vessel and Internals Project, BWR Core Shroud Repair Design Criteria," shroud repair
 
guidelines. This repair was designed for a 20-year license renewal term.
* NMP1 identified core shroud vertical weld cracking in 1997 following a baseline inspection required by BWRVIP-02 guidelines. This inspection safeguarded operations
 
for at least two years until the next inspection. A pre-emptive repair was installed in 1999
 
for the core shroud vertical welds. This repair was designed for a 20-year license
 
renewal term.
* NMP1 detected indications in the core shroud support H9 vessel attachment weld during baseline BWRVIP-38, "BWR Shroud Support Inspection and Flaw Evaluation
 
Guidelines," inspections in 2001. This attachment weld is an Alloy 182 nickel-based alloy
 
with operational experience from an overseas BWR of IGSCC. The analysis was
 
consistent with BWRVIP-38 methods and the detected indications were deemed
 
acceptable over a 10-year re-inspection frequency. Supplemental sampling inspections
 
have shown the indications are confined to the weld with no propagation into the vessel
 
low-alloy steel. The indications were similar to those discussed in a GE SIL. Other core
 
shroud indications were found in weld H8, weld H3, and weld H6A.
* NMP1 completed a sample baseline inspection of the top guide grid beam identified in BWRVIP-26, "BWR Top Guide Inspection and Flaw Evaluation Guidelines," as having
 
the potential for IASCC and as such representing a condition that warranted review for
 
license renewal. The inspection of the top guide based on the recommendations of a GE 3-50 SIL detected one indication consistent with grid beam cracking at Oyster Creek. The indication was evaluated consistently with BWRVIP-26 methods and found to be
 
tolerable for continued service. Ongoing inspection and monitoring consistent with
 
BWRVIP-26 requirements are proper long-term based on the current top guide fluence
 
predictions and extent of cracking.
Operating experience problems that have been ident ified at NMP2 include core shroud cracking and jet pump wedge wear. The applicant's BWR Vessel Internals Program has not identified
 
other cracking of internals covered by its BWR Vessel Internals Program. The BWR Vessel
 
Internals Program recommended actions to inspect the core shroud and internals welds for
 
cracks illustrate the effectiveness of the BWR Vessel Internals Program inspections. For
 
example:
* NMP2 detected core shroud horizontal weld cracking during the BWRVIP-01 required baseline inspection in 1998. The inspection found that the core shroud welds H4, H5, and H7 had greater than 30 percent cracking warranting plant-specific evaluation. The
 
condition was evaluated consistently with BWRVIP-01 methods and judged to be fit for
 
conditioned service without repair. The limiting inspection interval is four years for each
 
re-inspection. The condition currently is managed through IGSCC mitigation and
 
re-inspection. Core shroud repair according to BWRVIP-02 is considered a contingency
 
dependent on observed IGSCC growth.
* The BWRVIP-41 required baseline inspections are approximately 75 percent complete with no cracking detected. The baseline inspections that detected wedge bearing
 
surface wear contact and set screw gaps were recommended by the BWR Vessel
 
Internals Program based on industry operating experience. The inspections detected jet
 
pump wedge wear in the sample population. The required BWRVIP-41 scope expansion
 
was completed and the results showed the wear isolated to one location. The scope
 
expansion identified set screw gaps one of which warranted a preemptive auxiliary
 
wedge installation to eliminate it. The program has identified corrective measures
 
needed to prevent flow- induced vibration if NMP2 operates above rated core flow.
* NMP2 detected several cracks in the steam dryer upper support ring side of drain channel 1, 2, and 3 horizontal 304 stainless steel welds ranging in length from 0.1 to
 
===0.7 inches===
during inspections in RFO6. A GE evaluation concludes the indications
 
observed are typical of IGSCC. Factors contributing to the initiation of IGSCC (weld
 
residual stresses, weld sensitized 304 stainless steel in the heat affected zone (HAZ),
and surface cold work due to fabrication) are all present in the steam dryer upper
 
support ring. The cracking discovered at the NMP2 steam dryer upper support ring is
 
similar to but less severe than that seen on several similar steam dryers at other plants.
 
The ISI program plan was revised to re-inspect the locations of the cracks to detect any
 
significant increase in length or number.
* NMP2 detected several cracks on the stiffener to upper guide ring welds at various locations between the shroud head bolts during inspections performed in 1998. A GE
 
evaluation concluded that the indications detected are characteristic of IGSCC known to
 
occur in weld-sensitized type 304 stainless steel. NMP2 determined that no repair was
 
required during the current outage; however, the ISI program plan was revised to
 
re-inspect the locations of the indications to detect any significant increase in length or
 
number.
3-51 The staff found that the applicant's BWR Vessel Internals Program recommended actions to inspect the core shroud and internal welds for cracks indicate the effectiveness of its BWR
 
Vessel Internals Program inspections. The staff also found that changes and updates to the
 
applicant's BWR Vessel Internals Program have resulted from the ongoing review of industry
 
operating experience and regulatory notices as these are reviewed regularly for applicability to
 
the reactor vessel internals. In these ways the applicant addressed vessel internals degradation
 
noted at other BWRs systematically and revised its BWR Vessel Internals Program inspections
 
accordingly.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's BWR Vessel Internals Program will adequately manage the aging effects identified
 
in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. The applicant provided its UFSAR and USAR supplements for the BWR Vessel Internals Program in ALRA Section A1.1.12 for NMP1 and Section A2.1.13 for
 
NMP2 stating that its BWR Vessel Internals Program manages aging of materials inside the
 
reactor vessel. Program activities include (1) inspections for the presence and effects of
 
cracking and (2) monitoring and control of water chemistry. This program is also used to
 
manage loss of material for carbon steel vessel instrumentation penetrations for NMP2. This
 
program is based on guidelines issued by the BWRVIP and approved (or pending approval) by
 
the staff. Inspections and evaluations of reactor vessel components are consistent with the
 
guidelines provided in the applicable BWRVIP reports.
The applicant has completed or will complete each of the license renewal BWRVIP action items described in the staff safety evaluations for these BWRVIP reports. In addition the applicant will
 
implement the NRC-approved inspection and flaw ev aluation guidelines for the steam dryer and inaccessible core spray components weld at NMP1, and for the steam dryer, access hole cover, inaccessible core spray, jet pumps, and LPCI components welds at NMP2.
The applicant also provided its UFSAR supplement for NMP1 enhancements to its BWRVIP including the following revisions to existing activities credited for license renewal.
* The reinspection scope and frequency for the grid beam will be based on BWRVIP-26 guidance for plant-specific flaw analysis and crack growth assessment. The maximum
 
reinspection interval for the grid beam will not exceed 10 years consistent with standard BWRVIP guidance for the core shroud. The reinspection scope will be equivalent to the
 
UT baseline 2005 inspection scope. In addition the reinspection scope will include an
 
EVT-1 sample inspection of at least two locations with accessible indications within the
 
initial six years of the 10-year interval. The intent of the EVT-1 is to monitor the known
 
cracking to test flaw analysis crack growth assumptions.
* As stated in the ALRA, the applicant will implement the resolution of the BWRVIP-18 open items regarding the inspection of inaccessible welds for core spray. It will be
 
included in its BWRVIP response to be reviewed and accepted by the staff.
* Once the guidelines for inspection and evaluation for steam dryers currently under development by the BWRVIP committee are documented, reviewed and accepted by the staff, the actions will be implemented in accordance with the BWRVIP.
3-52
* The baseline inspections recommended in BWRVIP-47 for the BWR lower plenum components will be incorporated into the program.
If the October 19, 2005 draft of Code Case N-730 is approved by the ASME, NMP1 will implement the final code case as conditioned by the staff. If the code case is not approved by
 
the ASME, NMP1 will seek staff approval of the 10/19/05 code case draft on a plant specific
 
basis from the staff.
If during the period of extended operation, a CRD stub tube, rolled in accordance with the provisions of the code case, resumes leaking, NMP will implement one of the following zero
 
leakage permanent repair strategies prior to startup from the outage in which the leakage was
 
detected:  (1)A welded repair consistent with BWRVIP-58-A, "BWRVIP Internal access Weld Repair" and Code Case N-606-1, as endorsed by the NRC in Regulatory Guide 1.147.  (2)A variation of the welded repair geometry specified in BWRVIP-58-A subject to the approval of the NRC using Code Case N-606-1.  (3)A future developed mechanical/welded repair method subject to the approval of the staff.
* Enhance the program to evaluate component susceptibility to loss of fracture toughness. Assessments and Inspections will be performed, as necessary to
 
ensure that intended functions are not impacted by the aging effect. (Note: This
 
enhancement was revised through its letter dated December 1, 2005).
* An EVT-1 examination of the NMP1 feedwater sparger end bracket welds will be performed. The inspection extent and frequency of the end bracket weld inspection will be the same as the ASME Section XI inspection of the feedwater
 
sparger bracket vessel attachment welds. (Note: This enhancement was revised
 
through its letter dated December 1, 2005).
* NMP1 will perform an EVT-1 inspection of the thermal shield to flow shield weld starting 2007 and proceeding at a 10 year frequency thereafter consistent with
 
the ISI inspection interval. (Note: This enhancement was revised through its letter
 
dated December 1, 2005).
The applicant also provided its USAR suppl ement for NMP2 enhancements to its BWRVIP including the following revisions to existing activities credited for license renewal:
* NMP2 will perform inspections of the guide beams similar in methods, scope, and frequency to the inspections specified in BWRVIP-47 for the control rod guide tube
 
components. The extent of examination and its frequency will be based on inspection of
 
a 10 percent sample of the total population, which includes all grid beam and
 
beam-to-crevice slots, within 12 years of ent ry into the period of extended operation with 5 percent of the population inspected within the first six years. The sample locations
 
selected for inspection will be in areas exposed to the highest neutron fluence. The top
 
guide grid beam reinspection requirements will depend on the inspection results;
 
however, at a minimum the applicant's BWRVIP will follow the same guidance for the
 
subsequent 12-year interval as defined for the initial 12-year baseline. (Note: This 3-53 enhancement was revised through letters dated December 1, 2005, and December 13, 2005).
* The applicant will implement the resolution of the open items documented in BWRVIP-18, BWRVIP-41, and BWRVIP-42 regarding the inspection of inaccessible
 
welds for core spray, jet pump, and LPCI components, respectively. It will be included in
 
its BWRVIP response to be reviewed and accepted by the staff. (Note: This
 
enhancement was provided in the ALRA).
* Once the guidelines for inspection and evaluation for steam dryers currently under development by the BWRVIP committee are documented, reviewed, and accepted by
 
the staff they will be implemented accord ing to the BWRVIP. (Note: This enhancement was provided in the ALRA).
* Once the inspection and evaluation guidelines for access hole covers guidelines are documented, reviewed, and accepted by the st aff they will be implemented according to the BWRVIP. (Note: This enhancement was provided in the ALRA).
* The baseline inspections recommended in BWRVIP-47 for the BWR lower plenum components will be incorporated into the program. (Note: This enhancement was
 
provided in the ALRA).
* The applicant will enhance the program to evaluate component susceptibility to loss of fracture toughness. Assessments and inspections will be performed as necessary to
 
ensure that intended functions are not impacted by the aging effect. (Note: This
 
enhancement was revised through a letter).
* An EVT-1 examination of the NMP2 feedwater sparger end bracket welds will be performed. The extent and frequency of the end bracket weld inspection will be the same as the ASME Section XI inspection of the feedwater sparger bracket vessel
 
attachment welds. If the final fabrication review of the NMP2 feedwater thermal sleeves
 
finds that the hidden welds are not IGSCC- susceptible NMP2 inspections will be
 
discontinued. (Note: This enhancement was revised through its letter dated December 1, 2005). The staff reviewed the information in the supplements and found that they provide adequate summary descriptions of the program required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWRVIP, the staff determined that those program elements for which the applicant claimed consistency with the GALL Report
 
are consistent with the GALL Report. Also, the staff has reviewed the enhancements and
 
confirmed that the implementation of t he enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report AMP to which
 
it was compared.The staff concludes that there is reasonable assurance that the applicant
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions 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 UFSAR supplement for this AMP
 
and concludes that it provides an adequate summary description of the program, as required by
 
10 CFR 54.21(d).
3-54 3.0.3.2.7  Open-Cycle Cooling Water System Program Summary of Technical Information in the Amended Application. In ALRA Section B2.1.10, the applicant described the Open-Cycle Cooling Water System (OCCWS) Program, stating that thisis an existing program that is consistent, with enhancements, with GALL AMP XI.M20, "Open-Cycle Cooling Water System." The OCCWS Program manages aging of components exposed to raw, untreated (e.g., service) water. For NMP1 this includes portions of the service
 
water system, the emergency service water sy stem, shell side of the RBCLC heat exchangers, the EDG cooling water system, containment spray raw water system, and portions of the
 
circulating water system. Also included are other components WSLR wetted by the service water system that are credited in the AMR. The NMP2 OCCWS scope includes a portion of the
 
alternate decay heat system with associated por tions of the service water system, the RHR heat exchangers, diesel generator jacket water coolers, and control room chillers. Also included are
 
components within the scope of license renewal t hat are wetted by the service water system and credited in the AMR. Program activities include: (1) surveillance and control of biofouling (including biocide injection); (2) verification of heat transfer capabilities for components cooled
 
by the service water system; (3) inspection and maintenance; (4) walkdown inspections; and (5)
 
review of maintenance, operating and training practices and procedures. Inspections may
 
include visual, UT, and ECT methods. The OCCWS Program is based on the recommendations
 
of GL 89-13.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
The staff reviewed those portions of the OCCWS Program for which the applicant claimedconsistency with GALL AMP XI.M20 and found them consistent. The staff found the applicant's OCCWS Program acceptable because it conforms to the recommended GALL AMP XI.M20 with
 
enhancements.
In the ALRA, the applicant stated that its OCCWS Program is consistent with GALLAMP XI.M20 with enhancements and that the enhancements in meeting the GALL Report program description, "scope of program," "p reventive actions," and "monitoring and trending" program elements revises procedures to address the following:
* Ensure that the applicable NMP1 commitments made for GL 89-13 and therecommendations in GALL AMP XI.M20 are stated in the NMP1 implementation
 
documents for GL 89-13. (NMP1Commitment 14).
* Ensure that the applicable NMP2 commitments made for GL 89-13 and therecommendations in GALL AMP XI.M20 are stated in N2-TDP-REL-0104, "GL 89-13, Service Water System Problems Affecting Safety Related Equipment Program Plan,"(NMP2 Commitment 14).
* Incorporate into the OCCWS Program GALL AMP XI.M20 recommendations when they are more conservative than the GL 89-13 commitments (NMP1 and NMP2
 
Commitment 14).
3-55 As documented in the audit and review report, the applicant stated that it is developing an implementing program for both units to integrate the commitments made according to GL 89-13 and the recommendations made in the GALL Report for GALL AMP XI.M20. When the GALL
 
Report recommendations are more conservative than the GL 89-13 commitments, the GALL
 
Report recommendations will be integrated. This enhancement will make the applicant's AMP
 
consistent with the GALL Report and is, therefore, acceptable. These changes to the applicant's
 
program will provide assurance that aging effects will be adequately managed.
Also in its letter dated November 17, 2005, the applicant revised the ALRA to expand the discussion of the program to clarify that it includes internal portions of nonsafety-related
 
segments of the circulating water and service water systems within the scope of license renewal
 
under 10 CFR 54.4(a)(2) to maintain their pressure integrity. This letter also stated that this
 
program manages all aging effects for components subject to the recommendations for GL
 
89-13. The staff found this enhancement acceptable because it clarifies the overall program
 
scope.In addition in the ALRA the applicant stated that its OCCWS Program is consistent with the GALL Report with another enhancement and that the enhancement in meeting the GALL Report
 
"aceptance criteria" program element revises procedures to address the following:
* Revise the NMP1 and NMP2 preventive maintenance and heat transfer performance test procedures to incorporate specific inspection criteria, corrective actions, and
 
frequencies. (NMP1 and NMP2 Commitment 14).
As documented in the Audit and Review Report, the applicant stated that the heat exchanger preventive maintenance procedures will be revised to incorporate inspection criteria to ensure
 
thorough cleaning of all affected OCCW components and to initiate appropriate corrective
 
actions prior to the loss of intended function if progressive degradation persists. This
 
enhancement makes the applicant's AMP consistent with the GALL Report and is, therefore, acceptable. These changes to the applicant's program will provide assurance that aging effects
 
will be adequately managed.
Operating Experience. In ALRA Section B2.1.10, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the OCCWS Program.
 
Inspections implementing the guidance of GL 89-13 have identified deterioration (including pipe
 
wall thinning, pinhole leakage, and microbiologically influenced corrosion (MIC)) and
 
degradation (including clogged lines, flow restrictions, and fouling). These deficiencies were
 
documented in CRs and resulted in cleaning, repair, or replacement of the affected components
 
prior to loss of system function.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's OCCWS Program will manage adequately the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
3-56 UFSAR and USAR Supplements. In ALRA Sections A1.1.29 and A2.1.29, the applicant provided the respective UFSAR and USAR supplements for the OCCWS Program. The staff
 
reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's OCCWS Program, the staff determined that those program elements for which the applicant claimed consistency with the
 
GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR 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  Closed-Cycle Cooling Water System Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.11, the applicant described the Closed-Cycle Cooling Water System Program (CCCWS), stating that
 
this is an existing program that is consistent, with enhancements, with GALL AMP XI.M21,"Closed-Cycle Cooling Water System." The CCCWS Program manages loss of material and fouling of components exposed to closed-cycl e cooling water environments. The applicable piping systems at NMPNS include the NMP1 and NMP2 reactor building closed loop coolingsystems, NMP1 control room HVAC system, t he NMP2 control building ventilation chilled water system, the heat exchanger jacket water cooling portions of the NMP1 emergency diesel
 
generator system and the NMP2 standby diesel generator protection (generator) system.
Program activities include chemistry monitoring, surveillance testing, data trending, and
 
component inspections. The CCCWS Program implements the guidelines for controlling system
 
performance and aging effects described in EPRI Report TR-107396.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
The staff reviewed those portions of the CCCWS Program for which the applicant claimedconsistency with GALL AMP XI.M21 and found them consistent. The staff found the applicant's CCCWS Program acceptable because it conforms to the GALL AMP XI.M21 recommendations
 
with enhancements.
In the ALRA, the applicant stated that its CCCWS Program is consistent with GALLAMP XI.M21 with enhancements to meet the GALL Report "preventive actions" program element by revising procedures to address the following:
* Expand periodic chemistry checks of CCCW systems consistent with the guidelines of EPRI TR-107396 (NMP1 and NMP2 Commitment 15).
3-57
* Implement a program to use corrosion inhibitors in the NMP1 and NMP2 reactor building closed loop cooling systems, NMP1 contro l room HVAC system, and NMP2 control building ventilation chilled water system (NMP1 and NMP2 Commitment 15).
In the ALRA, the applicant stated that it is expanding chemistry parameters for the closed-cycle cooling water systems for consistency with the guidelines of EPRI TR-107396. The staff found
 
this enhancement acceptable because it will make the applicant's AMP consistent with the
 
GALL Report. Furthermore, in the ALRA the applicant stated that it will develop an
 
enhancement to implement the use of corrosion inhibitors in the NMP1 and NMP2 reactor
 
building closed loop cooling system, NMP1 c ontrol room HVAC system, and NMP2 control building ventilation chilled water system according to the guidelines in EPRI TR-107396. The
 
staff found this enhancement acceptable because it will make the applicant's AMP consistent
 
with the GALL Report.
As documented in the Audit and Review Report, the staff asked the applicant to clarify whether the chromate corrosion inhibitor used in the NMP1 diesel generator jacket cooling water is
 
consistent with the guidelines in EPRI TR-107396. The applicant responded that the chromate
 
concentrations are outside the range of values provided in that document. The staff asked the
 
applicant to justify the use of a corrosion inhibitor concentration outside the range of values
 
recommended in EPRI Report TR-107396.
In a letter dated December 1, 2005, the applicant stated that the chromate concentration is above the EPRI recommended control limit but consistent with vendor recommendations. In this
 
letter the applicant further stated that the lower concentration limit in the EPRI report is based
 
on the potential impact that the more highly concentrated corrosion inhibitor could have on the
 
life of mechanical seals. The applicant further stated that it had reviewed the maintenance
 
history of mechanical seals at NMP1 and found no occurrence of catastrophic failure. In order to
 
manage the impact of the higher concentration of corrosion inhibitor on the mechanical seal life, the applicant stated that it will establish a required seal replacement frequency of 10 years
 
maximum in lieu of the recommended replacement frequency of every 12 years. Based on
 
satisfactory operation with the vendor-recommended chromate corrosion inhibitor concentration
 
and the establishment of a program to replace the mechanical seals more frequently than
 
recommended. In summary, the staff found the enhancement as committed in ALRA
 
Appendix B2.1.11 acceptable (NMP1 and NMP2 Commitment 15):
For NMP2 the applicant is using a nitrite corrosion inhibitor in the diesel generator jacket cooling water. As documented in the Audit and Review Report, the staff asked the applicant to clarify
 
whether the nitrite corrosion inhibitor used in the NMP2 diesel generator jacket cooling water is
 
consistent with the guidelines in EPRI TR-107396. The applicant stated that the nitrite
 
concentrations are within the range of values provided in that report. The staff found this use
 
acceptable because it is consistent with the chemistry basis recommended in the GALL Report.
In the ALRA, the applicant stated that its CCCWS Program is consistent with the GALL Report with additional enhancements to meet the GALL R eport "parameters monitored/inspected" and "detection of aging effects" program elements by revising procedures to address the following:
* Direct periodic inspections to monitor for loss of material in CCCW systems piping (NMP1 and NMP2 Commitment 15).
3-58
* A corrosion monitoring program for larger bore CCCW piping not subject to inspection under another NMP1 program (NMP1 Commitment 15).
As documented in the Audit and Review Report, the applicant stated that expanding the existing corrosion monitoring program for small bore CCCW piping to include larger bore (greater than
 
3-inch outer diameter) makes its CCCWS Program consistent with the GALL Report. The staff
 
found this enhancement consistent with the GALL Report and, therefore, acceptable. These
 
changes to the applicant's program will provide assurance that aging effects will be adequately
 
managed.Furthermore, in the ALRA the applicant stated that its CCCWS Program is consistent with the GALL Report with enhancements to meet the GALL Report "monitoring and trending" program
 
element by revising procedures to address the following:
* Establish inspection frequencies for degradation of components in CCCW systems, including heat exchanger tube wall thinning (NMP1 and NMP2 Commitment 15).
* Perform a heat removal capability test for the NMP1 control room HVAC system at least every five years (NMP1 Commitment 15).
* Establish periodic monitoring, trending, and evaluation of performance parameters for the NMP1 and NMP2 reactor building closed loop cooling, NMP1 control room HVAC, and NMP2 control building ventilation chilled water systems (NMP1 and NMP2 Commitment 15).
* Specify chemistry sampling frequency for the NMP2 control building ventilation chilled water system. (NMP2 Commitment 15).
The staff found these enhancements to be consistent with the GALL Report and therefore acceptable. These changes to the applicant's program will provide assurance that aging effects
 
will be adequately managed.
In the ALRA, the applicant stated that its CCCWS Program is consistent with the GALL Report with additional enhancements to meet the GALL Report "acceptance criteria" program element by revising procedures to address the following:
* Provide controls and sampling necessary to maintain water chemistry parameters in CCCW systems within the guidelines of EPRI Report TR-107396. (NMP1 and NMP2
 
Commitment 15).
* Ensure acceptance criteria are specified in implementing procedures for indications of degradation (NMP1 and NMP2 Commitment 15).
The staff reviewed these enhancements and found them consistent with the GALL Report and therefore acceptable. These changes to the applicant's program will provide assurance that
 
aging effects will be adequately managed.
In the ALRA, the applicant stated that these enhancements are scheduled for completion prior to the period of extended operation.
3-59 Operating Experience. In ALRA Section B2.1.11, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the CCCWS Program. Review
 
of plant-specific operating experience revealed various forms of degradation that were
 
discovered by CCCWS Program activities at NMP. Corrective actions for observed degradation
 
included increased monitoring, component repai r, or component replacement as deemed necessary. Periodic monitoring of CCCW systems assures that any worsening trends are
 
identified and the capabilities of CCCWS components within the scope of license renewal are
 
maintained.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's CCCWS Program will manage adequately the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.13 and A2.1.14, the applicant provided the respective UFSAR and USAR supplements for the CCCWS Program. The staff
 
reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's CCCWS Program, the staff determined that those program elements for which the applicant claimed consistency with the
 
GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR 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  Boraflex Monitoring Program (NMP1 Only)
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.12, the applicant described the Boraflex Monitoring Program for NMP1, stating that this is an existingprogram that is consistent, with enhancements, with GALL AMP XI.M22, "Boraflex Monitoring."
 
The Boraflex Monitoring Program manages degradation of neutron absorbing material in spent
 
fuel pool storage racks resulting from radiation exposure and possible water ingress. Program
 
activities include: (1) inspection of the NMP1 test coupons to detect dimensional changes; (2) correlation of 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 (3) neutron attenuation
 
testing to measure the boron areal density of the short-length test coupons. The Boraflex
 
Monitoring Program will be enhanced to require periodic in-situ neutron attenuation testing and
 
measurement of boron areal density to confirm the correlation of the conditions of test coupons
 
to those of Boraflex racks that remain in use during the period of extended operation.
3-60 Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
The staff reviewed those portions of the Boraflex Monitoring Program for which the applicantclaimed consistency with GALL AMP XI.M22 and found them consistent. The staff found the
 
applicant's Boraflex Monitoring Program acceptable because it conforms to the recommended GALL AMP XI.M22, "Boraflex Monitoring Program," with enhancements.
In the ALRA and in its letter dated November 17, 2005, the applicant stated that its Boraflex Monitoring Program is consistent with GALL AMP XI.M22 with enhancements to meet the GALL Report "preventive actions," "parameters monito red/inspected,""detection of aging effects," and "monitoring and tranding" program elements.
These enhancements include (1) performance of periodic neutron attenuation testing and measurement of boron areal density to confirm the
 
correlation of the conditions of the test coupons to those of the Boraflex racks remaining in use
 
during the period of extended operation and (2) establishing monitoring and trending
 
instructions for in-situ test results, silica levels, and coupons results. (NMP1 Commitment 16).
In the LRA, the applicant stated that it originally planned to rely mainly on the test coupons, both short and full-length versions, to monitor the Boraflex panel condition. During the initial audit
 
and review (August 9-13, 2004), the staff expressed concern that there is no plan to perform
 
periodic boron areal density testing in the current NMP Boraflex panel conditions. To address
 
the staff's concern, the applicant revised its plan and stated in the ALRA and in its letter dated
 
November 17, 2005, that it will provide direction for periodic performance of neutron attenuation
 
testing and measurement of boron areal density to confirm the correlation of the conditions of
 
the test coupons to those of the Boraflex racks remaining in use during the period of extended
 
operation and establishing monitoring the trending instructions for in-situ test results, silica
 
levels, and coupons results. The staff found these enhancements acceptable. These changes to
 
the applicant's program will provide assurance that aging effects will be adequately managed.
Operating Experience. In ALRA Section B2.1.12, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Boraflex Monitoring
 
Program. Plant-specific operating experience at NMP is related to testing of surveillance
 
coupons, whose results indicate expected levels of degradation. Review of plant-specific
 
operating experience revealed additional conditions t hat were discovered by Boraflex Monitoring Program activities in 2002. When the results of c hemistry analysis indicated silica levels in the NMP1 spent fuel pool slightly greater than the established criteria for plant operation, a CR was
 
initiated. A technical evaluation determined that actual silica levels were acceptable and the
 
operating range was revised accordingly.
As documented in the Audit and Review Report, the staff noted that the applicant is managing the current Boraflex rack conditions. For NMP1 the applicant is in the process of replacing six of
 
the eight Boraflex racks with racks made of Boral. Boraflex racks remaining in the spent fuel
 
pool will be used only in low flux areas and not in the vicinity of freshly discharged fuel. For
 
NMP2 the applicant plans to replace all Boraflex panels with Boral panels prior to period of
 
extended operation (NMP2 Commitment 36).
3-61 The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff conclude that the Boraflex Monitoring Program will manage
 
adequately the aging effects and aging effects mechanisms identified in the ALRA for which this
 
AMP is credited.
UFSAR Supplement. In ALRA Section A1.1.5 and in its letter dated November 17, 2005, the applicant provided the UFSAR supplement for the Boraflex Monitoring Program. The staff
 
reviewed this section and determined that the information in the UFSAR supplement provides
 
an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Boraflex Monitoring Program, the staff determined that those program elements for which the applicant claimed consistency
 
with the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR 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  Inspection of Overhead Heavy Load and Light Load Handling Systems Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.13, the applicant described the Inspection of Overhead Heavy Load and Light Load Handling Systems
 
Program, stating that this is an existing program that is consistent, with enhancements, with GALL AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
 
Handling Systems." The Inspection of Over head Heavy Load and Light Load Handling Systems Program (referred to herein as the Crane Inspection Program) manages loss of material due to
 
corrosion of cranes within the scope of license renewal. Program activities include: (1)
 
performance of various maintenance activities on a specified frequency and (2) pre-operational
 
inspections of equipment prior to lifting acti vities. Crane inspection activities are based on applicable industry standards and the guidance of NUREG-0612.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
During the initial audit and review (August 9-13, 2004) the applicant stated in the program attribute assessment document "Units 1 and 2 Inspection of Overhead Heavy Load and Light
 
Load Handling Systems Program" (since superseded) that under the GALL Report program
 
element "parameters monitored/inspected" comparison "the program ensures that crane 3-62 operation is within the design limits in regards to the number and magnitude of lifts." The staff asked the applicant during the initial audit and review to explain how the number and magnitude
 
of lifts for each crane within the scope of license renewal have been documented historically
 
and will be documented in the future under a renewed license. The applicant also was asked to
 
explain how the individual or individuals responsible for ensuring that crane operations are
 
within crane design limits on the number and magnitude of lifts for license renewal cranes track
 
and maintain this information on a daily or outage basis.
During the initial audit and review, the applicant stated in response to the staff's questions that the statement in the program attribute asse ssment document that the program ensures crane operation is within the design limits on the number and magnitude of lifts is a qualitative and not
 
a quantitative review. The applicant stated in the superseded program attribute assessment
 
document that the cranes at NMP within the scope of license renewal are designed for standby
 
or infrequent service like most cranes in similar applications. Crane capacity loads may be
 
handled for initial installation of equipment and for infrequent maintenance. This crane use is
 
the lightest (Class A) duty cycle according to the Crane Manufacturers Association of America
 
crane service classifications. The applicant concludes that the infrequent use of the cranes
 
below their capacity rated by industry experience and engineering judgment meets the recommendation of GALL AMP XI.M23 for the number and magnitude of lifts and that a
 
documented history is not required. The staff found that the applicant maintained this same view of this GALL AMP XI.M23 program element in the ALRA.
The staff found this explanation acceptable because the cranes within the scope of license renewal are used infrequently. A qualitative review of the number and magnitude of crane lifts is reasonable because recording of the number and magnitude of every crane lift would be an
 
undue documentation burden where crane utilization is well below their design life.
The staff reviewed those portions of the Inspection of Overhead Heavy Load and Light Load Handling Systems Program for which the applicant claimed consistency with GALL AMP XI.M23 and found them consistent. Furthermore, the staff concludes that the applicant's Inspection of
 
Overhead Heavy Load and Light Load Handling Sy stems Program provides reasonable assurance that aging management of loss of material from corrosion of crane structural
 
components within the scope of license renewal will be performed. The staff found the
 
applicant's Inspection of Overhead Heavy Load and Light Load Handling Systems Program acceptable because it conforms to the recommended GALL AMP XI.M23 with an enhancement.
In the ALRA, the applicant stated that its Inspection of Overhead Load and Light Load Handling Systems Program is consistent with GALL AMP XI.M23 with an enhancement to meet the GALL Report "parameters monitored/inspected," "accept ance criteria," and "detection of aging effects" program elements. The applicant stated that various cranes and hoists are not inspected for
 
loss of material of the load-bearing components; therefore, an enhancement to the
 
corresponding preventive maintenance procedure will be made to add a visual inspection for
 
loss of material of the hoist lifting assembly components (NMP1 Commitment 17 and NMP2
 
Commitment 16).
As documented in the Audit and Review Report, the applicant stated that each crane within the scope of license renewal has a procedure which periodically performs an inspection of the
 
crane. This inspection, however, is not specifically of components for loss of material and
 
corrosion. Also, the procedures do not identify specifically the effects of wear on the rails in the 3-63 rail system. Procedures will be enhanced to add visual inspection for loss of material from corrosion and wear on the rails in the rail system.
In addition, as documented in the Audit and Review Report, the applicant stated that this enhancement will add specific inspection steps for general corrosion to the preventive
 
maintenance procedures for each crane within the scope of license renewal. Adding visual
 
inspections to the procedures will be adequate to ensure that loss of material is detected before
 
a loss of intended function. With these additional inspections, the applicant's Inspection of
 
Overhead Heavy Load and Light Load Handling Syst ems Program inspection will meet theprogram recommendations described in GALL AMP XI.M23. The staff found this enhancement
 
acceptable. These changes to the applicant's program will provide assurance that aging effects
 
will be adequately managed.
Operating Experience. In ALRA Section B2.1.13, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Crane Inspection Program.
 
Review of plant-specific operating experience revealed no failures caused by loss of material in
 
crane structural components.
The staff also reviewed the summary of specific operating experience as documented in the Audit and Review Report. The review indicated the Inspection of Overhead Heavy Load and
 
Light Load Handling Systems Program is effective in identifying crane degradation and
 
implementing repairs. A review of NMP plant co rrective action records revealed that there have been no failures from loss of material of crane structural components. Any deficiencies in NMP
 
cranes have been attributed to design flaws, installation deficiencies, adjustments, or improper
 
maintenance procedures. None of these deficiencies resulted in loss of intended function from
 
age-related degradation. These findings provided assurance that loss of material of crane and
 
trolley structural components had not occurred since the inception of the program. After
 
enhancement program procedures will be more effective in detecting age-related degradation, implementing repairs, and maintaining the integrity of NMP load handling systems within the
 
scope of license renewal to ensure discovery and evaluation of loss of material before a loss of
 
intended function.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's Inspection of Overhead Heavy Load and Light Load Handling Systems Program will manage adequately the aging effects and aging effects mechanisms identified in the ALRA for
 
which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.22 and A2.1.22, the applicant provided the respective UFSAR and USAR suppl ements for the Inspection of Overhead Heavy Load and Light Load Handling Systems Program. The staff reviewed these sections and
 
determined that the information in the supplements provides adequate summary descriptions of
 
the program, as required by 10 CFR 54.21(d).
3-64 Conclusion. On the basis of its review and audit of the applicant's Inspection of Overhead Heavy Load and Light Load Handling Systems Program, the staff determined that those
 
program elements for which the applicant claimed consistency with the GALL Report are
 
consistent with the GALL Report. Also, the staff has reviewed the enhancements and confirmed
 
that the implementation of the enhancements prior to the period of extended operation would
 
result in the existing AMP being consistent with the GALL Report AMP to which it was
 
compared.The staff concludes that there is reasonable assurance that the applicant
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions 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 UFSAR 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  Compressed Air Monitoring Program (NMP1 Only)
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.14, the applicant described the Compressed Air Monitoring Program for NMP1, stating that this is an
 
existing program that is consistent, with exceptions and enhancements, with GALL AMP XI.M24, "Compressed Air Monitoring."
The Compressed Air Monitoring Program manages aging effects for portions of the compressed air systems within the scope of license renewal, including cracking and loss of material due to general corrosion, by controlling the internal
 
environment of systems and components. Program activities include air quality checks at various locations to detect contaminants that would affect the system's intended function.
 
Additional visual inspections are credited for identification and monitoring of degradation for air
 
compressors, receivers, and air dryers. The Compressed Air Monitoring Program is based on
 
GL 88-14 and recommendations presented in INPO Significant Operating Event Report 88-01.
 
The Compressed Air Monitoring Program is only applicable to NMP1 since the components
 
requiring aging management for the NMP2 co mpressed air system are managed under the 10 CFR Part 50, Appendix J Program and the One-Time Inspection Program.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exceptions and
 
enhancements and the associated justifications to determine whether the AMP, with the
 
exceptions and enhancements, remains adequate to manage the aging effects for which it is
 
credited.In the "Exceptions to NUREG-1801" section of the ALRA the applicant stated that it took specific exception to any maintenance recommended in EPRI TR-108147, "Compressor and Instrument Air System Maintenance Guide: Revision to NP-7079," not endorsed also by the equipment
 
manufacturers and to the pre-service and in-service testing guidelines of ASME OM-S/G-1998, Part 17, "Performance Testing of Instrument Air Systems Information Notice Light-Water
 
Reactor Power Plants." As documented in the Audit and Review Report, the staff asked the
 
applicant to clarify why this exception was not mentioned in the "NUREG-1801 Consistency"
 
section of the ALRA. In its letter dated December 1, 2005, the applicant stated that it will revise
 
NMP AMP B2.1.14, to read:
3-65 The Compressed Air Monitoring Program is an existing program that will beconsistent with NUREG-1801, Section XI.M24 (Compressed Air Monitoring)
(Reference 2), with exceptions, after enhancements are incorporated.
The staff reviewed those portions of the Compressed Air Monitoring program for which theapplicant claimed consistency with GALL AMP XI.M24 and found them consistent. The staff
 
found the applicant's Compressed Air Monitoring Program acceptable because it conforms to the recommended GALL AMP XI.M24 with exceptions and enhancements.
During the audit, the applicant stated that its Compressed Air Monitoring Program is consistentwith GALL AMP XI.M24 with an exception. The Compressed Air Monitoring Program takes
 
exception to the GALL Report "preventive actions" and "detection of aging effects" program
 
elements. As stated in the ALRA, NMP1 takes a limited exception related to maintenance
 
suggestions in EPRI NP-7079 and EPRI TR-108147 not also endorsed by the manufacturer.
 
NMP1 takes specific exception to the pre-service and in-service testing guidelines of ASME
 
OM-S/G-1998, Part 17. It also takes specific exc eption to the pre-service and in-service testing guidelines of ASME OM-S/G-1998, Part 17.
The applicant also stated in justification for the GALL Report exception that (1) the maintenance practices reviewed and enhanced under the NMP1 response to GL 88-14 are adequate to
 
manage aging without additional testing and (2) there have been no age-related failures of the
 
compressed air monitoring system under its current program.
As documented in the Audit and Review Report, the staff noted that the applicant did not list ANSI/ISA-S7.0.01-1996 in NMP AMP B2.1.14. The staff inquired whether the applicant used
 
this standard for air quality. In its letter dated December 1, 2005, the applicant stated that it will
 
add the following for clarification:
NMP also takes exception to the use of ISA-S7.0.01-1996 for air quality standards. This is acceptable because the system air quality is monitored and
 
maintained in compliance with the requirements of ANSI/ISA-S7.3-1975, "Air
 
Quality Standards for Pneumatic Instruments" which meets or exceeds the
 
quality requirements for dew point, hydrocarbons, and particulate of Section 4.4
 
of EPRI TR-108147 and ISA-S7.0.01-1996.
The staff agreed with the applicant's assessment because the ANSI/ISA-S7.3-1975 air quality standard is higher than the ANSI/ISA-S7.0.01-1996 standard.
As documented in the Audit and Review Report, the staff noted that (1) the applicant had performed a satisfactory design and operations verification of the instrument air system in
 
response to GL 88-14, (2) the applicant has incorporated the INPO good engineering practice
 
recommendations on the instrument air system into its maintenance procedures, as described in
 
the INPO Significant Operating Experience Report (SOER) 88-01, (3) the applicant's air
 
sampling analysis procedure specifies the quality requirements of dew point, oil, water, and
 
particle size based on ANSI/ISA-S7.0.01-1975, "Quality Standard for Instrument Air," (4) the
 
applicant routinely performs preventative maintenance and inspection on the compressor and
 
carbon steel components to limit the introduction of contaminants into the air supply, and (5) the
 
applicant regularly tests the active compress ed air system valves and skid mounted compressor components to ensure their operability. All of these activities demonstrate that the applicant has 3-66 an adequate preventive maintenance program for inoperability of air-operated components due to corrosion and the presence of oil, water, rust, and other contaminants. In addition review of
 
the applicant's operating experience indicated that the its Compressed Air Monitoring Program
 
has an acceptable record of ensuring maintenance of the design basis function of the system.
 
Therefore, the staff agreed with the applicant's assessment and concludes that the applicant's
 
Compressed Air Monitoring Program includes good practice for general maintenance and
 
inspection of the compressor, receiver, and dryer as addressed in EPRI TR-108147 and ASME
 
OM-S/G-1998, Part 17. On these bases the staff found this exception acceptable.
In the ALRA, the applicant stated that its Compressed Air Monitoring Program is consistent withGALL AMP XI.M24 with enhancements to meet the GALL Report "scope of program,"
"preventive actions," "detection of aging effects," "monitoring and trending," and "acceptance
 
criteria" program elements by revising procedures to address such elements.    * "Scope of program," "preventive action," and "detection of aging effects" program elements - develop new activities to manage loss of material and SCC, perform periodic
 
system leak checks, and expand the scope, periodicity, and inspection techniques to
 
ensure aging management of aging of certain subcomponents of the dryers and
 
compressors (e.g., valves, heat exchangers) (NMP1 Commitment 18).  * "Monitoring and trending" program element - establish activities that manage the aging of internal surfaces of carbon steel piping and that require system leak checks to detect
 
deterioration of the pressure boundaries (NMP1 Commitment 18).    * "Acceptance criteria" program element - expand the acceptance criteria to ensure aging management of certain subcomponents of the dryers and compressors (e.g., valves, heat exchangers) (NMP1 Commitment 18).
As documented in the Audit and Review Report, the applicant stated that these enhancements are required to develop activities that manage loss of material due to general corrosion of such
 
carbon steel components upstream of the dryers as piping, receivers, and valves. Other new
 
required activities will address red brass pipe SCC and perform periodic system leak checks.
Certain existing activities will be revised to expand the scope and frequency of inspections so that aging of such sub-components of the dryers and compressors as solenoid-operated valves
 
and heat exchangers is addressed adequately. As documented in the Audit and Review Report, the staff noted that these additional activities are results of the applicant's ongoing evaluation of
 
its Compressed Air Monitoring Program to account for internal and external plant operating
 
experience problems. The staff found these enhancements acceptable. These changes to the
 
applicant's program will provide assurance that aging effects will be adequately managed.
Operating Experience. In ALRA Section B2.1.14, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Compressed Air Monitoring
 
Program. Since its inception in 1992, the Compressed Air Monitoring Program has effectively
 
detected the buildup of corrosion products and prevented component failure. NMP1 has
 
experienced age related degradation due to stress corrosion cracking in unannealed red brass
 
piping in areas that may have been chemically contaminated. However, no pneumatic
 
component within the scope of license renewal has experienced a loss of intended function due
 
to corrosion, corrosion product buildup, or dirt buildup in the instrument air system.
3-67 The applicant also stated in the ALRA that it reviews both industry and plant-specific operating experience relating to its Compressed Air Monitoring Program and continually adjusts to
 
account for internal and external plant operating experience issues. After discussions with the
 
applicant's technical staff and a sampling review of the CR list associated with the applicant's
 
Compressed Air Monitoring Program the staff concurred that the applicant incorporates the
 
operating experience into its operations effectively.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's Compressed Air Monitoring Program (NMP1 only) will manage adequately the aging
 
effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR Supplement. In ALRA Section A1.1.14, the applicant provided the UFSAR supplement for the Compressed Air Monitoring Program. The staff reviewed this section and determined that
 
the information in the UFSAR supplement provides an adequate summary description of the
 
program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Compressed Air Monitoring Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report. In addition, the staff
 
reviewed the exceptions and the associated justifications, and determined that the AMP, with
 
the exceptions, is adequate to manage the aging effects for which it is credited. Also, the staff
 
has reviewed the enhancements and confirmed t hat the implementation of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with
 
the GALL Report AMP to which it was compared.The staff concludes that there is reasonable
 
assurance that the applicant demonstrated that the effects of aging will be adequately managed
 
so that the intended functions 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 UFSAR
 
supplement for this AMP and concludes that it provides an adequate summary description of the
 
program, as required by 10 CFR 54.21(d).
3.0.3.2.12  BWR Reactor Water Cleanup System Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.15, the applicant described the BWR Reactor Water Cleanup System Program, stating that this is an
 
existing program that is consistent, with exception, with GALL AMP XI.M25, "BWR Reactor Water Cleanup System." The BWR Reactor Wa ter Cleanup System Program manages the effects of SCC or IGSCC on the intended function of austenitic stainless steel piping in the
 
reactor water cleanup (RWCU) system. This program is based on the NRC criteria related to
 
inspection guidelines for RWCU piping welds outboard of the containment isolation valve as
 
delineated in NUREG-0313, Revision 2, and GL 88-01. An exception is taken to the acceptance
 
criteria program element in that NMP1 utilizes the 1989 edition with no addenda of the ASME Section XI code versus the 1995 edition through the 1996 addenda as defined in the GALL. The
 
design of the NMP2 RWCU system is such that carbon steel piping welds are not required to be
 
examined in accordance with GL 88-01. The attributes of the BWR Reactor Water Cleanup 3-68 System Program related to maintaining reactor coolant water chemistry are included in the Water Chemistry Control Program.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exception and the
 
associated justifications to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.
The staff reviewed those portions of the BWR Reactor Water Cleanup System Program forwhich the applicant claimed consistency with GALL AMP XI.M25 and found them consistent.
 
The staff found the applicant's BWR Reactor Water Cleanup System Program acceptable because it conforms to the recommended GALL AMP XI.M25 with an exception.
In the ALRA, the applicant stated that its BWR Reactor Water Cleanup System Program isconsistent with GALL AMP XI.M25 with an exception. The BWR Reactor Water Cleanup System
 
Program takes exception to the "acceptance crit eria" program element. As stated in the ALRA, the exception to this program element is that the program described in GALL AMP XI.M25 citesASME Section XI requirements covered in the 1995 Edition through the 1996 Addenda for the
 
"acceptance criteria" element. NMP1 uses the 1989 Edition with no addenda.
As documented in the Audit and Review Report, the staff requested that the applicant clarify the ASME edition that would be used for aging management during the extended period of
 
operation. The applicant stated that the use of later code editions and addenda of ASME Section XI is determined according to 10 CFR 50.55a requirements 12 months before the start
 
of each 120-month inspection interval subject to limitations and modifications by the staff and requires NRC approval. The staff found this response acceptable as the applicant clarified that the ASME XI Edition will have to be chosen according to applicable regulations and submitted
 
for NRC approval. On this basis the staff found this exception acceptable.
Operating Experience. In ALRA Section B2.1.15, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to cracking in the reactor water
 
cleanup system. Review of plant-specific operating experience for NMP1 identified that leaks
 
were experienced in two welds outboard of the second isolation valve. Weld 33-FW-22 had
 
undergone a localized repair during its original construction and consequently, became more
 
sensitized. Weld 33-FW-23A is a one of a kind design configuration that promotes very high
 
stresses due to the fact that it connects very large shells that have different thermal movement
 
that cannot be accommodated by the short and stiff pipe. In addition, the pipe is subject to
 
thermal cycling. Both welds were repaired by a full structural weld overlay.
As documented in the Audit and Review Report, the staff reviewed plant-specific experience documented in a CR and summarized in the RWCU program basis document. The CR
 
addressed a leak in the RWCU system from a 7/16" axial crack (in a bimetallic weld where
 
stainless steel piping was replaced with carbon steel). The mechanism was classified as IGSCC
 
and the leak was repaired with a weld overlay. This type of leak was discussed in GL 88-01. To
 
confirm that this weld failure was a unique incident the applicant performed additional UT exams
 
on a sample of three other RWCU welds. The sample size was based on the planned sample
 
expansion criteria used during outages for RWCU inspections performed to comply with GL
 
88-01.
3-69 The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's BWR Reactor Water Cleanup System Program will manage adequately the aging
 
effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.9 and A2.1.10, the applicant provided the respective UFSAR and USAR supplements for the BWR Reactor Water Cleanup System
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provides adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWR Reactor Water Cleanup System Program, the staff determined that those program elements for which the applicant
 
claimed consistency with the GALL Report are consistent with the GALL Report. In addition, the
 
staff reviewed the exception and the associated justifications, and determined that the AMP, with the exception, is adequate to manage the aging effects for which it is credited.The staff
 
concludes that there is reasonable assurance that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR 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  Fire Protection Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.16, the applicant described the Fire Protection Program, stating that this is an existing program that is consistent, with exceptions and enhancements, with GALL AMP XI.M26, "Fire Protection." The
 
Fire Protection Program provides guidance for performance of periodic visual inspections to manage aging of the various materials comprising rated fire barriers. These include: (1)
 
sealants in rated penetration seals (subject to shrinkage due to weathering); (2) concrete and
 
steel in fire rated walls, ceilings, and floors (subject to loss of material due to flaking and
 
abrasion; separation and concrete damage due to relative motion, vibration, and shrinkage);
 
and (3) steel in rated fire doors (subject to loss of material due to corrosion and wear or
 
mechanical damage). In addition, the program requires testing of the diesel-driven fire pump to
 
verify that it is performing its intended function. This activity manages aging of the diesel
 
engine's fuel oil supply line and exhaust system, which may experience loss of material due to
 
corrosion. Inspection and testing is performed in accordance with the guidance of applicable
 
standards.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exceptions and
 
enhancements and the associated justifications to determine whether the AMP, with the
 
exceptions and enhancements, remains adequate to manage the aging effects for which it is
 
credited.
3-70 The staff reviewed those portions of the Fire Protection Program for which the applicant claimedconsistency with GALL AMP XI.M26 and found them consistent. The staff found the applicant's
 
Fire Protection Program acceptable because it conforms to the recommended GALL AMP XI.M26 with exceptions and enhancements.
In the ALRA, the applicant stated that its Fire Protection Program is consistent with GALLAMP XI.M26 with exceptions. The Fire Protecti on Program takes exception to the GALL Report "detection of aging effects" program element where it requires bi-monthly inspection of hollow
 
metal fire doors and monthly inspection of the halon/carbon dioxide suppression system valve lineup. Rather, NMP is consistent with Interim Staff Guidance (ISG-) 04, "Aging Management of
 
Fire Protection Systems for License Renewal," on both issues.
In the ALRA, the applicant stated that the current fire doors inspection frequency will be changed to comply with a plant-specific engineering evaluation of inspection intervals. This
 
change is consistent with ISG-04, as is states that fire doors are inspected visually on
 
plant-specific intervals for integrity of door surfaces and for clearances. On this basis the staff
 
found this exception acceptable.
In the ALRA, the applicant stated that consistent with ISG-04 and the latest regulatory guidance of GL-86-10 valve lineups on the carbon dioxi de/halon suppression systems will not be credited for aging management in its Fire Protection Program. Because ISG-04 states that valve lineup
 
inspection, charging pressure inspection, and an automatic mode of operation verification are
 
operational activities pertaining to system or component configurations or properties that may
 
change and are not related to aging management the staff found this exception acceptable.
In the ALRA, the applicant further stated that its Fire Protection Program is consistent withGALL AMP XI.M26 with enhancements to the GALL Report "scope of program," "parameters monitored/inspected," "detection of aging effects," and "acceptance criteria" program elements.
As part of the proposed enhancement the applicant will revise procedures to address the following elements:
* Incorporate periodic visual inspections of piping and fittings in a non-water environment (e.g., halon) and carbon dioxide fire suppression systems components to detect
 
evidence of corrosion and any system mechanical damage that could affect its intended
 
function (NMP1 Commitment 19, NMP2 Commitment 17).
* Expand the scope of periodic function tests of the diesel-driven fire pump to include inspection of engine exhaust system components to verify that loss of material is
 
managed (NMP1 Commitment 19, NMP2 Commitment 17).
* Perform an engineering evaluation to determine the plant-specific inspection frequency of fire doors (NMP1 Commitment 19, NMP2 Commitment 17).
The staff found Commitment 19 of Appendix A1.4 for NMP1 and Commitment 17 of Appendix A2.4 for NMP2 consistent with ISG-04 which provides a specific frequency for both inspections and function tests. The staff found that the enhancement adequately manages the
 
aging effects of piping and fittings in halon and carbon dioxide fire suppression systems
 
components.
3-71 As part of these commitments the scope of periodic functional tests of the diesel-driven fire pump will be expanded to include inspection of engine exhaust system components. The staff found that the enhancement adequately manages to maintain the functional reliability of the
 
diesel-driven fire pump.
As part of these commitments engineering evaluations will determine the plant-specific inspection frequency of fire doors. The staff determined that though is not consistent with the
 
GALL Report this enhancement is consistent with ISG-04, which states that hollow metal fire
 
doors should be inspected on a plant-specific interval and that this interval should be
 
determined by an engineering evaluation. On this basis the staff found this enhancement
 
acceptable.
In its letter dated November 17, 2005, the applicant stated that an enhancement to meet the GALL Report "detection of aging effects" program element revised procedures to address the
 
following elements:
Halon and carbon dioxide functional test frequencies will be changed to semi-annual in the Fire Protection Program procedures as an addition to NMP1 Commitment 19 and NMP2
 
Commitment 17. The staff reviewed this enhancement and found it consistent with the GALL
 
Report and acceptable.
Operating Experience. In ALRA Section B2.1.16, the applicant explained that it has evaluated applicable industry operating experience. Applicable guidelines and requirements have been
 
incorporated into Fire Protection Program implementing procedures. Minor degradation has
 
been identified while performing Fire Protection Program activities (e.g., fire barrier penetration
 
seals found damaged or cracked, fire dampers failed surveillance testing, and fire door
 
inspections not satisfactory) and corrective actions taken. No significant age-related problems
 
have been reported for NMP fire protecti on systems and components managed by the Fire Protection Program.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the
 
applicant's Fire Protection Program, NMP AMP B2.1.16, will manage adequately the aging
 
effects identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.17 and A2.1.17, the applicant provided the respective UFSAR and USAR supplements for the Fire Protection Program. The
 
staff reviewed these sections and determined that the information in the supplements provides
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Fire Protection Program, the staff determined that those program elements for which the applicant claimed consistency with
 
the GALL Report are consistent with the GALL Report. In addition, the staff reviewed the
 
exceptions and the associated justifications, and determined that the AMP, with the exceptions, is adequate to manage the aging effects for which it is credited. Also, the staff has reviewed the 3-72 enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR 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  Fire Water System Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.17, the applicant described the Fire Water System Program, stating that this is an existing program thatis consistent, with enhancements, with GALL AMP XI.M27, "Fire Water System." The Fire Water
 
System Program manages aging of water-based fire protection systems due to loss of material and biofouling. Program activities include periodic maintenance, testing, and inspection of
 
system piping and components containing water (e.g., sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes). Inspection and testing is performed in accordance with the
 
guidance of applicable National Fire Protection Association (NFPA) Codes and Standards and
 
the Nuclear Electric Insurance Limited Members' Manual.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, is adequate to
 
manage the aging effects for which it is credited.
The staff reviewed those portions of the Fire Water System Program for which the applicantclaimed consistency with GALL AMP XI.M27 and found them consistent. The staff found the
 
applicant's Fire Water System Program acceptable because it conforms to the recommended GALL AMP XI.M27 with enhancements.
In the ALRA and in its letter dated November 17, 2005, the applicant stated that its Fire Water System Program is consistent with GALL AMP XI.M27 with enhancements to meet the GALL Report "scope of program" program elem ent and program description. The enhancement includes revising procedures to address the following elements:
* Incorporate into existing periodic test procedures inspections to detect and manage loss of material due to corrosion (NMP1 Commitment 20, NMP2 Commitment 18).
* Incorporate into sprinkler head replacements or inspections procedures and preventive maintenance tasks to meet NFPA 25, "Inspection, Testing, and Maintenance of Water-
 
based Fire Protection System," Section 5.3.1 (2003 Edition) requirements (NMP1
 
Commitment 20, NMP2 Commitment 18).
This enhancement is stated in Commitment 20 of ALRA Section A1.4 for NMP1 and Commitment 18 of Section A2.4 for NMP2. The GALL Report recommends that portions of the
 
fire protection suppression piping located above ground and exposed to water be disassembled
 
and internally inspected visually once ever y refueling outage. ISG-04, "Aging Management of 3-73 Fire Protection Systems for License Renewal,"
recommends the use of non-intrusive testing of the piping system. The incorporation of new inspection and NFPA 25 requirements into existing
 
procedures will satisfy ISG-04. The staff found this enhancement acceptable.
In addition the applicant stated in its letter dated November 17, 2005, that as an addition to Commitment 20 of ALRA Section A1.4 and Commitment 18 of ALRA Section A2.4 new
 
procedures and preventive maintenance tasks for sprinkler head replacements or inspections to
 
meet NFPA 25 will be added to its Fire Water System Program. The staff reviewed this
 
enhancement and found it consistent with the GALL Report and acceptable.
In its letter dated November 17, 2005, the applicant also stated that an enhancement in meeting the GALL Report "preventive actions" program element revises procedures to address the following element:
* Specify periodic component inspections to verify management of loss of material (NMP1 Commitment 20, NMP2 Commitment 18).
In the ALRA, the applicant stated that an enhancement to increase the frequency of inspection of components will be added to the scope of its Fi re Water System Program to ensure further that loss of material is managed. This improvement of procedures consistent with ISG-04 and
 
with the GALL Report is stated in NMP1 Commitment 20 and NMP2 Commitment 18. The staff
 
found this enhancement acceptable. These changes to the applicant's program will provide
 
assurance that aging effects will be adequately managed.
In the ALRA and in its letter dated November 17, 2005, the applicant further stated an enhancement to meet the GALL Report "parameter s monitored/inspected" program element to revise procedures to address the following:
* Add procedural guidance for performing visual inspections to monitor internal corrosion and detect biofouling (NMP1 Commitment 20, NMP2 Commitment 18).
In the ALRA, the applicant stated in Commitment 20 of ALRA Section A1.4 and Commitment 18 of Section A2.4 that an enhancement will be made to add procedural guidance for performing
 
visual inspections to monitor internal corrosion and detect biofouling for fire protection piping
 
systems. The applicant also stated in its letter dated November 17, 2005, that the Fire Water
 
System Program will be enhanced by adding the requirements for procedures and preventive maintenance tasks to implement sprinkler head replacement or inspections to meet NFPA 25.
 
The staff reviewed this enhancement and concludes that it will make the applicant's Fire Water
 
System Program consistent with ISG-04 and NFPA 25 for non-intrusive inspections. ISG-04
 
states that disassembly of piping may not be the most effective method to detect aging effects.
 
Each opening of the system introduces oxygen which accelerates the potential for general
 
corrosion. ISG-04 recommends non-intrusive pipe wall thickness evaluations like volumetric
 
inspection. ISG-04 also states that the plant maintenance process may include a visual
 
inspection of the internal surface of the fire protection piping with routine or corrective
 
maintenance.
In addition the applicant stated in its letter dated November 17, 2005, that new procedures and preventive maintenance tasks for sprinkler head replacements or inspections will be added to its
 
Fire Water System Program to meet NFPA 25. On this basis, the staff found this enhancement
 
sufficient to manage the aging effects of fire protection piping systems.
3-74 In the ALRA, the applicant also stated that an enhancement to meet the GALL Report "detection of aging effects" program element revises procedures to address the following:
* Add specifications to periodically check water-based fire protection systems for microbiological contamination (NMP1 Commitment 20, NMP2 Commitment 18).
* Measure fire protection system piping wall thickness using non-intrusive techniques (e.g., volumetric testing) to detect loss of material from corrosion (NMP1 Commitment
 
20, NMP2 Commitment 18).
In the ALRA, the applicant stated in Commitment 20 of ALRA Section A1.4 and Commitment 18 of ALRA Section A2.4 for NMP2 that requirements are to be added to check the water-based
 
fire protection systems periodically for microbi ological contamination. The staff reviewed this enhancement and found it consistent with the GALL Report and acceptable.
In the ALRA, the applicant stated in Commitment 20 of ALRA Section A1.4 for NMP1 and Commitment 18 of ALRA Section A2.4 for NMP2 that measurement of fire protection piping wall
 
thicknesses using non-intrusive techniques (e.g., volumetric testing) will be implemented. The
 
staff reviewed this enhancement and found it consistent with ISG-04. The staff found these
 
enhancements acceptable. These changes to the app licant's program will provide assurance that the affects of aging will be adequately managed.
In addition in the ALRA the applicant stated that an enhancement in meeting the GALL Report "monitoring and trending" program element revises procedures to address the following
 
elements:
* Establish an appropriate means of recording, evaluating, reviewing, and trending the results of visual inspections and volumetric testing. (NMP1 Commitment 20, NMP2
 
Commitment 18)
In the ALRA in Commitment 20 of ALRA Section A1.4 and Commitment 18 of ALRA Section A2.4 the applicant stated that an appropriate means of recording, evaluating, reviewing, and trending the results of visual inspections and volumetric testings will be added to existing
 
procedures. The staff found this enhancement consistent with ISG-04. An appropriate means of
 
recording, evaluating, reviewing, and trending the results of visual inspections is consistent with
 
the GALL Report and an appropriate means of recording, evaluating, reviewing, and trending
 
the results of volumetric testing is consistent with the ISG-04. On this basis the staff found this
 
enhancement acceptable. These changes to the applicant's program will provide assurance that
 
aging effects will be adequately managed.
Furthermore, in the ALRA the applicant stated in Commitment 20 of ALRA Section A1.4 and Commitment 18 of ALRA Section A2.4 that the enhancement in meeting the GALL Report
 
"acceptance criteria" program element revises procedures to address the following element:
* Define acceptance criteria for visual inspections and volumetric testing (NMP1 Commitment 20, NMP2 Commitment 18).
The staff reviewed this enhancement and found it acceptable. The new acceptance criteria will provide in the inspection procedure parameters more specific than those listed in the GALL 3-75 Report, which states that no unacceptable signs of degradation should be observed during visual assessment of internal system c onditions under the program element "acceptance criteria." The GALL Report does not include volumetric testing; hence, it does not have
 
acceptance criteria for volumetric testing. The staff found this enhancement acceptable. These
 
changes to the applicant's program will provide assurance that aging effects will be adequately
 
managed.Operating Experience. In ALRA Section B2.1.17, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Fire Water System
 
Program. A review of the CAP shows that individual components have experienced various
 
types of non-conformances (e.g., pinhole leaks, pipe wall thinning). Evaluations have
 
demonstrated that no loss of system function w ould occur. CRs have been initiated to document conditions discovered while performing Fire Wate r System Program activities. Internal system leakage and failed surveillance tests were often traced to fouling of valve seating surfaces with
 
sand or silt. Typical resolutions included adding sections of piping to specific flushing
 
procedures or periodic disassembly and cleaning of components.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff, the staff concludes that there is reasonable assurance that the
 
applicant's Fire Water System Program will manage adequately the aging effects identified in
 
the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.18 and A2.1.18, the applicant provided the respective UFSAR and USAR suppl ements for the Fire Water System Program.
The staff reviewed these sections and determined that the information in the supplements
 
provides adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Fire Water System Program, the staff determined that those program elements for which the applicant claimed consistency
 
with the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR 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  Fuel Oil Chemistry Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.18, the applicant described the Fuel Oil Chemistry Program, stating that this is an existing program that is consistent, with exceptions and enhancements, with GALL AMP XI.M30, "Fuel Oil Chemistry."
The Fuel Oil Chemistry Program manages loss of material due to corrosion that may result from 3-76 introduction of contaminants into the plant's fuel oil tanks. Program activities include: (1) sampling and chemical analysis of the fuel oil inventory at the plant; (2) sampling, testing, and
 
analysis of new fuel oil as it is unloaded at the plant; and (3) cleaning and inspection of fuel oil
 
tanks. The Fuel Oil Chemistry Program is based on maintaining fuel oil quality in accordance
 
with the guidelines of American Society for Testing and Materials (ASTM) Standards D975, D1796, D2276, and D4057.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exceptions and
 
enhancements and the associated justifications to determine whether the AMP, with the
 
exceptions and enhancements, remains adequate to manage the aging effects for which it is
 
credited.The staff reviewed those portions of the Fuel Oil Chemistry Program for which the applicantclaimed consistency with GALL AMP XI.M30 and found them consistent. The staff found the
 
applicant's Fuel Oil Chemistry Program acceptable because it conforms to the recommended GALL AMP XI.M30, "Fuel Oil Chemistr y," with exceptions and enhancements.
In the ALRA, the applicant stated that its Fuel Oil Chemistry Program is consistent with GALLAMP XI.M30 with exceptions. The Fuel Oil Chemis try Program takes exceptions to the GALL Report "parameters monitored/inspected" and "acceptance criteria" program elements. NMP1 and NMP2 take exception to using both ASTM D1796 and ASTM D2709, "Standard Test
 
Method for Water and Sediment in Middle Distillate Fuels by Centrifuge," to determine the
 
concentration of water and sediment in the diesel fuel oil tanks. NMP1 and NMP2 use only the
 
guidance given in ASTM D1796. These standards apply to fuel oils of different viscosities. The
 
ASTM D1796 standard applies to the diesel fuel used at NMP1 and NMP2. NMP1 and NMP2
 
take exception to using the modified ASTM D2276 Method A, which specifies a pore size of 3.0m. NMP1 and NMP2 use a filter with a pore size of 0.8 m as specified in ASTM D2276.
On the first exception the staff found that the applicant is using the standard recommended by the GALL Report and one that the applicant states is appropriate for the viscosity of the fuel oil
 
in use at the site. As documented in the Audit and Review Report, the staff found the use of
 
ASTM D1796 acceptable because it is the appropriate testing procedure for the fuel oil in use at
 
NMP1 and NMP2. The staff determined the applicant's use of a filter pore size of 0.8 microns
 
instead of the 3.0 micron pore size recommended by the modified ASTM D2276 Method A to be
 
prudent for monitoring the presence of particulates in the fuel oil. The staff found this exception
 
in selection of the pore filter size acceptable.
The applicant also stated, by letter dated December 1, 2005, that it will add an exception to the "preventive actions" program element of the GALL Report. NMP1 and NMP2 take exception to the addition of fuel oil additives (biocides, stabilizers, and corrosion inhibitors) in the fuel oil
 
storage tanks. NMP2 monitors fuel quality, in part, through particulate contamination analysis.
 
The applicant stated that if the results from the particulate analysis exceed acceptance criteria, then biocides, stabilizers, and/or corrosion inhibitors will be evaluated for addition. The
 
particulate analysis acceptance criteria combined with the current program, periodic cleaning of
 
the tanks and removal of water is used to mange the aging effects of concern. NMP1 plans to
 
initiate the same evaluation, pending the incorporation of an identified enhancement. The staff 3-77 found this exception acceptable and adequate for the aging management of the fuel oil storage tanks.The applicant also stated in the ALRA that it takes exceptions to the GALL Report "detection of aging effects" program element. NMP1 and NMP2 take exception to multilevel sampling in the
 
diesel fuel oil tanks. The physical configuration of the fuel oil tanks does not allow a
 
representative fuel oil sample to be taken at multiple levels.
As documented in the Audit and Review Report, the applicant clarified that the measurements are taken at approximately six inches from the tank bottom. The tanks also are drained and
 
cleaned periodically to reduce the build-up of water or sediment. Because the sample is taken
 
from near the bottom where water and sediment would accumulate the staff found sampling at
 
this location a conservative representation of the whole tank contents. On this basis the staff
 
found this exception acceptable.
In its letter dated November 17, 2005, The applicant also stated that it will add an exception of the "detection of aging effects" program element of the GALL Report. NMP1 and NMP2 take
 
exception to performing internal inspections of any fuel oil tank. The applicant stated that after
 
enhancement, all such tanks will be routinely drained; thereby removing any contaminants from
 
the tank that would provide an aging mechanism. The staff confirmed the enhancements for
 
both units and found the exception acceptable.
The applicant further stated in the ALRA that it takes exception to the GALL Report "parameters monitored/inspected," "detection of aging effects," and "monitoring and trending" program
 
elements. NMP1 and NMP2 take exception to peri odic sampling of the diesel fuel oil day tanks.
These small tanks have no provision for sampling. Per technical specification surveillance
 
testing, the lower portion of the diesel fuel oil is drained quarterly in NMP1 and monthly in
 
NMP2. Such an exception has been accepted in NUREG-1796, "Dresden and Quad Cities
 
Safety Evaluation Report."
As documented in the Audit and Review Report, the applicant clarified that these are small tanks, the diesel fire pump day tank approximately 275 gallons and the emergency diesel fuel oil
 
day tank approximately 400 gallons. In addition per technical specification surveillance testing
 
the lower portion of the diesel fuel oil in these tanks is drained back to the larger storage tanks
 
quarterly for NMP1 and monthly for NMP2. Any water in the fuel oil is detected during the
 
surveillance of the bulk storage tanks. Based on its review of this information the staff concludes
 
that as the oil in the diesel fuel oil day tanks is sampled periodically when drained back to the
 
larger storage tank, this exception is acceptable.
In the ALRA, the applicant stated that its Fuel Oil Chemistry Program is consistent with GALLAMP XI.M30 with additional enhancements to m eet the GALL Report "scope of program,"
"preventive actions," "parameters monitored/
inspected," "detection of aging effects," and "monitoring and trending" by revising procedures to address the following:
* Incorporate periodic tests for microbiological organisms at NMP1.
* Provide guidelines for the appropriate use of biocides, corrosion inhibitors, or fuel stabilizers to maintain fuel oil quality (NMP1 Commitment 21, NMP2 Commitment 19).
3-78
* Add specifications to sample the NMP2 diesel fuel oil storage tanks for water and sediment at least quarterly per the ASTM standard (NMP2 Commitment 19)
In its letter dated November 17, 2005, the applicant deleted the first enhancement, "incorporate periodic tests for microbiological organisms at NMP1" because this test already is performed and the enhancement is not needed.
The staff found these enhancements consistent with the GALL Report recommendations and therefore acceptable. These changes to the applicant's program will provide assurance that
 
aging effects will be adequately managed.
In addition in the ALRA the applicant stated that an enhancement to meet the GALL Report "preventive actions" and "detection of aging effects" program elements revises applicable
 
existing procedures to address the following:
* Add specifications to inspect the interior surfaces of the NMP1 emergency diesel fuel oil tanks and diesel fire pump fuel oil day tank and the NMP2 fuel oil tanks periodically for
 
evidence of significant degradation, including a specific requirement that the tank bottom
 
thickness be determined (NMP1 Commitment 21, NMP2 Commitment 19)
In its letter dated November 17, 2005, the applicant deleted the "diesel fire pump fuel oil day tank" from this enhancement. The staff found this enhancement consistent with the GALL
 
Report and therefore acceptable. These changes to the applicant's program will provide
 
assurance that aging effects will be adequately managed.
In the ALRA, the applicant stated that an enhancement to meet the GALL Report "monitoring and trending" program element revises procedures to address the following:
* Add specifications for quarterly trending of particulate contamination analysis results (NMP1 Commitment 21, NMP2 Commitment 19).
In its letter dated November 17, 2005, the applicant added the following to the "monitoring and trending," "parameters monitored and inspected," "preventive actions," and "detection of aging
 
effects" program elements to the program elements affected:
* An enhancement for quarterly trending of water and sediment ("monitoring and trending" and "parameters monitored and inspected," NMP1 Commitment 21 and NMP2
 
Commitment 19).
* An enhancement for periodic opening of the diesel fire pump fuel oil day tank drain
("preventive actions" and "detection of aging effects," NMP1 Commitment 21).
* An enhancement for removal of water if found ("preventive actions" and "detection of aging effects," NMP1 Commitment 21 and NMP2 Commitment 19).
The staff found these enhancements consistent with the GALL Report and therefore acceptable.
These changes to the applicant's program will provide assurance that aging effects will be
 
adequately managed.
3-79 The enhancement for periodic opening of the diesel fire pump fuel oil day tank drain (NMP1) supports the exception taken by the applicant from periodic sampling of the diesel fuel oil day
 
tanks. The staff found the remaining two new enhancements consistent with the GALL Report
 
and, therefore, acceptable. These changes to the applicant's program will provide assurance
 
that aging effects will be adequately managed.
In the ALRA, the applicant also stated that an enhancement to meet the GALL Report "acceptance criteria" program element revises procedures to address the following:
* Ensure acceptance criteria are specified in the implementing procedures for indications of potential degradation. (NMP1 Commitment 21, NMP2 Commitment 19)
In the ALRA program description for the Fuel Oil Chemistry Program the applicant stated that this AMP is to maintain fuel oil quality according to ASTM Standards D975, D1796, D2276 and
 
D4057. This enhancement is to specify acceptance criteria in the implementing procedures. The
 
staff found this information consistent with the GALL Report and therefore acceptable On this
 
basis, the staff found this enhancement acceptable. These changes to the applicant's program
 
will provide assurance that aging effects will be adequately managed.
Operating Experience. In ALRA Section B2.1.18, the applicant explained it has reviewed both industry and plant-specific operating experience relating to the Fuel Oil Chemistry Program.
 
Review of plant-specific operating experience revealed several incidents where contaminants (e.g., water, particulate) were detected through Fuel Oil Chemistry Program examinations.
 
Corrective actions included contamination removal and system/component cleaning. However, there have been no instances of fuel oil system component failures at NMP attributed to
 
contamination.
From review of the applicant's operating experience, the staff found evidence that the fuel oil is sampled periodically and that when acceptanc e limits are exceeded appropriate corrective actions have been taken. The staff found that the applicant's Fuel Oil Chemistry Program is
 
effective in managing the aging effects and aging effects mechanisms of loss of material from
 
the presence of contaminants.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical staff to confirm that the plant-specific operating experience revealed no degradation
 
not bounded by industry experience.
During the initial audit and review (August 9-13, 2004), the staff requested that the applicant provide examples of the tank inspections to verify the effectiveness of the program and to indicate any aging effects and aging effects mechanisms that were identified. The applicant
 
stated in response that the most recent emergency diesel generator (EDG) tank inspections
 
returned normal results. The applicant concluded that initial ultrasound tests of NMP2 fuel oil
 
tanks had found no undue degradation of the tank wall. Ultrasound tests of the NMP1 tank had
 
not yet been implemented. The staff reviewed these reports and other documentation and
 
concludes that no aging of the fuel tanks had been detected.
After review of industry and plant-specific operating experience and discussions with the applicant's technical staff the staff concludes that there is reasonable assurance that the 3-80 applicant's Fuel Oil Chemistry Program will manage adequately the aging effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. The applicant provided its UFSAR supplement for the Fuel Oil Chemistry Program in ALRA, Appendix A, Section A1.1.20 for NMP1 stating that the Fuel Oil
 
Chemistry Program manages loss of material from corrosion that may result from introduction of contaminants into the plant's fuel oil tanks. Program activities include (1) sampling and chemical
 
analysis of the fuel oil inventory at the plant, (2) sampling, testing, and analysis of new fuel oil
 
unloaded at the plant, and (3) cleaning and inspection of fuel oil tanks. The staff reviewed the
 
ALRA and information provided in supplemental letters and determined that the information
 
provides adequate summary descriptions of the program as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Fuel Oil Chemistry Program, the staff determined that those program elements for which the applicant claimed consistency
 
with the GALL Report are consistent with the GALL Report. In addition, the staff reviewed the
 
exceptions and the associated justifications, and determined that the AMP, with the exceptions, is adequate to manage the aging effects for which it is credited. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR supplement
 
for this AMP and concludes that the supplement provides an adequate summary description of
 
the program, as required by 10 CFR 54.21(d).
3.0.3.2.16  Reactor Vessel Surveillance Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.19, the applicant described the Reactor Vessel Surveillance Program (RVSP), stating that this is an
 
existing program that is consistent, with enhancements, with GALL AMP XI.M31, "Reactor Vessel Surveillance." The applicant indicated that enhancements to the RVSP encompass
 
revisions to existing activities that are credited for license renewal to ensure the applicable
 
aging effects are discovered and evaluated. The enhancements will be completed prior to the
 
period of extended operation. The RVSP manages loss of fracture toughness due to neutron
 
irradiation embrittlement in the reactor pressure vessel (RPV) beltline material. Program
 
activities include: (1) periodic withdrawal and te sting of surveillance capsules from each RPV; (2) use of test results and allowable stress loadings for the ferritic RPV materials to determine
 
operating limits; and (3) comparison with a large industry data set to confirm validity of test
 
results. Analysis and testing are based on the requirements of 10 CFR 50, Appendix H, and
 
ASTM Standard E-185.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements to
 
determine whether the AMP, with enhancements, remains adequate to manage the aging
 
effects for which it is credited.
3-81 In ALRA Section B.2.1.19 the applicant described how this AMP will manage irradiation embrittlement of the RV through testing that monitors RV beltline materials. The ALRA states
 
that the RVSP will be enhanced by making it consistent with the BWRVIP integrated
 
surveillance program (ISP) for periods of ext ended operation (currently reviewed by the staff as BWRVIP-116) before NMPNS units enter their period of extended operation. The ALRA further states that the enhanced program will be consistent with GALL AMP XI.M31 described in the
 
GALL Report. For this AMP the GALL Report recommends further evaluation. The staff also
 
reviewed the UFSAR supplement to determine whether it provides an adequate description of
 
the program.
The applicant has implemented the BWRVIP ISP (as documented in the BWRVIP-86-A Report,"BWR Vessel and Internals Project, Updated BWR Integrated Surveillance Program (ISP)
 
Implementation Plan") for the period of the current NMPNS operating licenses. The staff
 
concludes that the BWRVIP ISP in the BWRVIP-86-A Report is acceptable for BWR licensee
 
implementation provided that all participating licensees use one or more compatible neutron
 
fluence methodologies acceptable to the staff for determining surveillance capsule and RV
 
neutron fluences. The staff acceptance of the BWRVIP ISP for the current term is documented
 
in the staff SE dated February 1, 2002, from Bill Bateman of the NRC to Carl Terry, BWRVIP
 
Chairman. The BWRVIP-116 report provides guidelines for an ISP to monitor neutron irradiation
 
embrittlement of the RV beltline materials for all United States (US) BWR power plants for their
 
original 40-year operating terms and their license renewal periods.
The staff's review of the original LRA Section B2.1.19 identified an area in which additional information was necessary to complete the review of the applicant's program elements. The
 
applicant responded to the staff's RAI as discussed below.
In RAI B.2.1.19-1 by letter dated January 13, 2005, the staff requested that the applicant make a commitment to implement the BWRVIP-116 ISP currently under review by the staff or to submit a plant-specific surveillance program fo r each NMPNS unit two years before it enters the extended period of operation.
In its response by letter dated February 14, 2005, the applicant indicated that it will implement either BWRVIP-116 as approved by the staff or if the ISP is not approved two years prior to the NMPNS units' period of extended operation a pl ant-specific surveillance program will be submitted to the NRC. In this response the applicant also stated that it will revise the original
 
LRA Sections A1.1.32, A2.1.32, and B2.1.19 as shown in the staff's evaluation of the USAR
 
supplement. The staff noted that the applicant had made a formal commitment to incorporate
 
either BWRVIP-116 as approved by the staff or a plant-specific surveillance program for each of the NMPNS units to satisfy the requirements of 10 CFR Part 50, Appendix H (NMP1
 
Commitment 22 and NMP2 Commitment 20).
The applicant stated that the future withdrawal and testing of the NMP1 and NMP2 surveillance capsules will be deferred permanently because NMP1 and NMP2 are not host reactors within
 
the BWRVIP-116 ISP. The applicant further stated that through participation in the BWRVIP ISP
 
the RVSP will be adjusted to account for industry experience and research and that as
 
additional operating experience is obtained lessons learned will be used to adjust this program
 
as needed. Therefore, the staff will require the following license condition:
3-82 Implementation of the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance
 
Program (ISP) as the method to demonstrate compliance with the requirements
 
of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule
 
withdrawal schedule must be submitted for NRC staff review and approval. Any
 
changes to the BWRVIP ISP capsule withdrawal schedule which affects the time
 
of withdrawal of any surveillance capsules must be incorporated into the
 
licensing basis. If any surveillance capsules are removed without the intent to
 
test them, these capsules must be stored in manner which maintains them in a
 
condition which would support re-insertion into the reactor pressure vessel, if
 
necessary.
The staff found the applicant has demonstrated that the effects of aging from loss of fracture toughness of the RV beltline materials will be adequately managed with the enhancements so
 
that the intended functions will be maintained consistently with the CLB for the period of
 
extended operation as required by 10 CFR 54.21(a)(3).
Operating Experience. In ALRA Section B2.1.19, the applicant indicated that NMPNS has successfully implemented a plant-specific RVSP that is consistent with Regulatory Guide 1.99, Revision 2, 10 CFR 50, Appendix H, and ASTM Standard E-185. Three surveillance capsules
 
that were originally installed in the NMP1 RV have been removed and tested with satisfactory
 
results. One of the three surveillance capsules that were originally installed in the NMP2 RV has
 
been removed and tested. Data from LaSalle, Units 1 and 2 and Columbia Generating Station
 
have been used to supplement the NMP2 surveillance data.
The applicant stated that under the ISP, neither NMP1 or NMP2 is identified as a host plant; the representative materials for the limiting RV plate and weld materials, and their associated
 
withdrawal schedules are identified in the BWRVIP-116 report. Thus, future withdrawal and
 
testing of the NMP1 and NMP2 surveill ance capsules will be permanently deferred.
The applicant also stated that through participation in the BWRVIP ISP, the RVSP will be adjusted to account for industry experience and research. The applicant stated that with
 
additional operating experience lessons learned will be used to adjust this program as needed.
The applicant maintains that the RVSP has been effective in managing loss of fracture toughness in RV beltline materials.
UFSAR and USAR Supplements. In RAI B2.1.19-1 the staff further requested that the applicant state, in the UFSAR and USAR its commitment regarding the implementation of BWRVIP-116
 
and in its response to RAI B.2.1.19-1 by letter dated February 14, 2005, the applicant stated
 
that it will revise the ALRA Sections A1.1.32 and A2.1.32, to include the following:
The reactor vessel surveillance program is an existing program that manages loss of fracture toughness due to neutron irradiation embrittlement in the reactor
 
pressure vessel beltline material. Program activities include (1) periodic
 
withdrawal and testing of surveillance capsules from the RPV; (2) use of test
 
results and allowable stress loadings from the ferritic RPV materials to determine
 
operating limits; and (3) comparison with a large industry data set to confirm
 
validity of test results. Analysis and testing are based on the requirements of 3-83 10 CFR 50, Appendix H, and ASTM Standard E-185. NMPNS commits to implement the Integrated Surveillance Program (ISP) described in BWRVIP-116 (if approved by the NRC staff). When the NRC issues a final safety evaluation for
 
BWRVIP-116, NMPNS will address any open items and complete the SER
 
Action Items. Should BWRVIP-116 not be approved by the NRC, a plant specific
 
reactor vessel surveillance program will be submitted to the NRC two years prior to commencement of the period of extended operation.
Enhancements to the RVSP include the following revisions to existing activities credited for license renewal:
Incorporate the requirements and elements of the ISP, as documented in BWRVIP-116 and approved by NRC, or an NRC-approved plant-specific
 
program, into the reactor vessel surveillance program, and include a requirement
 
that if NMPNS surveillance capsules are tested, the tested specimens will be
 
stored in lieu of optional disposal. When the NRC issues a final safety evaluation
 
report for BWRVIP-116, NMPNS will address any open items and complete the
 
SER Action items. Should BWRVIP-116 not be approved by the NRC, a plant
 
specific reactor vessel surveillance program will be submitted to the NRC two
 
years prior to commencement of the period of extended operation.Project analyses of upper shelf energy and pressure-temperature limits to 60 yearsusing methods prescribed by Regulatory Guide 1.99, Revision 2, and include the
 
applicable bounds of the data, such as operating and neutron fluence.
Enhancements will be completed prior to the period of extended operation.
This information has been incorporated into the ALRA. The staff reviewed the applicant's proposed revision to ALRA Sections A1.1.32 and A2.1.32 of the UFSAR and USAR
 
supplements and determined that the applicant has committed to implement an approved
 
plant-specific RPV surveillance program or the most recent staff-approved version of the
 
BWRVIP ISP to comply with the requirements of 10 CFR Part 50, Appendix H. Therefore, the
 
staff's concern described in RAI B.2.1.19-1 is resolved.
The staff reviewed the ALRA and information provided in supplemental letters and determined that the information provides adequate summary descriptions of the program as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's RVSP and RAI response, the staff determined that those program elements for which the applicant claimed consistency with
 
the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR and USAR
 
supplements for this AMP and concludes that it provides an adequate summary description of
 
the program, as required by 10 CFR 54.21(d).
3-843.0.3.2.17  ASME Section XI Inservice Inspection (Subsection IWE) Program Summary of Technical Information in the Amended Application. In ALRA Section B2.1.23, theapplicant described the ASME Section XI Inservice Inspection (Subsection IWE) Program, stating that this is an existing program that is consistent, with an exception and an enhancement, with GALL AMP XI.S1, "ASME Section XI, Subsection IWE." The ASME Section XI Inservice Inspection (Subsection IWE) Program (referred to herein as the IWE ISI
 
Program) manages aging effects due to: (1) corrosion of carbon steel components comprising
 
the NMP1 and NMP2 containment pressure boundaries and (2) degradation of NMP1 and
 
NMP2 containment pressure-retaining polymers.
Program activities include visual examination, with limited surface or volumetric examinat ions when augmented examination is required. The IWE ISI Program is based on the 1998 edition of the ASME Boiler and Pressure Vessel Code, Section XI (Subsection IWE) for containment inservice inspection (ISI) with plant-specific
 
exceptions approved by the staff.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancement and the
 
associated justifications to determine whether the AMP, with the exceptions and enhancement, remains adequate to manage the aging effects for which it is credited.
As documented in the Audit and Review Report, the staff asked the applicant to explain whythere is an identified enhancement in the ASME Section XI ISI (SubSection IWE) Program with
 
no affected program elements listed. The applicant stated that the reason no elements are
 
identified is that the enhancement shown is not required to ensure consistency with the GALL
 
Report but adopted as a function of the applicant's response to a staff request early in the
 
application review period. To avoid confusion with the specialized definition of "enhancement"
 
consistent with the GALL Report changes will be incorporated into the ALRA.
In its supplemental letter dated December 1, 2005, the applicant stated that the first sentence in the second paragraph in ALRA Sections A1.1.2 and A2.1.2 changes the word "enhanced" to
 
"improved" with the following sentence added at the end of this paragraph: "This improvement is
 
not required for consistency with the GALL but is an activity NMP is adopting to ensure consistency with industry practice." The same change is made to ALRA Section. In the ASMESection XI ISI (Subsection IWE) Program under the enhancement paragraph a new first
 
paragraph of "None" is added. The following sentence is added to the beginning of the second
 
paragraph: "The following improvement is not required for consistency with the GALL Report but
 
is an activity NMP is adopting to ensure consist ency with industry practice." The last sentence of this paragraph is replaced with the following sentence: "This improvement will be
 
implemented prior to entry into the period of extended operation." Also the phrase "and requires
 
enhancements to be consistent with others" is deleted from the GALL Report consistency Section of the ASME Section XI ISI (Subsection IWE) Program.
The staff found the applicant's response acceptable. With the clarification statements made bythe applicant no enhancement is required to make the applicant's ASME Section XI ISI (Subsection IWE) Program consistent with the GALL Report.The staff reviewed those portions of the ASME Section XI ISI (Subsection IWE) Program forwhich the applicant claimed consistency with GALL AMP XI.S1 and found them consistent with 3-85this GALL Report AMP. The staff found the applicant's ASME Section XI ISI (Subsection IWE)Program acceptable because it conforms to the recommended GALL AMP XI.S1 with an
 
exception.In the ALRA, the applicant stated that its ASME Section XI ISI (Subsection IWE) Program isconsistent with GALL AMP XI.S1 with exceptions. The ASME Section XI ISI (Subsection IWE)
 
Program takes exceptions to the GALL Report "
parameters monitored/inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements. The
 
GALL Report program elements identify both the ASME 1992 Edition with the 1992 Addenda
 
and the 1995 Edition with the 1996 Addenda as applicable to the NMP1 and NMP2 Application
 
for Renewed Operating License Appendix B - Aging Management Program ASME SectionXI-IWE as approved in 10 CFR 50.55a. The NMP IWE ISI Program complies with the ASME Section XI 1998 Edition with no Addenda.
In the ALRA, the applicant further stated that the GALL Report program description for this AMP identifies both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda as the applicable editions for the NMP1 and NMP2 ASME Section XI ISI (Subsection
 
IWE) Program as approved in 10 CFR 50.55a. The applicant's IWE ISI Program complies with ASME Section XI 1998 Edition with no Addenda. Although differences exist between code editions the applicant's IWE ISI Program complies with an edition of Section XI approved by the
 
staff for use at NMP. Implementation of guidance from this later code edition meets the
 
recommendations of the GALL Report.
As documented in the Audit and Review Report, the staff noted that the staff previously found this exception acceptable because the NMP code of record is an ASME Code version later than
 
that cited by the GALL Report. The use of the 1998 Edition of the ASME Code was found
 
acceptable in a letter from the US Nuclear Regulatory Commission to Niagara Mohawk Power
 
Corporation dated August 17, 2000, with the subject "Nine Mile Point Nuclear Station Unit Nos.
 
1 and 2 - Relief From the Requirements of 10 CFR 50.55a Related to Containment Inspection (TAC Nos. MA7116, MA7117, and MA7118)." The staff also noted that under the applicant's ASME Code of record for ASME Section XI ISI (Subsection IWE) a 10-year inspection interval is valid under the CLB. At present an ASME Section XI ISI (Subsection IWE) Program is approved
 
for use on an ASME Code 10-year ISI interval spec ific basis. However, the applicant will have torequest approval to use the ASME Section XI ISI (Subsection IWE) Program for the specific
 
intervals during the period of extended operation under 10 CFR 50.55a 12 months prior to each interval. Therefore, the staff determined that the ASME Section XI Code Edition as referenced in
 
10 CFR 50.55a, for which the applicant will request approval 12 months prior to each inspection
 
interval, is acceptable for the period of extended operation and found this exception acceptable.
Operating Experience. In ALRA Section B2.1.23, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the IWE ISI Program. Review of
 
plant-specific operating experience revealed few discrepancies and no age-related equipment
 
failures. Deficiencies discovered by recent IWE ISI Program examinations included damage to the NMP1 torus equipment hatch, damage to the NMP1 drywell dome manway hatch sealing surface, minor corrosion on the NMP1 drywell dome sealing surface, and minor corrosion on the
 
NMP2 drywell liner. These indications were corrected for NMP1 and NMP2.
As documented in the Audit and Review Report, the staff also reviewed the summary of specificoperating experience for the applicant's ASME Section XI ISI (Subsection IWE) Program. The 3-86 review indicated that the program is effective in identifying age-related degradation, implementing repairs, and maintaining the integrity of the containment pressure boundaries and
 
NMP1 and NMP2 containment pressure-retaining polymers.
During the initial audit and review (August 9-13, 2004) NMP1 plant maintenance records revealed that there have been only a few CRs written and no age-related component failures
 
following IWE inspections since the inception of the program with deficiencies limited to damage
 
to the torus equipment hatch, damage to the dr ywell dome manway hatch sealing surface, corrosion of the drywell liner, and minor damage or corrosion on the drywell dome sealing
 
surface. None of these deficiencies resulted in loss of intended function from age-related
 
degradation. These records provide assurance that containment pressure boundary
 
degradation has not occurred since the inception of the program. Subsequent to the onsite audit
 
and review of NMP ALRA, the staff also reviewed the applicant's Inservice Inspection Owner
 
Activity Report, dated July 23, 2003. In this report, the applicant has stated that, for NMP1, corrosion was identified over the entire 360 degree circumference of the drywell interior surface
 
of the liner plate at the 225 foot elevation. The applicant further stated in the report that (1) a
 
subsequent detailed (D-VT) visual examination (VT-1) was performed and that (2) no
 
unacceptable degradation in the visible areas of the drywell liner was found and that (3) no
 
immediate corrective action was taken. The staff has asked the applicant to provide further
 
discussion to address the staff concern regarding the loss of material due to corrosion of the
 
NMP1 drywell. This was designated as Open Item (OI) 3.0.3.2.17-1.
On March 27, 2006, the applicant met with the staff to discuss the issue identified in OI 3.0.3.2.17-1, and by letter dated April 4, 2006, the applicant provided its response to
 
OI 3.0.3.2.17-1. In its attachment to the letter, the applicant supplemented the following
 
background information related to corrosion of NMP1 drywell.
During the 2003 NMP1 refueling outage, a general visual examination of 100 percent of the accessible portions of the interior surface of the drywell shell was performed. Six localized
 
areas, coinciding with the area coolers, were observed to have significant corrosion. In accordance with ASME Section XI Subsection IWE, a detailed visual examination (VT-1) was
 
performed of the six localized areas and characterized the corrosion as 'major' (i.e., greater
 
than 5 percent of the base metal was judged to be lost). A condition report was generated in
 
accordance with the corrective action program and a rigorous engineering evaluation was
 
performed.
To ascertain the actual thickness of the drywell shell at these locations, the four most severe locations were chosen by the IWE responsible engineer to have volumetric (UT) examinations
 
performed. Four individual UT measurements were taken by cleaning the corrosion from the
 
base metal, conducting a continuous scan, and recording the lowest value. The results of the
 
UT examinations ranged from 1.106" to 1.131". The IWE Responsible Engineer compared these
 
results against the minimum design value of 1.049" and concluded that the drywell shell was
 
acceptable for continued service.
Subsequent to the evaluations performed during the 2003 refueling outage, an engineering calculation was performed that projected the time necessary to reach minimum design thickness
 
for the drywell shell. Using the volumetric results (min. 1.106") and minimum design value
 
(1.049"), the available margin was determined to be 57 mils. Using the originally assumed
 
corrosion allowance (62.5 mils over 40 years), it was calculated that it would take 36 years from 3-87 2003 to reach the minimum design thickness. This projects out to be the year 2039, which is 10 years beyond the end of the period of extended operation (2029).
Another method, using a newer approved corrosion rate, was also used to project the year that minimum wall thickness would be reached for the drywell shell. NMP uses a corrosion rate of
 
1.26 mils/yr in the Torus Corrosion Monitoring Program to evaluate volumetric examination results. This value is documented in a 1994 NRC safety evaluation report. The use of this
 
corrosion rate is appropriate since the material of the drywell shell is essentially the same as the
 
material for the torus shell for the purposes of corrosion resistance. The drywell shell is made of
 
ASTM-212, Gr. B carbon steel whereas the torus shell is made of ASTM-201, Gr. B. The
 
environment in the torus is also the same as, or more severe than, the drywell environment. The
 
torus is approximately half full of demineralized water and the remainder is a nitrogen inerted
 
atmosphere. The drywell is entirely a nitrogen inerted atmosphere. Therefore, since the
 
materials are essentially the same and the environments are also, it is appropriate to use an
 
approved corrosion rate for the torus for the drywell shell. Performing the calculation, 57 mils of
 
margin divided by 1.26 mils/yr. corrosion rate, yields 45 years until the minimum design
 
thickness of the drywell shell is reached (19 years beyond the end of the period of extended operation).
Based on the above, the applicant concluded that the NMP1 drywell shell could perform its intended function following the 2003 refueling outage and beyond the period of extended
 
operation. However, the applicant had also concluded that continued monitoring, in addition to the ASME Section XI Subsection IWE Program, of the drywell shell was necessary. The
 
applicant formalized the continuing monitoring program as "Drywell Supplemental Inspection Program." The following is the staff evaluation of the AMP program elements.  (1)Scope of Program - The scope of the NMP1 Drywell Supplemental Inspection Program includes the areas characterized as having major corrosion (rust) on the NMP1 drywell
 
shell in the NMP Owner Activity Report dated July 23, 2003. These six areas are
 
localized and located near and underneath the drywell area coolers on the 225'
 
elevation. This program provides aging managem ent activities to the six localized areasin addition to the activities required by the ASME Section XI Inservice Inspection (Subsection IWE) Program.
Based on the information provided in the applicant's background information, the staff found the scope of the program, as described herein, acceptable.    (2)Preventive Actions - There are no predetermined preventive actions associated with this program. However, NMP engineering may require preventive actions in the future as
 
part of the evaluation of examination results.
If the future examinations dictate that preventive actions (e.g., appropriate coating), are needed, the applicant will consider such actions. The staff agrees with the applicant's
 
assessment of this element.  (3)Parameters Monitored or Inspected - The six localized areas of the carbon steel drywell shell are examined for evidence of loss of material due to corrosion.
3-88 In response to the staff's query about the examination of the shell at the junction of the concrete floor and the drywell shell, which has been found as a site for corrosion at other
 
plants, the applicant asserted that the examination of this joint is part of the IWE
 
Inspection Program (i.e. AMP B.2.1.33). The staff found the applicant's response and
 
the program element as described in this supplementary AMP acceptable, as this
 
program is only applicable to the corrosion degradation found during its 2003 inspection.  (4)Detection of Aging Effects - Loss of material will be detected by performing a volumetric (ultrasonic thickness measurement) exami nation. This exam will be conducted during the 2007 refueling outage. Future performances will be based on the results obtained, as described under the Corrective Actions attribute.
The staff found the actions to be taken by the applicant, as shown in the table, commensurate with the as found corrosion rate, appropriate and acceptable.  (5)Monitoring and Trending - The condition of the localized area wall thickness of the drywell shell is monitored by virtue of the volumetric exam. Trending of the wall
 
thickness results will be performed to determine a rate of material loss and to project the
 
application of that rate to the drywell shell thickness value until the end of the period of
 
extended operation.
The staff found the applicant's program regarding monitoring and trending of the as found corrosion appropriate and acceptable.  (6)Acceptance Criteria - The acceptance criteria will be based upon the calculated corrosion rate and the projected wall thickness at the end of the period of extended
 
operation. The corrosion rate criteria are based on maintaining a wall thickness of
 
greater than the minimum design value. The following table correlates corrosion rates, projected wall thickness at the end of the period of extended operation, and actions that will be taken above those actions required by the ASME Section XI Subsection IWE
 
requirements. The values in the tables, except the corrosion rates, are calculated using
 
the lowest wall thickness reading (1.106") obtained during the 2003 refueling outage. For
 
wall thicknesses greater than 1.106" in 2003, these values are conservative.
Corrosion Rate(mils/year)Wall Thickness @
End of PEO (inches)Margin to Design (mils)Years to Reach Minimum DesignThicknessActions Beyond IWE Requirements< 0.30> 1.098> 49> 190None0.30 - 0.611.090- 1.09841 - 49 93 - 190Confirming UTevery 10 years0.62 - 1.251.074- 1.09025-4145 - 93Confirming UTevery 6 years1.26 - 2.21.049 - 1.0740 - 2526 - 45Confirming UTevery 4 years and implement a.mitigative strategy Corrosion Rate(mils/year)Wall Thickness @
End of PEO (inches)Margin to Design (mils)Years to Reach Minimum DesignThicknessActions Beyond IWE Requirements 3-89> 2.2< 1.049 0<2 6Confirming UTevery 2 years and implement a mitigative strategy Based on the history of corrosion found in NMP1 torus in the late 1980s, the applicant had elicited a corrosion rate of 1.26 mils/year. In the drywell, at the time of detecting
 
corrosion, i.e., in 2003, the applicant could not predict corrosion rates. The table above
 
envelopes corrosion rates lesser than the torus corrosion rate, and the last row depicts
 
the potential worst case. Therefore, the staff found actions required under various
 
corrosion rates appropriate and acceptable.  (7)Corrective Actions - Actions to be implemented beyond those required by the ASMESection XI Subsection IWE Program are delineated in the table above. A mitigative
 
strategy could include application of a protective coating, repair or replacement of
 
affected sections, or other actions deemed appropriate by the NMP IWE responsible
 
engineer. The Corrective Action Program meets the requirements of 10 CFR Part 50, Appendix B.
As indicated in the staff evaluation of element "Acceptance Criteria," the mitigative strategy, and possible remedial actions proposed in this element are appropriate and
 
acceptable.    (8)Confirmation Process - When acceptance criteria are not met, corrective actions are determined in accordance with the Corrective Action Program. Confirmation that the
 
corrective actions have been completed and are effective will be documented in
 
accordance with the requirements of 10 CFR Part 50, Appendix B.
The element meets the requirement of 10 CFR Part 50, Appendix B.  (9)Administrative Controls - The above stated actions to manage the corrosion of six localized areas on the NMP1 drywell shell will be controlled and documented in the NMP ASME Section XI Subsection IWE Program Plan.
The method of keeping control of the activities performed under this AMP is appropriate and acceptable. (10)Operating Experience - NMPNS has an ex isting effective program that continuously reviews internal and external operating experience to determine its applicability and
 
adjusts inspection plans accordingly. The operating experience program will continue to
 
be used to improve the NMP1 Drywe ll Supplemental Inspection Program.
The applicant's commitment to keep track of the external operating experience, and modifying the AMP, as necessary, is appropriate and acceptable.
3-90 Based on the review of the applicant's supplemental aging management program and the applicant's IWE Inspection Program (i.e., AMP B.2.1.33) for monitoring the NMP1 drywell
 
corrosion, the staff concludes that there is reasonable assurance that is there is reasonable
 
assurance that the NMP1 containment drywell integrity will be maintained during the period of
 
extended operation. Therefore, Open OI 3.0.3.2.17-1 is now considered closed.
In addition during the initial audit and review NMP2 plant maintenance records revealed that there has been only one CR written and no age-related component failures following IWE
 
inspections since the inception of the program. In 2000 minor corrosion was discovered and
 
removed from the drywell liner with no loss of integrity. These records provided assurance that
 
containment pressure boundary degradation had not occurred since the inception of the
 
program.The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel the staff concludes that there is reasonable assurance that the applicant's ASME Section XI ISI (Subsection IWE) Program will manage adequately the aging
 
effects and aging effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. The applicant provided its UFSAR supplement for the ASMESection XI Inservice Inspection (Subsection IWE) Program in ALRA Appendix A, Section A1.1.2 for NMP1 stating that the ASME Section XI Inservice Inspection (Subsection IWE) Program (referred to herein as the IWE Inservice Inspection Program) manages aging effects and aging
 
effects mechanisms due to (1) corrosion of carbon steel components comprising the
 
containment pressure boundary and (2) degradation of containment pressure-retaining
 
polymers. Program activities include visual ex aminations with limited surface or volumetric examinations when augmented examination is r equired. The IWE Inservice Inspection Programis based on the 1998 Edition of the ASME Boiler and Pressure Vessel Code Section XI (Subsection IWE) for containment inservice ins pection with plant-specific exceptions to theevaluation in the GALL Report (which covers ASME Section XI requirements from both the 1992
 
Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda) approved by the staff. The NMP1 ASME Section XI Inservice Inspection (Subsection IWE) Program will be
 
enhanced to add an augmented VT-1 visual examination of the NMP1 containment penetration
 
bellows. This inspection will be performed using enhanced techniques qualified for detecting
 
SCC per NUREG-1611, "Aging Management of Nuclear Power Plant Containments for License
 
Renewal," Table 2, Item 12.In addition the applicant provided its USAR supplement for the ASME Section XI ISI (Subsection IWE) Program in ALRA Appendix A Section A2.1.2 for NMP2 stating that the
 
program manages aging effects and aging effects mechanisms from (1) corrosion of carbon
 
steel components comprising the containment pressure boundary and (2) degradation of
 
containment pressure-retaining polymers. Program activities include visual examinations with limited surface or volumetric examinations when augmented examination is required. The IWE ISI Program is based on the 1998 Edition of the ASME Boiler and Pressure Vessel Code, Section XI (Subsection IWE) for containment ISI with plant-specific exceptions to the evaluation in the GALL Report (which covers ASME Section XI requirements from both the 1992 Edition 3-91 with the 1992 Addenda and the 1995 Edition with the 1996 Addenda) approved by the staff. TheNMP2 ASME Section XI ISI (Subsection IWE) Program will be enhanced to add an augmented
 
VT-1 visual examination of the NMP2 containment penetration bellows. This inspection will be
 
performed using enhanced techniques qualified for detecting SCC per NUREG-1611, Table 2, Item 12. As documented in the Audit and Review Report, the staff asked the applicant to explain whythere is an enhancement in ALRA Section B2.1.23 for its ASME Section XI ISI (Subsection IWE)
 
Program with no affected program elements listed. The applicant stated that there are no
 
elements identified because the enhancement shown is not required to ensure consistency with
 
the GALL Report has been adopted in response to a staff request early in the application review
 
period. To avoid confusion with the specialized definition of "enhancement" consistent with the
 
GALL Report changes will be incorporated into the ALRA.
In its letter dated December 1, 2005, the applicant stated that the first sentence in the second paragraph in ALRA Section A1.1.2 changes the word "enhanced" to "improved" with the
 
following sentence added at the end of this paragraph: "This improvement is not required for
 
consistency with the GALL but is an activity NMP is adopting to ensure consistency with industry practice." The same change is made to ALRA Section A2.1.2.
The staff found the applicant's response acceptable. With the clarification made by the applicantthere is no enhancement required to make the applicant's ASME Section XI ISI (Subsection
 
IWE) Program consistent with the GALL Report.
The staff reviewed these sections and information In the ALRA and determined that the information in the supplements provide adequat e summary descriptions of the program as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's ASME Section XI Inservice Inspection (Subsection IWE) Program, the staff determined that those program elements for
 
which the applicant claimed consistency with the GALL Report are consistent with the GALL
 
Report. In addition the staff reviewed the exceptions and the associated justifications, and
 
determined that the AMP, with the exceptions, is adequate to manage the aging effects for
 
which it is credited. Also, the staff has reviewed the enhancement and confirmed that the
 
implementation of the enhancement prior to the period of extended operation would result in the
 
existing AMP being consistent with the GALL Report AMP to which it was compared.The staff
 
concludes that there is reasonable assurance that the applicant has demonstrated that the
 
effects of aging will be adequately managed so that the intended functions 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 UFSAR and USAR supplements for this AMP
 
and concludes that it provides an adequate summary description of the program, as required by
 
10 CFR 54.21(d).3.0.3.2.18  ASME Section XI Inservice Inspection (Subsection IWL) Program (NMP2 Only)
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.24, theapplicant described the ASME Section XI Inservice Inspection (Subsection IWL) Program for
 
NMP2, stating that this is an existing program that is consistent, with exception, with GALL AMP XI.S2, "ASME Section XI, Subsection IWL." The ASME Section XI Inservice Inspection 3-92 (Subsection IWL) Program (referred to herein as the IWL ISI Program) manages aging of concrete in the NMP2 containment wall, base mat, and drywell floor. Program activities include
 
general visual examination of all accessible concrete surface areas, with provisions for detailed
 
visual examination when deterioration and distress of suspect areas is detected. The IWL ISI
 
Program is based on the 1998 edition of the ASME Boiler and Pressure Vessel Code, Section XI (Subsection IWL) for containment inse rvice inspection with plant-specific exceptions approved by the NRC. This program applies to concrete elements of BWR Mark II and III
 
containment structures. NMP1 is a BWR Mark I containment, therefore, this program does not
 
apply to NMP1.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exception and the
 
associated justification to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.
As documented in the Audit and Review Report, the staff asked the applicant to explain why in NMP AMP B2.1.24 under the consistency paragraph "IWE" is shown in the first sentence
 
instead of "IWL." The applicant responded that this typographical error should have been "IWL,"
 
not "IWE." In its letter dated December 1, 2005, the applicant stated that in NMP AMP B2.1.24
 
under the consistency paragraph the typographical error "IWE" has been changed to "IWL."
The staff found the applicant's response acceptable. With the correction of "IWE" to "IWL" thesentence agrees with the NMP AMP described in the ASME Section XI Inservice Inspection (Subsection IWL) Program.The staff reviewed those portions of the ASME Section XI ISI (Subsection IWL) Program (Unit 2only) for which the applicant claimed consistency with GALL AMP XI.S2 and found them consistent. The staff found the applicant's ASME Section XI ISI (Subsection IWL) Program (Unit 2 only) acceptable because it conforms to the recommended GALL AMP XI.S2 with
 
exception.In the ALRA, the applicant stated that its ASME Section XI ISI (Subsection IWL) Program takes exception to the GALL Report "parameters monitored/inspected," "detection of aging effects,"
 
"monitoring and trending," and "acceptance criteria" program elements. The GALL Report
 
program elements identify both the ASME 1992 Edition with the 1992 Addenda and the 1995
 
Edition with the 1996 Addenda as applicable editions for the NMP2 Application for Renewed Operating License Appendix B - Aging Management Program ASME Section XI-IWL as approved in 10 CFR 50.55a. The NMP IWL ISI Program complies with the ASME Section XI
 
1998 Edition with no addenda.
The applicant stated in the ALRA that the GALL Report program description for this AMP identifies both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda as applicable editions for its ASME Section XI ISI (Subsection IWL) Program as
 
approved in 10 CFR 50.55a. The applicant's IWL ISI Program complies with the ASME Section XI 1998 Edition with no addenda. Although differences exist between code editions the applicant's IWL ISI Program complies with an edition of Section XI approved by the NRC for use
 
at NMP. Implementation according to this later code edition meets the recommendation of the
 
GALL Report description.
3-93 As documented in the Audit and Review Report, the staff previously found this exception acceptable because the code of record for NMP2 is an ASME Code version later than that cited
 
by the GALL Report. The use of the 1998 Edition of the ASME Code was found acceptable in a
 
letter from the US Nuclear Regulatory Commission to Niagara Mohawk Power Corporation
 
dated August 17, 2000, with the subject "Nine Mile Point Nuclear Station, Unit Nos. 1 and 2 -
 
Relief From the Requirements of 10 CFR 50.55a Related to Containment Inspection (TAC Nos.
 
MA7116, MA7117, and MA7118)." The staff also noted that under the applicant's ASME code of record for ASME Section XI ISI (Subsection IWL) a 10-year inspection interval is valid under the CLB. At present an ASME Section XI ISI (Subsection IWL) program is approved for use on an
 
ASME Code 10-year ISI interval-specific basis. However, the applicant will have to requestapproval to use the ASME Section XI ISI (Subsection IWL) program for the specific intervals
 
during the period of extended operation under 10 CFR 50.55a 12 months prior to each interval.
Therefore, the staff determined that the ASME Section XI Code Edition as referenced in
 
10 CFR 50.55a, for which the applicant will request approval 12 months prior to each inspection
 
interval is acceptable for the period of extended operation and found this exception acceptable.
Operating Experience. In ALRA Section B2.1.24, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the IWL ISI Program. Review of
 
plant-specific operating experience revealed no CRs written as a result of IWL ISI Program
 
inspections since program inception.
During the initial audit and review, (August 9-13, 2004) the staff reviewed operating experiencefor the applicant's ASME Section XI ISI (Subsection IWL) Program (Unit 2 only). The review
 
indicated that the applicant's program is effective in maintaining the integrity of the containment
 
concrete with processes in place to identify age-related degradation and implement repairs.
As documented in the Audit and Review Report, the staff also reviewed the summary of specificoperating experience for the applicant's ASME Section XI ISI (Subsection IWL) Program. The
 
review indicated that there have been no CRs written following IWL inspections since the
 
inception of the program and provided assurance that containment degradation has not
 
occurred since the inception of the program.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel the staff concludes that there is reasonable assurance that the applicant's ASME Section XI ISI (Subsecti on IWL) Program (Unit 2 Only) will manage adequately the aging effects and aging effects mechanisms identified in the ALRA for which this
 
AMP is credited.
USAR Supplement. In ALRA Section A2.1.4, the applicant provided the USAR supplement forthe ASME Section XI Inservice Inspection (Subsection IWL) Program. The staff reviewed this
 
section and determined that the information in the USAR supplement provides an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's ASME Section XI Inservice Inspection (Subsection IWL) Program, the staff determined that those program elements for 3-94 which the applicant claimed consistency with the GALL Report are consistent with the GALL Report. In addition the staff reviewed the exception and the associated justification, and
 
determined that the AMP, with the exception, 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 intended functions 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 USAR 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 Inservice Inspection (Subsection IWF) Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.25, theapplicant described the ASME Section XI Inservice Inspection (Subsection IWF) Program, stating that this is an existing program that is consistent, with exception, with GALL AMP XI.S3, "ASME Section XI, Subsection IWF." The ASME Section XI Inservice Inspection (Subsection IWF) Program (referred to herein as the IWF ISI Program) manages aging of
 
carbon steel component and piping supports, including ASME Class MC supports, due to
 
general corrosion and wear. Program activities include visual examination to determine the
 
general mechanical and structural condition of components and their supports. The IWF
 
Inservice Inspection Program is based on the 1989 edition of the ASME Boiler and Pressure Vessel Code, Section XI (Subsection IWF) for inservice inspection of supports and implements
 
the alternate examination requirements of ASME Code Case N-491-1.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exception and the
 
associated justification to determine whether the AMP, with the exception, remains adequate to
 
manage the aging effects for which it is credited.The staff reviewed those portions of the ASME Section XI ISI (Subsection IWF) Program forwhich the applicant claimed consistency with GALL AMP XI.S3 and found them consistent. The staff found the applicant's ASME Section XI ISI (Subsection IWF) Program acceptable because it conforms to the recommended GALL AMP XI.S3 with exception.In the ALRA, the applicant stated that its ASME Section XI ISI (Subsection IWF) Program isconsistent with GALL AMP XI.S3 with exception to the GALL Report "scope of program,"
 
"parameters monitored/inspected," and "acc eptance criteria" program elements. The GALL Report program elements identify the ASME 1989 Edition through the 1995 Edition and
 
Addenda through the 1996 Addenda as applicable to the NMP1 and NMP2 Application for
 
Renewed Operating License Appendix B - Aging Management Program ASME Section XI-IWFas approved in 10 CFR 50.55a. The NMP IWF ISI Program complies with the ASME Section XI
 
1989 Edition with no addenda.
In the ALRA, the applicant stated that the NRC previously found this exception acceptable because the code of record for NMP IWF inspections is the 1989 version of the ASME Code
 
found acceptable in two letters from the US Nuclear Regulatory Commission to Niagara
 
Mohawk Power Corporation dated October 5, 2000 and March 3, 2000. The subject of the
 
October 5, 2000, letter was "Nine Mile Point Nuclear Station, Unit No. 1 - Reliefs for the Third
 
10-Year Inservice Inspection Program Plan, Revision 1 (TAC No. MA7129)." The subject of the 3-95 March 3, 2000, letter was "Nine Mile Point Nuclear Station, Unit No. 2 - Reliefs for the Second 10-Year Inservice Inspection Program Plan, Revision 1 (TAC No. MA6273)." The staff also noted that under the applicant's ASME code of record for ASME Section XI ISI (Subsection IWF) a 10-year inspection interval is valid under the CLB. At present an ASME Section XI ISI (Subsection IWF) Program is approved for use on an ASME Code 10-year ISI interval specificbasis. However, the applicant will have to request approval to use the ASME Section XI ISI (Subsection IWF) Program for the specific intervals during the period of extended operation
 
under 10 CFR 50.55a 12 months prior to each interval. Therefore, the staff determined that the ASME Section XI Code Edition as referenced in 10 CFR 50.55a, for which the applicant will
 
request approval 12 months prior to each inspection interval is acceptable for the period of
 
extended operation and found this exception acceptable.
As documented in the Audit and Review Report, the staff noted that the GALL Report AMP program identifies the ASME 1989 Edition through the 1995 Edition and addenda through the 1996 Addenda as applicable to applicant's ASME Section XI ISI (Subsection IWF) Program as
 
approved in 10 CFR 50.55a. The applicant's IWF ISI Program complies with the ASME Section XI 1989 Edition with no addenda. Although differences exist between code editions the applicant's IWF ISI Program complies with an edition of Section XI approved by the staff for use
 
at NMP. Implementation according to this code edition meets the recommendation of the GALL
 
Report description.
Operating Experience. In ALRA Section B2.1.25, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the IWF Inservice Inspection
 
Program. Review of plant-specific operating experience revealed no age-related failures of any
 
supports within the scope of the IWF Inservice Inspection Program.
As documented in the Audit and Review Report, the staff also reviewed the summary of specificoperating experience for its ASME Section XI ISI (Subsection IWF) Program. Review of the
 
summary indicated that the applicant did not identify any age-related ASME Code Class 1, 2, 3, and MC component support failures. During the initial audit and review (August 9-13, 2004)
 
NMP1 plant maintenance records revealed that there have been no age-related failures of any
 
supports in the program and internal audits hav e revealed only administrative deficiencies that did not affect the ability of any support to perform its intended function. One CR which
 
demonstrated the effectiveness of inspection techniques in use at NMP1 reported a support that
 
may have lost a degree of freedom from the improper application of paint. Further investigation
 
revealed the support maintained its intended function with no age-related degradation. Other
 
CRs documented deficiencies discovered and corrected through site quality assurance and
 
CAPs. No improperly managed age-related degradation was discovered, thus providing
 
assurance that support degradation had not occurred since the inception of the program.
During the initial audit and review (August 9-13, 2004) NMP2 plant maintenance records also revealed that there have been no age-related failures of any supports in the program, and
 
internal audits have revealed only administrative deficiencies that did not affect the ability of any
 
support to perform its intended function. One CR demonstrating effective inspection techniques
 
in use at NMP2 reported a support with a gap between the inner nut and clamp. The pipe clamp
 
bolts were tightened to their original design specification and the support was found to be
 
operable so there was no loss of intended function. Other CRs documented deficiencies
 
discovered and corrected through site quality assurance and CAPs. No improperly managed 3-96 age-related degradation was discovered, thus providing assurance that support degradation had not occurred since the inception of the program.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience reveals no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with theapplicant's technical personnel the staff concludes that the applicant's ASME Section XI ISI (Subsection IWF) Program will manage adequately the aging effects and aging effects
 
mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.3 and A2.1.3, the applicant providedthe respective UFSAR and USAR supplements for the ASME Section XI Inservice Inspection (Subsection IWF) Program. The staff reviewed these sections and determined that the
 
information in the supplements provide adequat e summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's ASME Section XI Inservice Inspection (Subsection IWF) Program, the staff determined that those program elements for
 
which the applicant claimed consistency with the GALL Report are consistent with the GALL
 
Report. In addition the staff reviewed the exception and the associated justifications, and
 
determined that the AMP, with the exception, is adequate to manage the aging effects for which
 
it is credited.The staff concludes that there is reasonable assurance that the applicant
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions 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 UFSAR and USAR supplements for
 
this AMP and concludes that they provide an adequate summary description of the program, as
 
required by 10 CFR 54.21(d).
3.0.3.2.20  Masonry Wall Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.27, the applicant described the Masonry Wall Program, stating that this is an existing program that is consistent, with enhancements, with GALL AMP XI.S5, "Masonry Wall Program." The Masonry
 
Wall Program manages aging effects so that the evaluation basis established for each masonry
 
wall within the scope of license renewal remains valid through the period of extended operation.
 
The Masonry Wall Program is based on the structures monitoring requirements of
 
10 CFR 50.65. Implementation of the Masonry Wall Program is discussed in the program
 
description for the Structures Monitoring Program.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
3-97 Because the applicant chose to implement its Masonry Wall Program through its Structures Monitoring Program the staff evaluations are combined with the evaluations of the Structures
 
Monitoring Program in SER Section 3.0.3.2.21.
Operating Experience. Refer to SER Section 3.0.3.2.21.
UFSAR and USAR Supplements. In ALRA Sections A1.1.23 and A2.1.23, the applicant provided the respective UFSAR and USAR supplements for the Masonry Wall Program. The
 
staff reviewed these sections and determined that the information in the supplements provide
 
adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Masonry Wall Program, the staff determined that those program elements for which the applicant claimed consistency with
 
the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR and USAR
 
supplements for this AMP and concludes that they provide an adequate summary description of
 
the program, as required by 10 CFR 54.21(d).
3.0.3.2.21  Structures Monitoring Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.28, the applicant described the Structures Monitoring Program, stating that this is an existing program that is consistent, with enhancements, with GALL AMP XI.S6, "Structures Monitoring Program."
 
The Structures Monitoring Program manages aging of structures, structural components, and
 
structural supports within the scope of license renewal. The program provides for periodic visual
 
inspections, surveys, and examination of all sa fety related buildings (including the primary containment and substructures within the primary containment) and various other buildings
 
within the scope of license renewal. Program activities identify degradation of materials of
 
construction, which include structural steel, concrete, masonry block, and sealing materials.
 
While not credited for mitigation of aging, protective coatings are also inspected under this
 
program. The Structures Monitoring Program, which was initially developed to meet the regulatory requirements of 10 CFR 50.65, implements guidance provided in RG 1.160, NUMARC 93-01, and NEI 96-03.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
During the initial audit and review (August 9-13, 2004) the staff asked the applicant to explain the design of the foundations for its structures within license renewal and whether any have
 
porous concrete subfoundations. In addition the staff requested the applicant to explain if any
 
license renewal structures have settlement issues and if there is a site de-watering system.
3-98 As documented in the Audit and Review Report, the applicant stated in response to the staff's questions that the foundations for the structures within the scope of license renewal are
 
reinforced concrete on bedrock. Porous concrete sub-foundation construction was not used at
 
NMP. The applicant also responded that settlement is not an aging effect or aging effect
 
mechanism at NMP and that there is no site de-watering system.GALL AMP XI.S5 under the "detection of aging effects" program element states that the frequency of inspection is selected to ensure 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 not contained by bracing warrant the most
 
frequent inspection because cracks may invalidate the existing evaluation basis. The applicant
 
stated in its Masonry Wall Program basis document that the inspection frequency of six years
 
for the unreinforced walls is consistent with the GALL Report. However, this inspection
 
frequency is the same as that for reinforced masonry walls as discussed in the applicant's
 
program basis document.
In addition as documented in the Audit and Review Report, the staff asked the applicant to explain how the same inspection frequency for all reinforced, unreinforced, and braced masonry
 
walls within the scope of license renewal is consistent with the GALL Report. The applicant
 
responded that it will require as part of its Masonry Wall Program (as managed by its Structures
 
Monitoring Program) that unreinforced masonry walls without bracing be inspected for cracking
 
more frequently than reinforced or braced masonry walls.
In its letter dated December 1, 2005, the applicant added to the ALRA a commitment to enhance its Masonry Wall Program (as managed by its Structures Monitoring Program) based on the GALL Report text in the program element, "detection of aging effects." The program
 
enhancement will provide guidance for inspecting NMP1 unreinforced or unbraced masonry
 
walls within the scope of license renewal more frequently than reinforced masonry walls. The
 
ALRA sections affected are A1.1.34, A1.4, and B2.1.28 (NMP1 Commitment 39).
The staff found the applicant's response acceptable. With the commitment to inspect unreinforced masonry walls more frequently the applicant's Structural Monitoring Program is now consistent with the "detection of aging effects" program element of GALL AMP XI.S5.
As further documented in the Audit and Review Report, the staff noted that the applicant's Structures Monitoring Program basis document lists wood in air as one of the NMP1
 
component/commodity groups managed by the pr ogram. The staff requested the applicant to explain why wood was not listed under the program description in ALRA Section A1.1.34 and
 
NMP AMP B2.1.28 as one of the construction materials inspected for degradation by the
 
program. The applicant responded that it would add wood to the list of materials for NMP1 in the
 
program description of ALRA Sections B2.1.28 and A1.1.34.
In its letter dated December 1, 2005, the applicant stated that ALRA Section A1.1.34 had been revised to add NMP1 wooden structure to the list of construction materials in the first paragraph
 
and that ALRA Section B2.1.28 had been revised by adding NMP1 wooden structure to the list
 
of construction materials in the first paragraph under the program description.
3-99 The staff found the applicant's response acceptable. With the addition of wood to ALRA Sections A1.1.34 and B2.1.28 the applicant's Structures Monitoring Program in the ALRA is now
 
in agreement with the program basis document.
The staff reviewed those portions of the Structures Monitoring Program for which the applicantclaimed consistency with GALL AMP XI.S5 and GALL AMP XI.S6, and found them consistent.
 
The staff found the applicant's Structures Monitoring Program acceptable because it conforms to the recommended GALL AMP XI.S5, "Masonry Wall Program," and GALL AMP XI.S6, "Structures Monitoring Program," with enhancements.
In the ALRA, the applicant stated that its Structures Monitoring Program is consistent with GALLAMP XI.S6 with an enhancement. As stated In the ALRA, the enhancement in meeting the
 
GALL Report program elements is to expand scope and make revisions to activities (i.e.,
procedures) credited for license renewal to ensure that aging effects and aging effects
 
mechanisms are discovered and evaluated (NMP1 Commitment 26, NMP2 Commitment 24).
In the ALRA, the applicant stated that its Structures Monitoring Program will be expanded to include within the scope of license renewal the following listed activities or components not
 
currently within the scope of 10 CFR 50.65:  (a)  NMP2 fire-rated assemblies and watertight penetration visual inspections,  (b)NMP2 masonry walls in the turbine building and service water tunnel serving a fire barrier function, and    (c)the steel electrical transmission towers required for the station blackout (SBO) and recovery paths for NMP1 and NMP2.
Also parameters monitored during structural inspections will be expanded to include those relevant to aging effects and aging effects mechanisms for structural bolting. This enhancement
 
affects the "parameters monitored/inspected," "detection of aging effects," and acceptance
 
criteria" program elements of the GALL Report. In addition regularly scheduled ground water
 
monitoring will ensure that a benign environment is maintained, this enhancement affects the
 
"parameters monitored/inspected" and "detecti on of aging effects" program elements of the GALL Report.
The staff determined that with these additional inspections of SCs the applicant's Structures Monitoring Program will meet the recommendation of GALL AMP XI.S6. The applicant identifiedcommitments to the NRC with these enhancements relative to GALL AMP XI.S6. Because
 
inspection of these additional structural components will make the applicant's program consistent with GALL AMP XI.S6 the staff found these enhancements acceptable. These
 
changes to the applicant's program will provide assurance that the effects of aging will be
 
adequately managed.
Operating Experience. In ALRA Section B2.1.28, the applicant explained it has reviewed both industry and plant-specific operating experience relating to the Structures Monitoring Program.
 
Since implementation of inspections under the Structures Monitoring Program, minor cracking
 
has been identified in various concrete structures and slight (but stable) ground water leaks
 
have occurred in some tunnels. However, a review of plant-specific operating experience 3-100 revealed no cases of structural failure caused by unidentified degradation. Similarly, no structural deficiencies have been identified in flood control structures.
As documented in the Audit and Review Report, the staff also reviewed the summary of specific operating experience for the applicant's Structures Monitoring Program. The review indicated
 
that the applicant's Structures Monitoring Program is effective in identifying structural
 
degradation, implementing corrective actions , and trending parameters for NMP structures within the scope of license renewal. When degradation has been identified corrective actions
 
have been implemented to ensure that the integrity of the affected structure is maintained
 
without loss of intended function.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
As stated in the Audit and Review Report, NMP1 and NMP2 plant maintenance/ inspection records revealed that since implementation t he applicant's Structures Monitoring Program has been effective identifying structural degradation before a loss of intended function occurs.
Several CRs have identified minor cracking in concrete structures including the service water pipe tunnel. Because the service water pipe tunnel is susceptible to small wall cracks allowing
 
leakage of ground water the staff requested the applicant to discuss the results of the latest
 
inspections of the tunnel and how often these inspections were done. The applicant stated in
 
response that the repaired areas referenced in the service water pipe tunnel CR had been
 
inspected recently and that there continued to be no entry of ground water in the areas repaired.
 
The frequency of inspections following the repairs has varied. Initially repair inspections were
 
monthly, then quarterly, then annually. Inspections of the tunnel are now scheduled for every
 
refueling outage.
In addition during the initial audit and review the staff asked the applicant to explain if there is any rust staining in the tunnel, indicating corrosion of rebar in the concrete, the reason for not
 
performing any external waterproofing repairs to the tunnel. The applicant responded that
 
inspections of accessible areas adjacent to inaccessible areas can indicate the condition of the
 
inaccessible areas. Rust stains have not been identified on the internal surface of the concrete
 
adjacent to the areas of leakage through the tunnel concrete walls. Therefore, it is reasonable to
 
conclude that degradation of the reinforcing steel is not occurring. Waterproof coating of the
 
exterior surface of the structure is not required due to successful repairs to water penetration
 
paths from the inside the structure.
Furthermore, during the initial audit and review the staff asked the applicant to explain how the design of the service water pipe tunnel keep the flood depth under three inches if ground water
 
entered again and the sump pumps failed as reported in the CR. The applicant stated that the
 
tunnel is sectioned by various curbs and elevations. If the sumps failed in the tunnel water
 
would flow over the curb and into another sump.
The applicant was also asked at the time to discuss results of the latest inspections for the normal switchgear building, service water tunnels, and the radwaste building for below grade
 
exterior walls where groundwater also has entered. The applicant stated that the latest 3-101 inspections have not identified significant water entry for the structures within the scope of license renewal.
Based on the initial audit and review that the applicant's Structures Monitoring Program procedures provide for buried structures that when inaccessible areas are excavated or
 
exposed if practical an inspection of these structures will be performed and findings included in
 
the program's database.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel the staff concludes that there is reasonable assurance that the
 
applicant's Structures Monitoring Program will manage adequately the aging effects and aging
 
effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.34 and A2.1.34, the applicant provided the respective UFSAR and USAR supplem ents for the Structures Monitoring Program.
The staff reviewed these sections and determined that the information in the supplements
 
provide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Structures Monitoring Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report. Also, the staff has
 
reviewed the enhancements and confirmed that t he implementation of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the
 
GALL Report AMP to which it was compared.The staff concludes that there is reasonable
 
assurance that the applicant has demonstrated that the effects of aging will be adequately
 
managed so that the intended functions 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
 
UFSAR and USAR supplements for this AMP and concludes that they provide an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.22  Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program Summary of Technical Information in the Amended Application. In ALRA Section B2.1.30, the applicant described the Non-EQ Electrical Cables and Connections Used in Instrumentation
 
Circuits Program, stating that this is an exis ting program that is consistent, with enhancements,with GALL AMP XI.E2, "Electrical Cables and Connections Not Subject to 10 CFR 50.49
 
Environmental Qualification Requirements Used in Instrumentation Circuits." The Non-EQ
 
Electrical Cables Used in Instrumentation Circuits Program manages aging of cables and connections exposed to adverse localized temper ature and radiation environments that could result in loss of insulation resistance. It applies to accessible and inaccessible electrical cables
 
that are not in the EQ Program and are used in circuits with sensitive, high-voltage, low-level
 
signals such as radiation monitoring, nuclear instrumentation, and other such cables subject to
 
AMR that are sensitive to a reduction in insulation resistance. Activities include routine
 
calibration tests of instrumentation loops or direct testing of the cable system in those cases
 
where cable testing is conducted as an alternate to surveillance testing, and in either case are
 
implemented through the Surveillance Testing and Preventive Maintenance Programs. Testing is based on requirements of the particular calibrations, surveillances, or testing performed on
 
the specific instrumentation circuit or cable and is implemented through the NMP work control 3-102 system. Where cable testing is conducted as an alternate to surveillance testing the acceptance criteria for each test will be defined by the specific type of test performed and the specific cable
 
tested.Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justification to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
The staff reviewed nuclear engineering reports (NERs) for NMP1 and NMP2. The staff found inconsistency between NMP1 and NMP2 non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program scopes. For example, the scope for NMP1 includes power range monitoring (PRM) and intermediate range moni toring (IRM) circuitry. However, the AMP scope for NMP2 includes only the IRM circuit. As documented in the Audit and Review Report, the staff requested that the applicant review the NERs and clarify the differences between the
 
scoping of the two units. The applicant clarified differences between the scoping of NMP1 and
 
NMP2. The applicant indicated that some cables are not within the scope of the Non-EQ
 
Electrical Cables and Connections Used in Inst rumentation Circuits Program because these cables are in the EQ Program and therefore not within the scope of Non-EQ Electrical Cables
 
and Connections Used in Instrumentation Circuits Program. The applicant also informed the
 
staff that as a result of responding to the staff's request it reviewed the NERs and found a
 
discrepancy in the safety classification between NMP1 and NMP2. The applicant informed the
 
staff that it would initiate a CR to document the discrepancy between NMP1 and NMP2 and
 
revise the NMP1 and NMP2 NERs and the program basis document. The staff found the
 
applicant's response acceptable. The staff reviewed the applicant's revised program basis
 
document and NERs and concludes that the scope of cables in the Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program is acceptable.
As documented in the Audit and Review Report, the staff also requested that the applicant verify tests performed by procedures including the entire loop (cables and connections) credited in the
 
Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program basis document. The applicant responded that the credited procedure steps listed in its program basis
 
document (GALL Report program element "accept ance criteria") were reviewed to ensure that all cables and connections of the system were tested. The applicant verified for each procedure credited that all cables and connections within the scope of GALL AMP XI.E2 are tested. The
 
staff found the applicant's response acceptable.
The staff reviewed those portions of the Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program for which the applicant claimed consistency with GALLAMP XI.E2 and found them consistent. The staff found the applicant's Non-EQ Electrical Cables
 
and Connections Used in Instrumentation Circuits Program acceptable because it conforms tothe recommended GALL AMP XI.E2 with enhancements.
In the ALRA, the applicant stated that its Non-EQ Electrical Cables and Connections Used inInstrumentation Circuits Program is consistent with GALL AMP XI.E2 with enhancements to the
 
GALL Report "detection of aging effects" program element by reviews of calibration or
 
surveillance data for indications of aging degradation affecting instrument circuit performance.
 
The first reviews will be completed prior to the period of extended operation and every ten years 3-103 thereafter. A review of the calibration and surveillance results can indicate aging effects and aging effects mechanisms by monitoring key param eters and providing instrumentation circuit performance data reviewed at the time of the calibrations and surveillances, thereby providing
 
reasonable assurance that severe aging degradation will be detected prior to loss of the cables'
 
intended function. Where a calibration or surveillance program does not include the cabling
 
system in the testing circuit alternatives like in sulation resistance tests or other testing effective in determining cable insulation condition or deterioration of the insulation system will be
 
performed. The first test will be completed prior to the period of extended operation. Test
 
frequency will be based on engineering evaluation but will be at least once every 10 years (NMP1 Commitment 28, NMP2 Commitment 26).
As documented in the Audit and Review Report, the staff concludes that these enhancements will not impact adversely the ability of this AMP to manage the effects of aging as either of the two methods is acceptable to detect aging degradation. Calibration results or surveillance
 
testing program findings are evaluated to detect cable aging degradation. Direct testing of the
 
cable system will be effective in determining the condition of cable insulation. On this basis, the
 
staff found this enhancement acceptable because changes to the applicant's program will
 
provide assurance that the effects of aging will be adequately managed.
Operating Experience. In ALRA Section B2.1.30, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the Non-EQ Electrical Cables
 
Used in Instrumentation Circuits Program. Review of plant-specific operating experience
 
revealed documentation of cable degradation identified through routine calibration testing that is
 
similar to the industry operating experience (e.g., degraded cables for temperature instruments, degraded shielding for drywell instrument cables).
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel the staff concludes that there is reasonable assurance that the
 
applicant's Non-EQ Electrical Cables Used in Instrumentation Circuits Program will manage adequately the aging effects and aging effects mechanisms identified in the ALRA for which this
 
AMP is credited.
UFSAR and USAR Supplements. In ALRA Sections A1.1.25 and A2.1.25, the applicant provided the respective UFSAR and USAR supplem ents for the Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program. The staff reviewed these sections and
 
determined that the information in the supplements provide adequate summary descriptions of
 
the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Non-EQ Electrical Cables and Connections Used in Instrumentation Circuits Program, the staff determined that those program
 
elements for which the applicant claimed consistency with the GALL Report are consistent with
 
the GALL Report. Also, the staff has reviewed the enhancements and confirmed that the
 
implementation of the enhancements prior to t he period of extended operation would result in the existing AMP being consistent with the GALL Report AMP to which it was compared.The
 
staff concludes that there is reasonable assurance that the applicant has demonstrated that the 3-104 effects of aging will be adequately managed so that the intended functions 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 UFSAR and USAR supplements for this AMP
 
and concludes that they provide an adequate summary description of the program, as required
 
by 10 CFR 54.21(d).
3.0.3.2.23  Bolting Integrity Program
 
Summary of Technical Information in the Application. In ALRA Section B2.1.36, and as supplemented by letter dated November 17, 2005, the applicant described the Bolting Integrity
 
Program, stating that this is an existing program that is consistent with enhancements and an exception to GALL AMP XI.M18, "Bolting Integrity." The Bolting Integrity Program manages
 
aging effects due to loss of preload, cracking and loss of material from bolting within the scope
 
of license renewal including SR bolting, bolting for NSSS component supports, bolting for other
 
pressure-retaining components, and structural bolting. Program activities include periodic
 
inspections of bolting for indication of loss of preload, cracking and loss of material due to
 
corrosion, etc. This program is based on the guidelines delineated in NUREG-1339, "Resolution
 
of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," and the
 
guidance contained in EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power
 
Plants," with exceptions noted in NUREG-1339 for safety-related bolting and EPRI TR-104213, "Bolted Joint Maintenance and Applications Guide," for other bolting. The Bolting Integrity Program is implemented through the ASME Section XI ISI (Subsection IWB, IWC, IWD)
Program, ASME Section XI Inservice Inspection (Subsection IWE) Program, ASME Section XI
 
Inservice Inspection (Subsection IWF) Program , Structures Monitoring Program, Preventive Maintenance Program, and Systems Walkdown Program.
Staff Evaluation. In ALRA Section B.2.1.36, "Bolting Integrity Program," and by letter dated November 17, 2005, the applicant described its AMP to manage effects of aging in bolting. The applicant states that this AMP when enhanced will be consistent with GALL AMP XI.M18 with
 
an exception.
As stated in ALRA Section B2.1.36, enhancements to the Bolting Integrity Program include establishing an augmented inspection program for high-strength bolts in nuclear steam supply
 
system (NSSS) supports and revisions to activities credited for license renewal.
Program Elements Affected - Documents will be prepared or revised to address the following elements:
Scope of Program - The Structures Monito ring, Preventive Maintenance, and Systems Walkdown Programs will be enhanced to include requirements to inspect bolting for loss
 
of preload, cracking, and loss of material, as applicable. References to the bolting
 
integrity program and industry guidance will be included in NMP administrative and
 
implementing program documents.
Detection of Aging Effects - An augmented inspection program for high-strength (actual yield strength >
150 ksi) bolts will be established to prescribe the examinationrequirements of Tables IWB-2500-1 and IWC-2500-1 of ASME Section XI for
 
high-strength bolts in the Class 1 and Class 2 component supports, respectively.
3-105 The applicant stated that the enhancements will be completed prior to the period of extended operation (NMP1 Commitment 33 and NMP2 Commitment 31).
As stated in the applicant's letter dated November 17, 2005, an exception to GALL ReportSection XI.M18, "Bolting Integrity," was added for its reference to the 1995 Edition-1996
 
Addenda of the ASME Code. The program described in GALL AMP XI.M18 under "detection of aging effects" cites ASMESection XI requirements covered in the 1995 Edition through the 1996 Addenda. The code of
 
record for NMP1 and NMP2 is the 1989 Code with no addenda; this is an exception to the GALL
 
Report. For SR bolting the applicant relies on the NRC recommendations and guidelines of NUREG-1339 and industry's technical basis for material selection and testing, bolting preload
 
control, ISI, plant operation and maintenance, and evaluation of structural integrity of bolted
 
joints outlined in EPRI NP-5769 with the exceptions noted in NUREG-1339. This guidance is consistent with GALL AMP XI.M18 and the staff found it acceptable.
With regard to other bolting the applicant states that it will comply with the aging management attributes of EPRI TR-104213. The staff found that for other bolting the applicant's Bolting
 
Integrity Program will be consistent with the recommendations in the GALL Report and will meet
 
the standards of EPRI TR-104213 with the inclusion of enhancements.
The first enhancement to the Bolting Integrity Program is that the applicant will establish an augmented inspection program for high-strength (actual yield strength >
150 ksi) bolts. The staff noted that this augmented program will pre scribe the examination requirements ofTables IWB-2500-1 and IWC-2500-1 of ASME Section XI for high-strength bolts in the Class 1
 
and Class 2 component supports, respectively. The second enhancement is that the Structures
 
Monitoring, Preventive Maintenance and Sy stems Walkdown Programs will be enhanced to include requirements to inspect bolting for loss of preload, cracking, and loss of material. The
 
last enhancement is that references to the Bolting Integrity Program and industry guidance will
 
be included in NMPNS program documents. The staff noted that the existing Bolting Integrity Program with these enhancements will be consistent with GALL AMP X1.M18.
Previously the staff has accepted the use of periodic ISI of closure bolting as an acceptable AMP for loss of mechanical closure integrity as failure of the mechanical joint indicated by
 
leakage can be attributed to loss of material, cracking of bolting materials, or loss of preload.
The staff determined that periodic ASME Section XI ISI and plant preventive maintenance
 
programs as described in NUREG-1339 and EPRI NP-5769 can be relied upon effectively to
 
detect loss of closure integrity for bolted assemblies. Therefore, the applicant's program for loss
 
of mechanical closure integrity is adequate for managing aging effects of loss of material
 
cracking and loss of preload. The staff finds that the applicant with its enhancements to the
 
Bolting Integrity Program has demonstrated its compliance with all the attributes of GALL AMP XI.M18 for bolting within the scope of license renewal including safety-related bolting, bolting for NSSS component supports, and bolting for other pressure-retaining components.
The applicant in its letter dated November 17, 2005, indicated that an exception had been added to the Bolting Integrity Program. The exception was with respect to the reference to the 1995 Edition-1996 Addenda of the ASME Code in GALL Report Section XI.M18. However, the 3-106 Code of record for NMP1 and NMP2 is the 1989 Code 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 through the 1996 Addenda against those of the 1989 Edition
 
and found them to be consistent with the exception of the examination requirement for the RV
 
closure head nuts. The staff noted that the examination requirement in the 1989 Code Edition
 
for the RV closure head nuts is more conservative than that required in the 1995 Edition through
 
the 1996 Addenda. Furthermore, the staff noted that the RV closure head nuts will be managed
 
by the applicant's Reactor Head Closure Studs Program (ALRA Section B2.1.3), which is
 
assessed in SER Section 3.0.3.2.3. Therefore, the staff finds the applicant's Bolting Integrity
 
Program with the enhancements and exception acceptable. The staff concludes that by
 
implementing the Bolting Integrity Program, which is consistent with the GALL Report with an
 
exception, the aging effects on the bolting within the scope of license renewal including SR
 
bolting, bolting for NSSS component supports, and bolting for other pressure-retaining
 
components, will be adequately managed for the extended period of operation.
Operating Experience. In ALRA Section B2.1.36, the applicant indicated that it has reviewed both industry and plant-specific operating experience related to the Bolting Integrity Program
 
and is aware of the types of bolting issues that have been reported and documented in the
 
industry. The applicant also indicated that the lessons learned from industry experiences have
 
been incorporated into the NMPNS bolting practices such that this program has adequately
 
detected bolting integrity issues and has been effective in correcting issues prior to the loss of
 
intended function. This program is adjusted continually to account for industry experience and
 
research. The applicant also indicated that with additional operating experience lessons learned
 
will be used to adjust the Bolting Integrity Program as needed.
The applicant stated that the Bolting Integrity Program has been effective in managing the aging effects of bolting within the scope of license renewal including SR bolting, bolting for NSSS
 
component supports, and bolting for other pressure-retaining components.
UFSAR and USAR Supplements. In ALRA Sections A1.1.38 and A2.1.37, the applicant provided the respective UFSAR and USAR supplements for the Bolting Integrity Program. The
 
staff reviewed the following UFSAR and USAR supplement summary description for the Bolting
 
Integrity Program:
The Bolting Integrity Program manages aging effects due to loss of preload, cracking and loss of material of bolting within the scope of license renewal
 
including safety-related bolting, bolting for NSSS component supports, bolting for
 
other pressure retaining components, and structural bolting. Program activities
 
include periodic inspections of bolting for indication of loss of preload, cracking
 
and loss of material due to corrosion, rust, etc.
This program is based on the guidelines of NUREG-1339 and the guidance of EPRI NP-5769 with exceptions noted in NUREG-1339 for safety-related bolting and EPRI TR-104213 for other
 
bolting. The Bolting Integrity Program is implemented through the ASME Section XIinservice Inspection (Subsections IWB, IWC, IWD) Program, ASME Section XI Inservice Inspection (Subsection IWE) Program, ASME Section XI Inservice 3-107 Inspection (Subsection IWF) Program, Structures Monitoring Program, Preventive Maintenance Program, and Systems Walkdown Program.
Enhancements to the Bolting Integrity Program include:Establish an augmented inspection program for high-strength (actual yield strength > 150 ksi) bolts. This augmented program will prescribe the examinationrequirements of Tables IWB-2500-1 and IWC-2500-1 of ASME Section XI for high-strength bolts in the Class 1 and Class 2 component supports, respectively. The Structures Monitoring, Preventive Maintenance and Systems WalkdownPrograms will be enhanced to include requirements to inspect bolting for indication
 
of loss of preload, cracking and loss of material, as applicable. Include in NMP administrative and implementing program documents references to the Bolting Integrity Program and industry guidance.
Enhancements will be completed prior to the period of extended operation.
The applicant stated that the exception to the NMP1 and NMP2 Bolting Integrity Program includes: Add an exception to GALL Report Program XI.M18 for its reference to the 95-96 Addenda of the ASME Code.
The applicant's UFSAR and USAR supplement summary descriptions for the Bolting Integrity Program appropriately describe the implementati on of relevant programs that would enable the applicant to manage effectively the aging effect due to loss of material, cracking, and loss of
 
preload of the bolts at the NMPNS units for the extended period of operation.
Conclusion. On the basis of its review and audit of the applicant's Bolting Integrity Program, the staff determined that those program elements for which the applicant claimed consistency with
 
the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant has demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR and USAR
 
supplements for this AMP and concludes that they provide an adequate summary description of
 
the program, as required by 10 CFR 54.21(d).
3.0.3.2.24  BWR Control Rod Drive Return Line (CRDRL) Nozzle Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.37, the applicant described the BWR Control Rod Drive Return Line (CRDRL) Nozzle Program, stating
 
that this is an existing program that is consistent, with exceptions, with GALL AMP XI.M6, "BWR Control Rod Drive Return Line Nozzle." The NMP1 CRDRL Nozzle is examined according to ASME Code, Section XI, program which satisfies the requirements in GALL AMP XI.M1, "ASME 3-108Section XI Inservice Inspection, Subsections IWB, IWC and IWD." This program is updated in accordance with 10 CFR 50.55(a). Augmented examinations incorporated into the ISI program
 
plan that implemented the requirements of NUREG-0619, "BWR Feedwater Nozzle and Control
 
Rod Drive Return Line Nozzle Cracking,"
November 1980, have been superseded by ASMESection XI, Appendix VIII, "Performance Demonstr ation for Ultrasonic Examination Systems" (1995 Edition with the 1996 Addenda). NMP2 cut and capped the CRD return nozzle prior to
 
commercial operation. The capped NMP2 CRD return nozzle was therefore not subject to the
 
augmented examination requirements described in NUREG-0619. The NMP2 CRDRL Nozzle Program is implemented through ASME Section XI, Subsection IWB, Table IWB 2500-1 (1989 edition no addenda) and ASME Section XI, Appendix VIII, "Performance Demonstration for
 
Ultrasonic Examination Systems" (1995 Edition with the 1996 Addenda).
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exceptions and the
 
associated justifications to determine whether the AMP, with the exceptions, remains adequate
 
to manage the aging effects for which it is credited.
The staff reviewed those portions of the BWR CRDRL Nozzle Program for which the applicantclaimed consistency with GALL AMP XI.M6 and found them consistent. The staff found the
 
applicant's BWR CRDRL Program acceptable because it conforms to the recommended GALL AMP XI.M6 with exceptions.
In the ALRA, the applicant stated that its BWR CRDRL Nozzle Program is consistent with GALLAMP XI.M6 with an exception to the Program Description in GALL AMP XI.M6 involving theASME Code edition used as the basis for the Section XI requirements. GALL AMP XI.M6 identifies the 1995 Edition (including the 1996 Addenda) of ASME Section XI as the basis for
 
the GALL CRDRL Nozzle Program. The NMP ISI Program will not comply with the edition and addenda of ASME Section XI cited in the GALL Report because the program is updated to the latest edition and addenda of ASME Section XI as mandated by 10 CFR 50.55a prior to the start
 
of each inspection interval. The acceptability of the NMP1 CRDRL Nozzle Program in meeting
 
the augmented inspection requirements established in NUREG-0619 is documented in NRC
 
Safety Evaluation Report dated February 5, 1999.
In the ALRA, the applicant stated that the exceptions were found acceptable in the February 5, 1999, NRC Safety Evaluation Report. As mandated by 10 CFR 50.55a, UT examinations areperformed according to the ASME Section XI Appendix VIII 1995 Edition with the 1996
 
Addenda. As documented in the Audit and Review Report, the staff also noted that the applicant's ASME code of record for ASME Section XI ISI (Subsections IWB, IWC, and IWD) is valid for a 10-year inspection interval under the CLB. At present an ASME Section XI ISI (Subsection IWB, IWC, and IWD) program is approved for use on an ASME Code 10-year ISI interval-specific basis. However, the applicant will have to request 12 months prior to each interval approval to use the ASME Section XI ISI (Subsection IWB, IWC, and IWD) Program for
 
the specific intervals during the period of extended operation under 10 CFR 50.55a,. Therefore, the staff determined that the ASME Section XI Code Edition as referenced in 10 CFR 50.55a in
 
effect 12 months prior to each inspection interval is acceptable for the period of extended
 
operation and the staff found this exception acceptable.
3-109 In addition in the ALRA, the applicant stated that it takes exceptions to the GALL Report "detection of aging effects," "monitoring and trending," and "acceptance criteria" program
 
elements. The three exceptions to GALL AMP XI.M6 are (1) the NMP ISI Program does notcomply with the specified edition and addenda of ASME Section XI cited in the GALL Report because the program is updated to the latest edition and addenda of ASME Section XI as
 
mandated by 10 CFR 50.55a prior to the start of each inspection interval, (2) the NMP program
 
uses enhanced UT inspection techniques instead of PT inspections to satisfy the recommendations of NUREG-0619 (now superseded by Appendix VIII to ASME Section XI, Division 1, 1995 Edition with the 1996 Addenda), and (3) the NMP program uses an inspection
 
frequency of every 10 years versus every sixth refueling outage or 90 startup/shutdown cycles
 
specified in NUREG-0619.
In the ALRA, the applicant stated that it has evaluated each of these exceptions and determined that its CRDRL Nozzle Program adequately manages the effects of aging on the CRDRL. The
 
applicant evaluated each of these exceptions and determined that its CRDRL Nozzle Program is consistent with GALL AMP XI.M6. After review of operating experience for the applicant's
 
BWR CRDRL Nozzle Program, the staff found this exception acceptable.
Operating Experience. In ALRA Section B2.1.37, the applicant explained that UT examinations of the Unit 1 CRDRL nozzle performed during refueling outages using automated test equipment qualified according to Appendix VIII to ASME Section XI, Division 1, 1995 Edition
 
with the 1996 Addenda, found no indications. The UT examination using automated test
 
equipment has been demonstrated to be capable of reliably detecting flaws greater than or
 
equal to a 0.25 inch depth. No industry experience was identified that indicates that existing
 
programs and practices will not be effective in the timely identification of CRDRL nozzle
 
cracking.The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel, the staff concludes that there is reasonable assurance that the
 
applicant's BWR CRDRL Nozzle Program will manage adequately the aging effects and aging
 
effects mechanisms identified in the ALRA for which this AMP is credited.
UFSAR Supplement. In ALRA Section A1.1.39, the applicant provided the UFSAR supplement for the BWR CRDRL Nozzle Program. The staff reviewed this section and determined that the
 
information in the supplement provides an adequate summary description of the program, as
 
required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's BWR CRDRL Nozzle Program, the staff determined that those program elements for which the applicant claimed
 
consistency with the GALL Report are consistent with the GALL Report. In addition the staff
 
reviewed the exceptions and the associated justifications, and determined that the AMP, with
 
the exceptions, is adequate to manage the aging effects for which it is credited.The staff
 
concludes that there is reasonable assurance that the applicant has demonstrated that the
 
effects of aging will be adequately managed so that the intended functions will be maintained
 
consistent with the CLB for the period of extended operation, as required by 3-110 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR 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  Protective Coating Monitoring and Maintenance Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.38, the applicant described the Protective Coating Monitoring and Maintenance Program, stating that
 
this is an existing program that is consistent, with exceptions and enhancements, with GALL AMP XI.S8, "Protective Coating Monitoring and Maintenance Program." The Protective Coating Monitoring and Maintenance Program is described in the NMP1 and NMP2 responses to
 
GL 98-04, "Potential for Degradation of the Emergency Core Cooling System and the
 
Containment Spray System after a Loss-Of-Coolant Accident because of Construction and
 
Protective Coating Deficiencies and Foreign Material in Containment." The program was
 
developed according to ANSI N101.4-1972 referenced in RG 1.54, June 1973, along with
 
ANSI/ASME NQA-1-1983. The NMP program is a "comparable program" as described in GALL,Chapter XI, Program XI.S8, Protective Coating Monitoring and Maintenance Program, which is
 
an acceptable AMP for license renewal. The program applies to Service Level 1 protective
 
coatings inside the NMP1 primary containment and items within the torus [outside surface of the
 
vent (ring) header and downcomer, inside surface of the vent piping, ring header, vent header
 
junctions, and downcomers] and the NMP2 pr imary containment. The NMP2 suppression pool (wetwell) is not included because it is primarily stainless steel and does not have Service Level 1 coatings. Coating conditions monitored by this program include blistering, cracking, peeling, loose rust, and physical/mechanical damage. When localized degradation of a coating is
 
identified, the affected area is evaluated by engineering and is scheduled for repair, replacement, or removal, as needed. The condition assessments and resulting repair, replacement, or removal activities ensure that the amount of coatings subject to detachment
 
from the substrate during a loss of coolant accident (LOCA) is minimized to ensure
 
post-accident operability of the emergency core cooling system (ECCS) suction strainers.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the exceptions and
 
enhancements and the associated justifications to determine whether the AMP, with the
 
exceptions and enhancements, remains adequate to manage the aging effects for which it is
 
credited.The staff reviewed those portions of the Protective Coating Monitoring and MaintenanceProgram for which the applicant claimed consistency with GALL AMP XI.S8 and found them
 
consistent. The staff found the applicant's Protective Coating Monitoring and Maintenance Program acceptable because it conforms to the recommended GALL AMP XI.S8, "Protective
 
Coating Monitoring and Maintenance Program," with exceptions and enhancements.
In the ALRA, the applicant stated that its Protective Coating Monitoring and MaintenanceProgram is consistent with GALL AMP XI.S8 wi th an exception to the GALL Report "preventive actions" and "operating experience" program el ements. The Protective Coating Monitoring and Maintenance Program is not credited in the ALRA for the prevention of corrosion of carbon steel
 
components in the containment; however, the program monitors for rust not intact as a potential debris source for ECCS suction strainers. Therefore, as documented in the Audit and Review 3-111 Report, the applicant stated that operating experience pertaining to only the degradation of coatings and their potential clogging of the ECCS strainers is relevant to license renewal.
The staff found this exception acceptable because the applicant's Protective Coating Monitoring and Maintenance Program indeed is not credited in the amended license renewal application for
 
the prevention of corrosion of carbon steel co mponents in the NMP1 or NMP2 containment.
Other NMP AMPs are credited in the ALRA for the detection of loss of material by corrosion of
 
carbon steel components in the NMP1 or NMP2 containment. The applicant's Protective
 
Coating Monitoring and Maintenance Program is credited in the ALRA only for ensuring that the
 
amount of coatings subject to detachment from the substrate during a LOCA is minimized for post-accident operability of the ECCS suction strainers.
The applicant also stated in the ALRA that it takes exceptions to the GALL Report "parameters monitored/inspected," "detection of aging effects," "monitoring and trending," and "acceptance
 
criteria" program elements. The Protective C oating Monitoring and Maintenance Program will be enhanced following the guidance within ASTM D 5163-05a, "Standard Guide for Establishing
 
Procedures to Monitor the Performance of Coat ing Service Level 1 Coatings Systems in anOperating Nuclear Power Plant," instead of ASTM D 5163-96 as specified in GALL AMP  XI.S8.
In the ALRA, the applicant stated that the use of the guidance from ASTM D 5163-05a instead of ASTM D 5163-96 is acceptable because ASTM D 5163-05a is the most recently issued
 
standard and incorporates the latest industry guidance on protective coatings. In addition, as
 
documented in the Audit and Review Report, the applicant stated that ASTM D 5163-05a will be
 
utilized because this consensus standard was revised to correct previous errors embedded
 
within the qualification standards. The newer standard provides guidance on the qualification of
 
the individual(s) performing the actual coatings condition assessment while the GALL
 
Report-referenced standard is silent on that qualification. The older standard recommends that
 
inspectors and inspection coordinators be Level II Coatings Inspectors. This is an inappropriate
 
recommendation for the inspection coordinator since the Level II inspector qualification
 
requirement is invoked only for those enforcing compliance with 10 CFR 50 Appendix B Criterion IX (Special Processes) by coating film thickness readings (required when performing qualitative follow-up inspections) and inspections while restoring a coating system but not by
 
condition assessments which the coordinator facilitates.
The staff found this exception acceptable because other than the improvement changes between ASTM D 5163-05a and ASTM D 5163-96 discussed by the applicant the documents
 
are essentially the same. A terminology paragraph has been added to ASTM D 5163-05a which
 
shifts the paragraph numbering scheme by one. The element referenced in GALL AMP XI.S8 to the paragraph numbers in ASTM D 5163-96 would have a different paragraph number
 
referenced in ASTM D 5163-05a but there is little or no change to the content of the ASTM
 
standard.The applicant also stated In the ALRA that it takes exception to the GALL Report "acceptance criteria" program element. The Protective C oating Monitoring and Maintenance Program will vary the guidance of ASTM D 5163-05a paragraphs 10.2.2 and 10.2.3 on the measurement of
 
cracks and peeling coating. Rather, the applicant will use visual methods to estimate the size of
 
any defective areas. Once an area with cracks, peeling, or delaminated coating has been
 
detected visual estimation will quantify the surface area. Conservative estimates will be made 3-112 using known structural dimensions. This technique is acceptable for the purposes of quantifying the total amount of degraded coatings.
The staff found the applicant's explanation for the exceptions acceptable in that taking definitive measurements of cracking, peeling, or delaminated coatings in the NMP1 and NMP2
 
containments is an unnecessary burden which adds no value. Once a coatings area has been
 
identified as degraded an experienced coatings per son can use visual estimation techniques to quantify the square footage. Conservative estimates of the size of these areas will result in a
 
conservative total amount of degraded coatings that then can be compared to the total amount
 
of permitted degraded coatings to ensure post-accident operability of the ECCS suction
 
strainers. Conservative estimates of the amount of degraded coatings ensure actual margin for
 
ECCS suction strainer operability. Should the conservative estimate of degraded coatings
 
exceed the permitted amount more definitive m easurements then could be taken or coating repairs immediately undertaken.
No credit for coatings is taken in the prevention of corrosion; therefore, ASTM D 5163-96 is used instead of ASTM D 5163-05a because of improvement changes, and visual estimation
 
techniques are conservative. The staff's review of operating experience for the applicant's
 
Protective Coating Monitoring and Maintenance Program found these exceptions to be
 
acceptable.
In the ALRA, the applicant stated that its Protective Coating Monitoring and MaintenanceProgram is consistent with GALL AMP XI.S8 with an enhancement to meet the GALL Report
 
"parameters monitored/inspected," "detection of aging effects," "monitoring and trending," and
 
"acceptance criteria" program elements. Progr am administrative controls will be enhanced to incorporate specific details consistent with requirements in ASTM D 5163-05a (NMP1
 
Commitment 34, NMP2 Commitment 32).
In the ALRA, the applicant stated that its Protective Coating Monitoring and Maintenance Program administrative controls will be enhanced to specify the visual examination of coated surfaces for any visible defects including blistering, cracking, flaking, peeling, and physical or
 
mechanical damage. Also program administrative controls will be enhanced to (1) inspect
 
coatings every refueling outage versus every 24 months, (2) set minimum qualifications for inspection personnel, inspection coordinators, and inspection results evaluators, (3) perform
 
thorough visual inspections in areas noted as deficient concurrently with general visual
 
inspections, and (4) specify the types of instruments and equipment that may be used for
 
inspections. In addition program administrative controls will be enhanced to require (1) reviews
 
of the previous two monitoring reports before the condition assessment and (2) guidelines for
 
prioritization of repair areas to be monitored until they are repaired. Finally, program
 
administrative controls will be enhanced to require inspection results evaluators to determine
 
which areas are unacceptable and to initiate corrective action.
The staff determined that enhancement of the administrative controls for the applicant's Protective Coating Monitoring and Maintenance Progr am is consistent with the specific GALL Report referenced recommendations of ASTM D 5163-96 (now ASTM D 5163-05a after
 
exception) and will ensure the amount of Servic e Level 1 coatings inside the NMP1 primary containment and on surfaces within the torus (outside surface of the vent (ring) header and
 
downcomer, inside surface of the vent piping, ring header, vent header junctions, and
 
downcomers) and inside the NMP2 primary cont ainment subject to detachment from the 3-113 substrate during a LOCA is minimized for post-accident operability of the ECCS suction strainers. In addition the staff determined that by revising the program administrative controls for
 
these specific items the program will be consistent with the recommendations in GALL AMP XI.S8 considering the exception to the use of the 1996 Edition of ASTM D 5163. Because
 
adding these specific administrative controls will make the applicant's program consistent with GALL AMP XI.S8 the staff found this enhancement acceptable. These changes to the
 
applicant's program will provide assurance that the effects of aging will be adequately managed.
Operating Experience. In ALRA Section B2.1.38, the applicant explained that the Protective Coating Monitoring and Maintenance Program is not credited in the ALRA for prevention of
 
corrosion of carbon steel. NMP has implemented a Protective Coating Monitoring and
 
Maintenance Program consistent with the response to GL 98-04. The response to GL 98-04
 
described program attributes, including design and licensing basis, procurement, control of
 
coating application, quality assurance, monitoring, and maintenance of Service Level 1
 
coatings. Industry operating experience events pertaining to Service Level 1 coatings are
 
evaluated for applicability to NMP. If determined to be applicable, these events are entered into
 
the site CAP for determining any required corrective or preventive actions.
As documented in the Audit and Review Report, the staff also reviewed the summary of specific operating experience. The staff determined that the applicant's Protective Coating Monitoring
 
and Maintenance Program has been effective in detecting degraded coatings at various areas
 
within the NMP1 and NMP2 primary containments during refueling outages. To find some areas
 
of degraded coatings in containments during refueling outages is typical of industry experience.
 
Once the degraded coating areas were detected the applicant's CAP then either removed the
 
degraded coatings, repaired the degraded coatings, or deferred repair while maintaining the
 
total below the permitted amount subject to detachment from the substrate during a LOCA to
 
ensure post-accident operability of the ECCS suction strainers.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel the staff concludes that there is reasonable assurance that the
 
applicant's Protective Coating Monitoring and Maintenance Program will manage adequately
 
the aging effects and aging effects mechanisms identified in the ALRA for which this AMP is
 
credited.UFSAR and USAR Supplements. In ALRA Sections A1.1.40 and A2.1.38, the applicant provided the respective UFSAR and USAR supplements for the Protective Coating Monitoring
 
and Maintenance Program. The staff reviewed these sections and determined that the
 
information in the supplements provide adequat e summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Protective Coating Monitoring and Maintenance Program, the staff determined that those program elements for which the
 
applicant claimed consistency with the GALL Report are consistent with the GALL Report. In
 
addition the staff reviewed the exceptions and the associated justifications, and determined that
 
the AMP, with the exceptions, is adequate to manage the aging effects for which it is credited.
3-114 Also, the staff has reviewed the enhancements and confirmed that the implementation of the enhancements prior to the period of extended operation would result in the existing AMP being
 
consistent with the GALL Report AMP to which it was compared.The staff concludes that there
 
is reasonable assurance that the applicant has demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR and USAR supplements for this AMP and concludes that they provide an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.26  Fatigue Monitoring Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B3.2, the applicant described the Fatigue Monitoring Program, stating that this is an existing program that is consistent, with enhancements, with GALL AMP X.M1, "Metal Fatigue of Reactor Coolant
 
Pressure Boundary." The Fatigue Monitoring Program (FMP) manages the fatigue life of reactor
 
coolant pressure boundary components by tracking and evaluating key plant events. Events
 
were selected based upon plant-specific evaluations of the most fatigue-limited locations for
 
critical components, including those discussed in NUREG/CR-6260. The FMP monitors
 
operating transients to-date, calculates cumulative usage factors to-date, and directs
 
performance of engineering evaluations to devel op preventive and mitigative measures in order not to exceed the design limit on fatigue usage. The effects of reactor coolant environment will
 
be considered through the evaluation of, as a minimum, those components selected in
 
NUREG/CR-6260 using the appropriate environmental fatigue factors. The FMP provides an
 
analytical basis for confirming that the number of cycles established by the analysis of record
 
will not be exceeded before the end of the period of extended operation. In order to determine
 
cumulative usage factors (CUFs) more accurately, the FMP will implement FatiguePro fatigue
 
monitoring software.
Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report. Details of the staff's audit evaluation of this AMP are
 
documented in the Audit and Review Report. The staff reviewed the enhancements and the
 
associated justifications to determine whether the AMP, with the enhancements, remains
 
adequate to manage the aging effects for which it is credited.
The staff reviewed those portions of the FMP for which the applicant claimed consistency withGALL AMP X.M1 and found them consistent. The staff found the applicant's Fatigue Monitoring Program acceptable because it conforms to the recommended GALL AMP X.M1, "Metal Fatigue
 
of Reactor Coolant Pressure Boundary," with enhancements.In the ALRA, the applicant stated that FMP is consistent with GALL AMP X.M1 with enhancements. As stated In the ALRA, the enhancement in meeting the GALL Report
 
"preventive actions" program element revises app licable existing procedures to ensure that the procedures address the following:
The FMP will be enhanced with guidance for the use of the FatiguePro software package and updated methodology for environmental fatigue factors in
 
establishing updated fatigue life calculations for components.
 
((NMP1 Commitment 5, NMP2 Commitment 4) 3-115 In the ALRA, the applicant stated that the FMP will provide guidance for the use of FatiguePro and methodology for calculation of environmental fatigue factors.
As documented in the Audit and Review Report, t he staff evaluated the applicant's existing FMP and noted that it had identified correctly the need for more sophisticated methods to determine
 
adequate margin to fatigue limits. Improved calcul ation of environmental fatigue factors is also necessary. The staff determined that the use of FatiguePro is an appropriate method to improve
 
monitoring and, taken together with improved methodology for calculation of environmental fatigue factors, will provide assurance that fatigue damage will be adequately managed and
 
found this enhancement acceptable. These changes to the applicant's program will provide
 
assurance that the effects of aging will be adequately managed.
In addition in the ALRA, the applicant stated that enhancements in meeting the GALL Report "parameters monitored/inspected" program element revises procedures to address the following:
Safety relief valve actuations will be added to the list of key plant events (transients) that are monitored for NMP1 (NMP1 Commitment 11).
For the critical reactor vessel component locations, shown in Table 4.3-3 (NMP1) and Table 4.3-4 (NMP2) of the ALRA, additional usage will be added to the baseline CUF using one
 
of the methods described in ALRA Section 4.3. (NMP Commitment 6 and NMP2 Commitment 5)
Transients contributing to fatigue usage of the f eedwater system nozzles will be tracked by the FMP with additional usage added to the baseline CUF using the stress based fatigue described
 
in ALRA Section 4.3. (NMP Commitment 7 and NMP2 Commitment 7)
Develop a baseline CUF for the specified portions of the following systems: (1) feedwater/high pressure coolant injection, (2) core spray, (3) reactor water cleanup (piping inside the reactor
 
coolant pressure boundary), and (4) reactor recirculation (and associated shutdown cooling
 
systems lines). If the baseline CUF for a specifi ed portion of a system exceeds 0.4, the limiting locations may require additional monitoring to demonstrate compliance over the period of
 
extended operation. (NMP Commitment 8)
Assess the impact of the reactor coolant environment on a sample of critical component locations, including locations equivalent to those identified in NUREG/CR-6260, as part of the
 
FMP. These locations will be evaluated by applying environmental correction factors to existing and future fatigue analyses. (NMP1 Commitment 9 and NMP2 Commitment 10)
The FMP will track transients specific to the emergency cooling system with additional usage added to the baseline CUF for the emergency condensers as described in ALRA 4.3 (NMP1
 
Commitment 10)
Enhance the FMP to (1) ensure that fatigue usage of the torus attached piping and other torus locations does not exceed the design limits, add electromatic relief valve lifts as a transient to
 
be counted by the FMP and (2) add the two highest usage torus attached piping locations, the
 
12-inch core spray suction line fo core spray pump 111 that enters the torus at penetration XS-337 and the 3-inch containment spray line that enters the torus at penetration XS-326 as
 
fatigue monitoring locations. (NMP1 Commitment 11) 3-116 For the bounding locations for ASME Class 1 systems, transients contributing to fatigue usage will be tracked by the FMP with additional usage added to the baseline CUF using the design
 
cycle based fatigue method described in ALRA Section 4.3. If a bounding location with a current
 
CUF value less than or equal to 0.1 could have its CUR value exceed 0.1 before the end of the
 
period of extended operation, then the impact on the original break postulation calculations will
 
be assessed. (NMP2 Commitment 6)
If fatigue monitoring of ASME Class 1 piping (described in ALRA Section 4.3.2) indicates higher fatigue usage than expected, non-ASME Class piping will be evaluated for possible fatigue
 
concerns. (NMP2 Commitment 8)
Revise or evaluate the CUF evaluations for the shroud, core support plate and studs, and jet pumps to remove conservatism and/or encompass the period of extended operation (e.g., a
 
more extensive fatigue analysis of the jet pumps will be performed). (NMP2 Commitment 9)
For penetrations listed in ALRA Table 4.6-4, transients contributing to fatigue usage will be tracked by the FMP with additional usage added to the baseline CUF using the cycle based
 
fatigue method described in ALRA Section 4.3. (NMP2 Commitment 11)
In the ALRA, the applicant stated that safety relief valve actuations will be added to the list of key plant events monitored for NMP1. (Such act uations are already monitored for NMP2). The acceptability of this enhancement is discussed by the staff in SER Section 4 in the evaluation of
 
RAI 4.6.2-1.
The staff reviewed the rest of enhancements to the "parameters monitored/inspected" program elements of the GALL Report. Based on the review, the staff found that the additional
 
enhancements adequately monitors all plant transients that cause cyclic strains, which could
 
contribute to the fatigue usage factor. Therefore, the staff found these enhancements
 
acceptable.
Operating Experience. In ALRA Section B3.2, the applicant explained that it has reviewed both industry and plant-specific operating experience relating to the FMP. In instances where the
 
potential existed to exceed CUFs before the end of plant life, the engineering analyses showed
 
that actual margins were larger than initially estimated. A result of these fatigue evaluations was
 
the recognition that the FMP could benefit from the use of analytical fatigue software such as
 
FatiguePro. CRs written in 2003 identified opportunities for programmatic improvement. This led
 
to the establishment of a comprehensive FMP document, additional reviews of cycle records with an emphasis on NMP1, and a proposal for the implementation of fatigue analysis software.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel. At NMP there are components at or near the limit of the allowed cycle count established under the original TLAA. Evaluations confirm that for all locations, even the
 
most limiting, significant margin remains below a CUF=1.0 and the proposed program will
 
enable the applicant to keep within that limit.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel, the staff concludes that there is reasonable assurance that the
 
applicant's Fatigue Monitoring Program will manage adequately the aging effects and aging
 
effects mechanisms identified in the ALRA for which this AMP is credited.
3-117 UFSAR and USAR Supplements. In ALRA Sections A1.1.16 and A2.1.16, the applicant provided the respective UFSAR and USAR supplements for the Fatigue Monitoring Program.
 
The staff reviewed these sections and determined that the information in the supplements
 
provide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Fatigue Monitoring Program, the staff determined that those program elements for which the applicant claimed consistency
 
with the GALL Report are consistent with the GALL Report. Also, the staff has reviewed the
 
enhancements and confirmed that the implementat ion of the enhancements prior to the period of extended operation would result in the existing AMP being consistent with the GALL Report
 
AMP to which it was compared.The staff concludes that there is reasonable assurance that the
 
applicant has demonstrated that the effects of aging will be adequately managed so that the
 
intended functions 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 UFSAR and USAR
 
supplements for this AMP and concludes that they provide an adequate summary description of
 
the program, as required by 10 CFR 54.21(d).
3.0.3.2.27  Non-EQ Inaccessible Medium Voltage Cables Program (NMP2 Only)
Summary of Technical Information in the Amended Application
: In the NMP ALRA Appendix B, the applicant deleted Section B2.1.31, "Non-EQ Inaccessible Medium Voltage Cables Program,"
 
which was submitted in the original LRA. In ALRA Table 3.6.1, "Summary of Aging Management
 
Program for the Electrical and I&C Syst ems Components Evaluated In Chapter VI of NUREG-1801," the applicant stated that NMP1 has no inaccessible medium-voltage cables
 
within scope of license renewal. It also stated that NMP2 has no inaccessible medium-voltage
 
cables within the scope of license renewal, meeting the GALL Report program criteria requiring
 
aging management.
Staff Evaluation:
During its AMP and AM audits (weeks of September 19 and October 24, 2005) at NMPNS the staff reviewed engineering report NER-2E-032, "Identification of NMP2 Non-EQ
 
Inaccessible Medium Voltage Cables in the Sc ope of the License Renewal Program," and found at least one underground cable within the scope of license renewal requiring an AMP. Upon this
 
finding the staff requested the applicant whether there are other medium voltage cables (e.g.,
2kV to 35 kV) within the scope of license renewal for both NMP1 and NMP2 energized greater
 
than 25 percent of the time and located underground. The staff also requested that the applicant
 
specifically address in its response such cable in stalled for plant service water systems. In its letter dated December 1, 2005, the applicant stated that NMP1 has no inaccessible
 
medium-voltage cables within the scope of license renewal exposed to significant moisture
 
simultaneously with significant voltage. The only medium-voltage cables at NMP1 installed
 
underground and energized greater 25 percent of the time are used to power systems not within
 
the scope of license renewal or to power equipm ent not related to any plant systems. The applicant stated that the normal service water system pump motors are powered via
 
medium-voltage cables routed in cable trays, wall sleeves, or conduit installed inside the NMP1 turbine building and screen house, not underground. The emergency service water system
 
pump motors are powered via low-voltage (<2kV) cables and, therefore, these cables are not within the scope of the GALL XI.E3 program.
For NMP2 the applicant stated that it has inaccessible medium-voltage cables within the scope of license renewal as these cables are exposed to significant moisture simultaneously with 3-118 significant voltage when energized. The applicant identified 18 NMP2 cables (including service water pump cables) within the scope of license renewal and thus requiring an AMP to manage
 
aging effects. The service water system pump motors are powered via medium-voltage cables from the safety-related 4.16 kV switchgears. These cables are routed underground in duct lines.
 
Because these cables are installed underground and the service water system pump motors are
 
energized greater than 25 percent of the time these cables require aging management and thus are in the scope of the GALL XI.E3 program. In this letter the applicant also stated that it will
 
revise NER-2E-032 to identify medium-vol tage cables requiring aging management, develop anAMP and the plant-specific database for the GALL AMP XI.E3, and revise the ALRA to incorporate GALL AMP XI.E3. The staff found the applicant's response acceptable.
The applicant further stated in its letter dated December 1, 2005, that the Non-EQ Inaccessible Medium Voltage Cables Program is credited with managing aging effects through periodic
 
maintenance activities that minimize or prevent the exposure of in-scope cables to significant moisture or standing water. An adverse variation in environment would be significant if it could
 
increase the rate of aging of a component appreciably or have an immediate adverse effect on
 
operability. In this aging management program, periodic actions such as inspecting for water
 
collection in cable manholes, are taken to prevent cables from being exposed to significant
 
moisture. Additionally, in-scope medium-voltage cables exposed to significant moisture and significant voltage are tested for the condition of the conductor insulation. The specific type of
 
test would be power factor, partial discharge, or other testing both state of the art and consistent
 
with the latest industry guidance for detecting deterioration of the insulation system due to
 
wetting as described in EPRI TR-103834-P1-2. This program considers the technical
 
information and guidance of NUREG/CR-5643, IEEE Std. P1205, SAND96-0344, and EPRI
 
TR-109619.
In the ALRA Section B2.1.30 the applicant stated that the Non-EQ Inaccessible Medium-VoltageCables Program will be consistent with GALL AMP XI.E3 and the most recent industry and
 
regulatory precedence after enhancements are incorporated.
The specific testing for the in-scope medium-voltage cables associated with motors was detailed in procedure S-EPM-MPM-V080. Currently credited methods include polarization index
 
and hi-pot testing. The specific testing associated with the cables supplying the auxiliary
 
transformers will be detailed in an enhancement to procedure S-EPM-GEN-700. The staff reviewed procedure S-EPM-MPM-V080 and in discussi on with the applicant the staff expressed a concern that hi-pot testing may affect the lif e of medium-voltage cables adversely. In response to the staff's concern in the letter dated December 1, 2005, the applicant stated that it will
 
develop a new testing procedure specific to those cables requiring aging management under
 
this program. The specific type of test will be a proven test for detecting deterioration of the
 
insulation system as described in EPRI TR-103834-P1-2, power factor, partial discharge, or
 
other testing state of the art and consistent with the latest industry guidance at the time the test
 
is performed.
The applicant also made the following commitment:
NMP2 Commitment 38:
 
Enhance the Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program as follows: (1) Expand the scope of 3-119 the existing procedure to provide for manhole inspections and water removal, (2) develop a new testing procedure specific to those cables requiring aging management
 
under this program. The specific type of test performed will be a proven test for detecting deterioration of the insulation system due to wetting as described in EPRI
 
TR-103834-P1-2, such as power factor, partial discharge, or other testing that is both
 
state of the art and consistent with the latest industry guidance at the time the test is
 
performed, (3) establish requirement to test cables subject to aging management prior
 
to, and every 10 years during the period of extended operation, and (4) establish
 
maintenance requirement to inspect and remove water, as necessary, from manholes
 
serving cables subject to aging management. The inspection frequency will be based
 
upon actual plant experience with water accumulation in the manhole, but in any event, will be at least once every two years. The first inspection will be completed prior to the
 
period of extended operation.
The staff found the applicant's response and commitment acceptable because the testing methods, preventive actions taken, and the testing frequency are consistent with the updated GALL AMP XI.E3.
For the program elements of the Non-EQ Ina ccessible Medium-Voltage Cables Program statedby the applicant to be consistent with GALL AMP XI.E3 the staff determined that these conform to the corresponding GALL AMP XI.E3 program elements and acceptance criteria.
The applicant stated in December 1, 2005, letter that four enhancements to GALL ReportAMP XI.E3 program description, "parameters m onitored/inspected," "preventive actions," and "detection of aging effects" program element s will be implemented: Expand the scope of the existing manhole inspection procedure to include cables within the scope of the program.
 
Develop a new testing procedure specific to cables requiring aging management under this
 
program. The specific type of test performed w ill be power factor, partial discharge, or other testing state of the art at the time the test is performed and consistent with the latest industry
 
guidance for detecting deterioration of the insulation system as described in EPRI
 
TR-103834-P1-2. Establish maintenance requirements to test cables subject to aging
 
management prior to and every 10 years during t he period of extended operation. Establish a maintenance requirement to inspect for and remove water as necessary from manholes serving
 
cables subject to aging management. The inspection frequency will be based on actual plant
 
experience with water accumulation in the manhol e but in any event will be at least once every two years. The first inspection will be completed prior to period of extended operation.
The staff found the enhancements stated by the applicant acceptable because they will not adversely impact the ability of this AMP to manage the affects of aging. Periodic actions as
 
inspecting for water collection in cable manholes and draining water as needed are taken to
 
prevent cable exposure to significant moisture. These preventive actions are not sufficient to
 
assure that water is not trapped elsewhere in the raceways. In addition in-scope, medium
 
voltage cables exposed to significant moisture and significant voltage are tested for the
 
condition of the conductor insulation. The specific type of test will be power factor, partial
 
discharge, and polarization index as described in EPRI TR-103834-P1-2, or other state of the
 
art proven test for detecting deterioration of the insulation system due to wetting. For these
 
reasons the staff found the enhancements acceptable.
3-120 Operating Experience. The applicant stated in ALRA Section B2.1.31 that NMPNS has reviewed both industry and plant-specific operating experience relating to the Non-EQ Inaccessible
 
Medium Voltage Cables Program. Although infrequent there have been some failures of
 
medium voltage cables at other plants due to moisture intrusion. There have been no such
 
events at NMP2 but industry studies suggest that a regular cable testing program can detect
 
degradation of non-EQ inaccessible medium voltage cables before there is an insulation failure.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no
 
degradation not bounded by industry experience.
After review of the above operating experience and on discussions with the applicant's technical personnel the staff concludes that there is reasonable assurance that the applicant's Non-EQ
 
Inaccessible Medium-Voltage Cables Program adequately manage the aging effects and aging
 
effects mechanisms identified in the ALRA for which this AMP is credited.
USAR Supplement. In its letter dated December 1, 2005, the applicant proposed its USAR supplement for the non-EQ inaccessible medium voltage cables program in ALRA
 
Section A2.1.26 for NMP2. The applicant stated that the Non-EQ Inaccessible Medium Voltage
 
Cables Program provides reasonable assurance that the intended function of inaccessible
 
medium-voltage cables not subject to 10 CF R 50.49 environmental qualification requirements and exposed to adverse localized environments c aused by moisture while energized will be maintained consistent with the CLB through the period of extended operation. An adverse local
 
environment is a condition in a limited plant area significantly more severe than the specified
 
service environment for the cable. An adverse vari ation in environment is significant if it could appreciably increase the rate of aging of a component or have an immediate adverse effect on
 
operability. In this aging management program such periodic actions as inspecting for water
 
collection in cable manholes and draining water as needed are taken to prevent cable exposure
 
to significant moisture. Additionally, in-sc ope medium-voltage cables exposed to significant moisture and significant voltage are tested for the condition of the conductor insulation. The
 
specific type of test performed will be power factor, partial discharge as described in EPRI
 
TR-103834-P1-2, or other state of the art testing at the time the test is performed proven for
 
detecting deterioration of the insulation system due to wetting. The program considered the
 
technical information and guidance provided in applicable industry publications.
Enhancements to the non-EQ inaccessible medium voltage cables program include:
* Expand the scope of the existing procedures to manhole inspection and water removal.
* Develop new testing procedures specific to those cables requiring aging management under this program. The specific type of test will be power factor, partial discharge, or
 
other testing both state of the art and consistent with the latest industry guidance at the
 
time the test is performed proven for detecting deterioration of the insulation system due
 
to wetting as described in EPRI-TR-103834-P1-2.
* Establish maintenance to test cables subject to aging management prior to and every 10 years during the period of extended operation.
* Establish maintenance requirement to inspect for and remove water as necessary from manholes serving cables subject to aging management. The inspection frequency will be 3-121 based on actual plant experience with water accumulation in the manhole but in any event will be at least once every two years. The first inspection will be completed prior to
 
the period or extended operation.
Enhancements will be implemented prior to entering the period of extended operation.
The staff reviewed these USAR supplements and confirmed that they provide an adequate summary description of the program as identified in the SRP-LR FSAR supplement table and as
 
required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicant's Non-EQ Inaccessible Medium-Voltage Cables program the staff deter mined that those program elements for which the applicant claimed consistency with the GALL Report are indeed consistent. In addition the
 
staff reviewed the enhancements to the GALL Report and confirmed that the implementation of
 
enhancements prior to the period of extended operation would make the AMP consistent with
 
the GALL Report AMP to which it was compared.The staff concludes that there is reasonable
 
assurance that the applicant has demonstrated that the effects of aging will be adequately
 
managed so that the intended function will be maintained consistently with the CLB during the
 
period of extended operation as required by 10 CFR 54.21(a)(3). The staff also reviewed the
 
proposed USAR supplements for this AMP and concludes that they provide an adequate
 
summary description of the program as required by 10 CFR 54.21(d).3.0.3.3  AMPs That Are Not Consistent with or Not Addressed in the GALL Report In ALRA Appendix B, the applicant identified that the following AMPs were plant-specific:
* Preventive Maintenance Program
* Systems Walkdown Program
* Non-Segregated Bus Inspection Program
* Fuse Holder Inspection Program
* Non-EQ Electrical Cable Metallic Connections Inspection Program
* Wooden Power Pole Inspection Program (NMP2 Only)
* Torus Corrosion Monitoring Program (NMP1 Only)
For AMPs that are not consistent with or not addressed by the GALL Report, the staff performed a complete review of the AMPs to determine if they were adequate to monitor or manage aging.
 
The staff's review of these plant-specific AMPs is documented in the following sections of this
 
SER.3.0.3.3.1  Preventive Maintenance Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.32, the applicant described the Preventive Maintenance Program, stating that this is an existing, plant-specific program. The Preventive Maintenance Program consists of the appropriate ten
 
elements described in SRP-LR Appendix A.
The Preventive Maintenance Program manages aging effects for SSCs within the scope of licence renewal. The program provides for
 
performance of various maintenance activi ties on a specified frequency based on vendor recommendation and operating experience.
3-122 The key elements of aging management activities in the Preventive Maintenance Program are described. The applicant's evaluations of each key element against the appropriate ten
 
elements defined in SRP-LR Appendix A also are provided.
The Preventive Maintenance Program manages aging effects of SSCs within the scope of license renewal not managed by other AMPs. The scope of the program includes but is not limited to valve bodies, heat exchangers, expans ion joints, tanks, ductwork, fan/blower housings, dampers, and pump casings.
Additional details of the program scope are addre ssed in the basis document for the Preventive Maintenance Program kept onsite. With regard to the "preventive actions" element of the
 
program the applicant stated that although routine maintenance is largely preventive only the
 
condition monitoring aspects of Preventive Maintenance Program activities are credited for
 
license renewal. For example, when a pipi ng system is opened to conduct preventive maintenance on a valve a visual inspection of the valve body or piping may be specified. Such
 
activities do not prevent aging effects but detect degraded conditions that affect the ability of the
 
component to perform its intended function. C onsequently, there are no specific preventive actions associated with this program.
The applicant states that aging effects of concern will be detected by visual inspection and examination of component surfaces for evidence of defects and age-related degradation.
With regard to acceptance criteria the applicant states that the Preventive Maintenance Program establishes specific acceptance criteria for each component inspected. The
 
acceptance criteria are related to the aging effects requiring management and are dependent
 
on each individual inspection or examination of the aging effect managed.
The program documentation has specific requirem ents for CRs in the CAP. The NMPNS Quality Assurance Program Topical Report documents a commi tment to the corrective action criteria of 10 CFR Part 50. The CAP includes the detection and correction of conditions adverse to quality
 
and the detection, cause determination, correction, and prevention of recurrence of conditions
 
significantly adverse to quality.
The Quality Assurance Program Topical Report documents the confirmation process for NMPNS under the corrective action criterion. At NMPNS the confirmation process is
 
implemented through corrective action effectiv eness reviews and is performed for conditions significantly adverse to quality and selected hardware-related conditions adverse to quality. The
 
CAP includes but is not limited to SR, NSR, and fire protection SSCs. Therefore, those SSCs
 
within the scope of license renewal are addressed as part of the current CAP.
The applicant states that NMPNS has reviewed both industry and plant-specific operating experience relating to the Preventive Maintenanc e Program as part of a process to optimize maintenance practices. Review of plan-specific operating experience revealed CRs initiated
 
after Preventive Maintenance Program examinat ions. In cases where age-related degradation was detected the reported conditions (e.g., corrosion of motor-operated valves, piping, heat
 
exchanger internals) were resolved through implem entation of the work order process prior to loss of an intended function.
3-123 The Preventive Maintenance Program is adjusted c ontinually to account for industry experience and research. As additional operating experience is obtained lessons learned are used to adjust
 
this program as needed.
The applicant states that there are no exceptions to the SRP-LR and that the enhancements to the Preventive Maintenance Program encompass revi sions to existing activities credited for license renewal to ensure that aging effects are discovered and evaluated. These
 
enhancements expand the scope of the Prevent ive Maintenance Program to encompass activities for certain additional components requiring aging management and explicitly define
 
the aging management attributes including syst ems and the component types and commodities.
Other elements are: (1) preventive actions which would be revised to list activities credited for aging management, (2) the element "parameters monitored/inspected" would be revised to specifically list parameters monitored, (3) t he element "detection of aging effects" would be reviewed to specifically list the aging effects, (4) the element "monitoring and trending" would
 
establish a requirement that inspection data be monitored, and (5) the element "acceptance
 
criteria" would be revised to establish detailed specific acceptance criteria.
According to the applicant the enhancements would be completed prior to the period of extended operation. The applicant stated that the Preventive Maintenance Program has been
 
effective in maintaining the intended functions of long-lived passive SSCs. The effectiveness of
 
the Preventive Maintenance Program is also reflected in the level of system/equipment availability documented by maintenance rule periodic assessments.
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B2.1.32, regarding the applicant's demonstration of the Preventive
 
Maintenance Program to ensure that the effects of aging, as discussed above, will be
 
adequately managed so that the intended functions will be maintained consistent with the CLB
 
for the period of extended operation.
The staff reviewed the Preventive Maintenance Program against the AMP elements found in SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 and focused on how the program manages
 
aging effects through the effective incorporation of 10 elements (i.e., program scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and
 
operating experience).
The applicant indicated that the corrective actions, confirmation process, and administrative controls are parts of the site-controlled quality assurance program. The staff's evaluation of the
 
quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements
 
are discussed below.  (1)Scope of Program - The applicant stated in ALRA Section B2.1.32 that the Preventive Maintenance Program manages aging effects of many SSCs within the scope of license
 
renewal not managed by other AMPs. The scope of the program includes but is not
 
limited to valve bodies, heat exchangers, expans ion joints, tanks, ductwork, fan/blower housings, dampers, and pump casings.
3-124 Additional details of the program scope are discussed in the basis document for the Preventive Maintenance Program. The applicant states that there are no exceptions to
 
the SRP-LR and the enhancements to the Preventive Maintenance Program revise
 
activities credited for license renewal to ensure detection and evaluation of aging effects.
 
These enhancements would expand the Preventiv e Maintenance Program to activities for certain additional components requiring aging management and define the aging
 
management attributes of systems and t he component types and commodities included in the program.
The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1.
The staff concludes that this program attribute is acceptable.  (2)Preventive Actions - The applicant stated in ALRA Section B2.1.32 that although routine maintenance is largely preventive in nature only the condition monitoring aspects of
 
Preventive Maintenance Program activities are credited for license renewal. For
 
example, when a piping system is opened to conduct preventive maintenance on a valve a visual inspection of the valve body or pi ping may be specified. Such activities do not prevent aging effects but will detect degraded conditions affecting the ability of the
 
component to perform its intended function. Consequently, there are no specific
 
preventive actions for this program. Enhancement s to this element would specifically list those activities credited for aging management. Additional details of this element are
 
discussed in the basis document for the Preventive Maintenance Program.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.2. The staff concludes that this program attribute is acceptable.
In RAI B2.1.32-1 dated November 17, 2004, the staff stated that the descriptions of several elements in the Preventive Maintenance Program were too brief and general for the staff to
 
review the program's effectiveness and adequacy. Therefore, the staff requested that the
 
applicant provide more specific detailed information for the following four elements of the AMP
 
according to the guidelines of SRP-LR Appendix A.  (1)Element (3) - Parameters Monitored/Inspected    (2)Element (4) - Detection of Aging Effects (3)Element (5) - Monitoring and Trending (specified schedule)
  (4)Element (6) - Acceptance Criteria In addition the staff requested the applicant to provide specific information related to these four listed elements of the Preventive Maintenance Program for the management of aging effects of two specific components, (1) piping and fittings in the NMP2 Control Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1 Radioactive Waste System (original
 
LRA Table 3.3.2.A-14), to demonstrate the effectiveness and adequacy of this Preventive
 
Maintenance Program.
The applicant provided its response by letter dated December 21, 2004, and the staff's evaluation of elements (3) through (6) is as follows.
 
3-125  (3)Parameters Monitored/Inspected - In the original LRA Section B2.1.32, the applicant stated that inspection and testing activities monitor various parameters, including
 
surface condition, for evidence of defects and age-related degradation.
In its response to the staff RAI B2.1.32-1 dated November 17, 2004, with regard to this element, the applicant stated that there are no prevention, mitigation, or performance
 
monitoring activities in the Preventive Maintenance Program credited for license
 
renewal. Rather, condition monitoring activities inspect for visual signs of degradation or test for leaks. Surface conditions of components are monitored through visual inspection
 
and examination for evidence of defects and age-related degradation. Components in
 
selected portions of systems are monitored through visual inspection. The inspections
 
detect aging effects which if left unmanaged would lead to degradation of the
 
components' intended functions. Examples of components, inspections, and parameters monitored under the Preventive Maintenance Program are as follow: UnitComponent(s)InspectionType/ParameterParameterProcedure1Fuel Pool heat exchanger tubes and
 
tube sheets Visual/Condition Evidence of various forms of corrosions N1-MM-0054-4051Various carbon steel valve internals and
 
externals Visual/Condition Evidence of Various forms of internal
 
and/or external
 
corrosion N1-MM-GEN-2001Reactor Building andDry Well Sump Pump Visual/Condition Evidence of various forms of internal
 
corrosion N1-MM-GEN-0051RX Building Emergency Ventilation and Control
 
Room Emergency Ventilation Fan Visual/Condition Evidence of corrosion of carbon steel;
 
cracking, hardening
 
shrinkage and loss of strength of polymers N1-MM-GEN-5511Unit 1 Reactor BuildingCharcoal Filter Housing Visual/Condition Evidence of general corrosion of housing
 
internalsN1-TSP-202-001113.8 & 4.16KV Motors Visual/Condition Presence of motor cooler fouling S-EMP-GEN-0812Ventilation Heaters Visual/Condition Presence of general corrosion on heater
 
internals N2-EPM-GEN-V7862Condition and various forms of corrosion2Motor
 
Operated Actuators and
 
Dampers Visual/Condition Internal inspection for general corrosion of
 
damper and actuator N2-EPM-GEN-V786 UnitComponent(s)InspectionType/ParameterParameterProcedure 3-1262Air Handling Unit Cooling Cools Visual/Condition &
Test/Refrigerant
 
Leakage Inspection of signs of fouling, and testing for
 
leakage NS-MPM-GEN-SA562
& N2-MPM-HVC-V554 Most Preventive Maintenance Program im plementing procedures require enhancement to include/annotate parameters credited for aging management.
The applicant also provided the specific inspection methods for detection of aging effects related to two specific components, (1) piping and fittings in the NMP2 Control Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1 Radioactive Waste System (original LRA Table 3.3.2.A-14), to demonstrate the
 
effectiveness and adequacy of this Preventive Maintenance Program.
The staff confirmed that after completion of the enhancements this program element will satisfy the criterion of SRP-LR Section A.1.2.3.3. The staff concludes that this program
 
attribute is acceptable.  (4)Detection of Aging Effects - In the original LRA Section B2.1.32 the applicant stated that the aging effects of concern will be detected by visual inspection and examination of
 
component surfaces for evidence of defects and age-related degradation.
In response to RAI B2.1.32-1 on this element the applicant stated that:
The aging effects requiring management for the components within the scope of the Preventive Maintenance Program are detected by visual
 
inspection and examination of surfaces of components for evidence of
 
defects and age-related degradation. The activities that are performed to
 
detect aging effects requiring management are identified in the specific
 
PM procedures that perform the PM. The procedures are developed
 
based on vendor recommendations and operating experience that forms
 
the basis for the inspections performed and the frequency of the
 
inspections such that aging effects are detected prior to a loss of the
 
components' intended functions. NMPNS administrative procedures
 
provide for overall control of the Preventive Maintenance Program and
 
identification of how PMs are to be established, documented, scheduled, and optimized for the benefit of equipment and system reliability. Most
 
Preventive Maintenance Program procedures will require an
 
enhancement to include/annotate the aging effect being detected.
The applicant also provided the specific inspection methods for detection of the aging effects related to two specific components, (1) piping and fittings in the NMP2 Control
 
Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1
 
Radioactive Waste System (original LRA Table 3.3.2.A-14), to demonstrate the
 
effectiveness and adequacy of this Preventive Maintenance Program.
3-127 The staff confirmed that after completion of the enhancements this program element will satisfy the criterion of SRP-LR Section A.1.2.3.4. The staff concludes that this program
 
attribute is acceptable.  (5)Monitoring and Trending - In original LRA Section B2.1.32 the applicant stated that the Preventive Maintenance Program is condi tion-monitoring performed on a specified schedule. After inspection results are documented they are reviewed and evaluated.
In response to RAI B2.1.32-1 on this element the applicant stated:
The Preventive Maintenance Program is a condition-monitoring program executed on a specified schedule. Results of the tasks performed are
 
documented in the corresponding implementing procedures. These
 
procedures include a review and evaluation of the results. The Preventive
 
Maintenance Program requires an enhancement to specifically include
 
monitoring and trending, as appropriate, for age-related degradation.. The applicant also provided the specific monitoring and trending attributes for the
 
management of aging effects related to the two specific components, (1) piping and
 
fittings in the NMP2 Control Building HVAC System (original LRA Table 3.3.2.B-9) and
 
(2) valves in the NMP1 Radioactive Waste System (original LRA Table 3.3.2.A-14), to
 
demonstrate the effectiveness and adequacy of this Preventive Maintenance Program.
The staff confirmed that after completion of the enhancements this program element will satisfy the criteria of SRP-LR Section A.1.2.3.5. The staff concludes that this program
 
attribute is acceptable.
 
    (6)Acceptance Criteria - In the original LRA Section B2.1.32 the applicant stated that the Preventive Maintenance Program establishes specific acceptance criteria for each
 
component inspected. The acceptance criteria are related to the aging effects requiring
 
management and dependent on each individual inspection and examination of the aging
 
effect managed.
In its response to RAI B2.1.32-1, dated December 21. 2004, the applicant stated:
Acceptance criteria for visual inspection and examination of components are provided in the Preventive Maintenance Program implementing procedures. The acceptance criteria are related to the aging effects
 
requiring management and are dependent on each individual inspection
 
and examination considering the aging effect being managed.
 
Implementing procedures will be enhanced to include more specific and
 
detailed acceptance criteria, as appropriate. This program attribute will be
 
consistent with the generic attribute description in Appendix A of
 
NUREG-1800 upon program enhancements.
The applicant also provided the acceptance criteria for the management of aging effects related to the two specific components, (1) piping and fittings in the NMP2 Control
 
Building HVAC System (original LRA Table 3.3.2.B-9) and (2) valves in the NMP1 3-128 Radioactive Waste System (original LRA Table 3.3.2.A-14), to demonstrate the effectiveness and adequacy of this Preventive Maintenance Program.
The staff confirmed that after completion of the enhancements this program element will satisfy the criteria of SRP-LR Section A.1.2.3.6. This information has been incorporated
 
in the ALRA. The staff concludes that this program attribute is acceptable.  (10)Operating Experience - The applicant stated in ALRA Section B2.1.32 that it has reviewed both industry and plant-specific operating experience relating to the Preventive
 
Maintenance Program as part of a process to optimize maintenance practices. Review of
 
plan-specific operating experience revealed CRs initiated after Preventive Maintenance
 
Program examinations. Where age-related degradation was detected the reported
 
conditions (e.g., corrosion of motor-operated valves, piping, heat exchanger internals)
 
were resolved through implementation of the work order process prior to loss of an
 
intended function.
The Preventive Maintenance Program is adjusted continually to account for industry experience and research. With additional operating experience lessons learned will be
 
used to adjust this program as needed.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.10. The staff concludes that this program attribute is acceptable.
The applicant stated that enhancements to the Preventive Maintenance Program will be made to revise existing procedures. These enhancements would provide the level of detail and
 
specificity needed for staff review of the Preventive Maintenance Program. They would affect
 
the main program elements including "scope of program," "preventive actions," "parameters monitored," "detection of aging effects," "monitoring and trending," and "acceptance criteria."
 
These enhancements are scheduled to be completed prior to the period of extended operation.
 
The staff views these as major enhancements which would require review and approval prior to
 
implementation of the Preventive Maintenance Program.
In RAI B2.1.32-2, dated November 17, 2004, the staff requested that the applicant provide a commitment that these enhancements would be completed on a schedule of sufficient time for
 
staff review and approval prior to the period of extended operation.
In its response, by letter dated December 21, 2004, the applicant stated that this staff concern also was raised during the review of the AMPs by the audit team and the audit question was
 
documented as AMP Issue 30 of the Audit and Review Report. The applicant provided the
 
response that was given to Issue 30 as follows:
As with any commitment NMPNS makes to the NRC, the resolution and/or implementation are subject to review by the NRC. Specifically for new aging
 
management programs (AMP), the NRC can utilize Inspection Procedure 71003
 
Post-Approval Site Inspection for License Renewal, to verify that outstanding
 
commitments have been met. This procedure also includes specific wording
 
whereby the assistance of NRR/DRIP/RLEP can be utilized to ensure the
 
licensee commitments have been met. Currently there is no specific notification
 
to the NRC required when a commitment has been satisfied. Consistent with the 3-129 industry, NMP would prefer that any review of new AMPs be conducted as part of the inspection process.
The applicant further stated that:
The commitment to enhance appropriate maintenance procedures that exist within the Preventive Maintenance Program is made commensurate with the
 
inclusion of statements to that effect within Appendices A and B of the [original]
 
LRA. Enhancements will be review ed and approved using approved NMPNS administrative procedures. Once made, all maintenance activity enhancements
 
will be readily available for review by the NRC prior to the period of extended
 
operation.
The staff reviewed the applicant's response and found that the applicant has provided adequate assurance for the completion as well as review and approval of the enhancements prior to the
 
period of extended operation. Enhancements to the Preventive Maintenance Program are NMP1 Commitment 29 and NMP2 Commitment 27. Based on the review and information
 
provided in the ALRA the staff concern in RAI B2.1.32-2 is resolved.
UFSAR and USAR Supplements. In ALRA Sections A1.1.30 and A2.1.30, the applicant provided the respective UFSAR and USAR supplements for the Preventive Maintenance
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provide adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Preventive Maintenance Program, the staff concludes that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR and USAR supplements for this AMP and concludes that they provide an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.3.2  Systems Walkdown Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.33, the applicant described the Systems Walkdown Progr am, stating that this is an existing, plant-specific program. The Systems Walkdown Program manages aging effects for accessible external surfaces of systems and components within the scope of license renewal. The aging effects of concern are material degradation and loss of material from external surfaces of
 
pumps, valves, piping, bolts, heat exchangers, tanks, HVAC components, and other
 
components. The program also identifies adverse conditions that can lead to aggressive
 
environments for systems or components within t he scope of license renewal. Program activities include system engineer walkdowns (i.e., field evaluations of system components to assess material condition), documentation and evaluation of inspection results, and appropriate
 
corrective actions.
In the ALRA, the applicant stated that the key elements of aging management activities used in the Systems Walkdown Program are the results of an evaluation of each key element against the appropriate ten elements described in SRP-LR Appendix A with enhancements that include 3-130 revisions to existing activities credited for license renewal to ensure the applicable aging effects are detected and evaluated. Enhancements are scheduled for completion prior to the period of
 
extended operation.
The applicant stated that recording and reporting visually detectable degradation have been parts of good engineering practice at NMPNS for many years and will continue under the Systems Walkdown Program, which has been effective in maintaining the intended functions of
 
long-lived passive SSCs. The applicant stated t hat the Systems Walkdown Program has been enhanced since its inception and further improvem ents will be implemented prior to the period of extended operation.
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B2.1.33, regarding the applicant's demonstration of the Systems
 
Walkdown Program to ensure that the effects of aging, as discussed above, will be adequately
 
managed so that the intended functions will be maintained consistent with the CLB for the
 
period of extended operation.
In RAI B2.1.33-1 dated November 17, 2004, the staff noted that the applicant stated in the original LRA that this System Walkdown Progr am manages aging effects for accessible external surfaces of selected SSCs within the scope of license renewal. It was not clear to the staff
 
whether all carbon steel components listed in the program or just the samples are covered by
 
this AMP. Therefore, the staff requested that the applicant clarify the reference to "selected
 
SSCs" within the scope of license renewal. Furthermore, with respect to the program description
 
paragraph of Section B2.1.33, the staff requested that the applicant clarify the phrase "other
 
carbon steel components" and explain why "mechanical penetrations" are excluded from
 
components listed in the program description.
In its response by letter dated December 17, 2004, the applicant listed NMP1 and NMP2 systems which include components within the scope of license renewal and which credit the
 
Systems Walkdown Program for managing the aging of external surfaces. The applicant stated that because not all components in a system may be in-scope the term "selected" is used to
 
differentiate between those in-scope and those out-of-scope. For each of the systems listed the
 
determination of which component types are "selected" is shown in the applicable original LRA
 
aging management review section. The applicant also stated that there are no structures within
 
the scope of license renewal that credit t he Systems Walkdown Program for managing aging effects. The applicant stated that the "Program Description" paragraph of the original LRA Section B2.1.33 includes the statement, "The specific aging effect of concern is loss of material
 
from external surfaces of... other carbon steel components." This phrase is intended to capture
 
generically system components or subcomponents not specifically listed. Examples of "other carbon steel components" are flanges, tees, reducers, and pipe caps. Mechanical penetrations
 
at NMP1 and NMP2 are managed under the Stru ctures Monitoring Program and the ASMESection XI ISI (Subsections IWE and IWL) Pr ograms rather than by the Systems Walkdown Program. The applicant noted that for the NMP1 Reactor Vessel Instrumentation System although the Systems Walkdown Program is credited correctly in original LRA Section 3.1.2.A.3 it was omitted inadvertently from original LRA Table 3.1.2.A-3 (page 3.1-54 of the revised Section 3.1 3-131 submitted by NMPNS letter NMP1L 1892 dat ed December 6, 2004). The correction to Table 3.1.2.A-3 is provided in the applicant's December 17, 2004, submittal. The staff found the
 
applicant's response acceptable. Therefore, the staff's concern described in RAI B2.1.33-1 is
 
resolved.The staff evaluated key elements of aging managem ent activities of the Systems Walkdown Program against the appropriate ten elements described in SRP-LR Appendix A, including the
 
enhancements to the existing activities. The staff reviewed the Systems Walkdown Program
 
against the AMP elements found in SRP-LR Section A.1.2.3, and SRP-LR Table A.1-1 and
 
focused on how the program manages aging effects through the effective incorporation of 10
 
elements (i.e., "program scope," "preventive actions,"
"parameters monitored or inspected,"
"detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions,"
 
"confirmation process," "operating experience," and "operating experience").
The applicant indicated that the "corrective actions," "confirmation process," "and "administrative controls," are parts of the site-controlled quality assurance program. The staff's evaluation of the
 
quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements
 
are addressed here.    (1)Scope of Program - In the original LRA Section B2.1.32, the applicant stated that the scope of the Systems Walkdown Program is a ccessible external surfaces of structures and components within the scope of license renewal and subject to AMR. The
 
inspections will look for loss of material, material degradation, and leakage.
In RAI B2.1.33-1 dated November 17, 2004, the staff requested that the applicant identify the systems and structures within the scope of license renewal to which this
 
AMP applies at NMPNS.
In its December 17, 2004, response to RAI B2.1.33-1 the applicant listed NMP1 andNMP2 systems as follow:
NMP1 Systems
* Compressed Air System
* Control Room Heating, Ventilating, and Air Conditioning (HVAC)
* Control Rod Drive
* Core Spray System
* Condensate System
* Containment System
* Containment Spray
* City Water System
* Reactor Water Cleanup
* Emergency Diesel Generator
* Emergency Cooling
* Fire Detection and Protection
* Spent Fuel Pool Filtering and Cooling
* Feedwater/high Pressure Coolant Injection
* Hydrogen Water Chemistry
* Main Generator and Auxiliary System 3-132
* Main Steam
* Miscellaneous Non-contaminated Vents and Drains
* Neutron Monitoring
* Reactor Building HVAC
* Reactor Building Closed Loop Cooling
* Radwaste Building Hvac
* Radwaste System
* Reactor Vessel Instrumentation
* Shutdown Cooling
* Sampling System
* Service Water
* Turbine Building Hvac
* Turbine Building Closed Loop Cooling Water
 
NMP2 Systems
* Alternate Decay Heat Removal System
* Compressed Air System
* Reactor Building Closed-loop Cooling Water
* Containment Atmosphere Monitoring
* Condensate System
* Main Condenser Air Removal
* Primary Containment Purge
* High-pressure Core Spray
* Low-pressure Core Spray
* Domestic Water System
* Air Startup - Standby Diesel Generator
* Standby Diesel Generator Fuel Oil Storage and Transfer
* Generator Standby Lube Oil System
* Standby Diesel Generator Protection (Generator) System
* Floor and Equipment Drains
* Engine-driven Fire Pump - Fuel Oil
* Fire Protection Halon
* Cardox Fire Protection - Low Pressure C0 2
* Fire Protection - Water
* Feedwater System
* Standby Gas Treatment
* Design Basis Accident (DBA) Hydrogen Recombiner
* Control Building Air-conditioning
* Glycol Heating
* Hot Water Heating
* Auxiliary Service Building Air-conditioning
* Control Building Chilled Water
* Chilled Water - Ventilation
* Diesel Generator Building Ventilation
* Reactor Building Ventilation
* Yard Structure Ventilation
* Reactor Core Isolation Cooling
* Reactor Vessel Instrumentation 3-133
* Main Steam
* Moisture Separator and Reheater System
* Makeup Water System
* Reactor Recirculation System
* Residual Heat Removal
* Reactor Pressure Vessel
* Spent Fuel Pool Cooling and Cleanup
* Process Sampling System
* Service Water
* Seal Water System
* Reactor Water Cleanup For the enhancement of this AMP the applicant stated in the original LRA that it will state the aging management attributes explic itly, including the systems and component types/commodities included in the program.
In the updated response to RAI B2.1.33-1 dated August 12, 2005, the applicant pointed out that portions in its previous response had been superseded by responses dated July
 
14, 2005, to staff RAIs 2.1-4, 2.2-3 and 3.1.2.C.4-1 dated February 23, 2005. The
 
complete revised list of NMP1 and NMP2 systems that credit the System Walkdown Program for aging management is provided here and also has been incorporated in the
 
ALRA section number (italics indicate added systems).
NMP1 System:ALRA Section
* Circulating Water3.3.2.A.1
* City Water3.3.2.A.2
* Compressed Air3.3.2.A.3
* Condensate and Condensate Transfer3.4.2.A.1
* Condenser Air Removal and Off-gas3.4.2.A.5
* Containment Spray3.2.2.A.1
* Containment System3.3.2.A.4
* Control Rod Drive3.1.2.A.5
* Control Room HVAC3.3.2.A.5
* Core Spray3.2.2.A.2
* Diesel Generator Building Ventilation3.3.2.A.6
* Electric Steam Boiler 3.3.2.A.24
* Emergency Cooling3.2.2.A.3
* Emergency Diesel Generator3.3.2.A.7
* Feedwater/high Pressure Coolant Injection3.4.2.A.2
* Fire Detection and Protection3.3.2.A.8
  * (Hydrogen Water Chemistry - deleted from list)
* Liquid Poison3.3.2.A.10
* Main Generator and Auxiliary3.4.2.A.3
* Main Steam3.4.2.A.4
* Main Turbine and Auxiliary3.4.2.A.6
* Misc Non-contaminated Vents & Drains            3.3.2.A.11
* Moisture Separator Reheater Steam3.4.2.A.7
* Neutron Monitoring3.3.2.A.12 3-134
* Radwaste Building HVAC3.3.2.A.13
* Radwaste System3.3.2.A.14
* Reactor Building Closed Loop Cooling3.3.2.A.15
* Reactor Building HVAC3.3.2.A.16
* Reactor Vessel Instrumentation3.1.2.A.3
* Reactor Recirculation System3.1.2.A.4
* Reactor Water Cleanup3.3.2.A.17
* Sampling System3.3.2.A.18
* Service Water3.3.2.A.19
* Shutdown Cooling3.3.2.A.20
* Spent Fuel Pool Filtering and Cooling3.3.2.A.21
* Turbine Building Closed Loop Cooling3.3.2.A.22
* Turbine Building HVAC3.3.2.A.23 NMP2 Systems:
ALRA Section
* Air Startup - Standby Diesel Generator3.3.2.B.1
* Alternate Decay Heat Removal3.3.2.B.2
* Auxiliary Boiler3.3.2.B.33
* Auxiliary Service Building Hvac            3.3.2.B.3
* Circulating Water            3.3.2.B.34  * (Chilled Water Ventilation - deleted from list)
* Compressed Air3.3.2.B.5
* Condensate System3.4.2.B.2
  * (Containment Atmosphere Monitoring - deleted from list)
* Control Building Chilled Water3.3.2.B.8
* Control Building HVAC3.3.2.B.9
* Control Rod Drive3.1.2.B.5
* Diesel Generator Building Ventilation3.3.2.B.10
* Domestic Water3.3.2.B.11
* Engine-driven Fire Pump Fuel Oil3.3.2.B.12
* Extraction Steam & Feedwater Heater Drains3.4.2.B.6
* Feedwater 3.4.2.B.3
* Fire Detection and Protection3.3.2.B.13
* Floor and Equipment Drains3.3.2.B.14
* Generator Standby Lube Oil3.3.2.B.15
  * (Glycol Heating - deleted from list)
* High Pressure Core Spray3.2.2.B.2
* Hot Water Heating3.3.2.B.17
* Hydrogen Recombiner System3.2.2.B.1
* Low Pressure Core Spray3.2.2.B.3
* Main Condenser Air Removal3.4.2.B.1
* Main Steam3.4.2.B.4
* Makeup Water3.3.2.B.18
* Moisture Separator and Reheater3.4.2.B.5
* Primary Containment Purge3.3.2.B.20
  * (Process Sampling - deleted from list)
* Radioactive Liquid Waste Management3.3.2.B.36
* Reactor Building Closed Loop Cooling3.3.2.B.22 3-135
* Reactor Building HVAC3.3.2.B.23
* Reactor Core Isolation Cooling3.2.2.B.4
  * (Reactor Pressure Vessel - deleted from list)
* Reactor Pressure Vessel Instrumentation3.1.2.B.3
  * (Reactor Recirculation - deleted from list)
* Reactor Water Cleanup3.3.2.B.24
* Residual Heat Removal3.2.2.B.5
* Roof Drainage System3.3.2.B.37
* Sanitary Plumbing and Drains3.3.2.B.38  * (Seal Water - deleted from list)
* Service Water3.3.2.B.26
* Spent Fuel Pool Cooling and Cleanup3.3.2.B.27
* Standby Diesel Generator Fuel Oil3.3.2.B.28
* Standby Diesel Generator Protection3.3.2.B.29
* Standby Gas Treatment3.2.2.B.6
* Turbine Building Closed Loop Cooling3.3.2.B.40
* Turbine Main System3.4.2.B.7
* Water Treatment3.3.2.B.35
* Yard Structures Ventilation3.3.2.B.31 The staff reviewed the amended information in the ALRA and considers the scope of the program to be defined clearly and acceptable. Therefore, the staff's concern described
 
in RAI B2.1.33-1 is resolved.
The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1.
The staff concludes that this program attribute is acceptable.  (2)Preventive Actions - In the original LRA Section B2.1.33 the applicant stated that the Systems Walkdown Program mitigates degradation through regular inspection of
 
in-scope components and detection of degraded conditions that could affect the ability of
 
components to perform intended functions. There are no specific preventive actions
 
associated with this program other than the detection of the aging effects of concern
 
before damage to a component or pressure boundary occurs. The staff concurred that
 
no preventive actions are required for this condition monitoring program.
The staff also reviewed ALRA and confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.2. The staff concludes that this program attribute is
 
acceptable.
 
  (3)Parameters Monitored/Inspected - In original LRA Section B2.1.33 the applicant stated that system engineers conduct visual inspections of assigned SSCs and document the
 
presence of corrosion and other signs of deterioration.
In RAI B2.1.33-2 dated November 17, 2004, the staff stated that in the "parameters monitored/inspected" program element "other signs of deterioration" was not clear.
 
Therefore, the staff requested that the applicant describe those other aging effects and
 
explain how they can be detected.
3-136 In its December 17, 2004, response to RAI B2.1.33-2 the applicant stated that the phrase "other signs of deterioration" is intended to encompass the condition of coatings (material degradation), leakage and indications of leakage as stated under the "Enhancements" heading of original LRA Section B2.1.33, as well as cracking, elastomer degradation, and weathering. The applicant stated that in incorporating this
 
enhancement into the implementing procedure it intends to utilize the guidance of EPRI
 
reports on identification of aging as part of the training of system engineers. These
 
industry guidelines provide the basis for the identification of aging effects and will
 
provide the system engineers with the necessary knowledge to identify "other signs of
 
deterioration." (EPRI reports 1007932, "Identification and Detection of Aging Issues,"
1007933, "Aging Assessment Field Guide," and 1009743, "Aging Identification and
 
Assessment Checklist - Mechanical Components.")
In the updated response to RAI B2.1.33-2 dated August 12, 2005, the applicant pointed out that no change to RAI response is required. Thus AMP B2.1.33, Systems Walkdown
 
Program, was modified after RAI response and Section B2.1.33 under the "parameters
 
monitored/inspected" heading of the ALRA has been reworded to state:
System engineers conduct visual inspections of accessible portions of credited systems and components WSLR. Visible degradation, anomalous indications, or adverse conditions are documented and
 
evaluated. Adverse conditions that can lead to aggressive environments
 
for in scope components, such as evidence of leakage, wetted insulation, or degraded non-safety related or out of scope piping or anchor points
 
attached to in-scope portions, are also monitored.
The applicant stated that although the paragraph has been reworded for clarification the response to RAI B2.1.33-2 dated December 17, 2004, remains valid.
The staff found the parameters considered in the program implementation to be according to general industry practice and acceptable. Therefore, the staff's concern
 
described in RAI B2.1.33-2 is resolved.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.3 and concludes that this program attribute is acceptable.  (4)Detection of Aging Effects - In original LRA Section B2.1.33 the applicant stated that the aging effects of concern will be detected and documented through visual inspections
 
during system walkdowns. The frequency of inspections is at least once per refuel cycle
 
for each structure and system. This frequency is sufficient since the aging effects
 
typically are caused by long-term degradation. The staff considers this approach to
 
detection of aging effects for accessible external surfaces of selected SSCs within the
 
scope of license renewal at NMPNS acceptable.
In RAI B2.1.33-4 dated November 17, 2004, the staff requested that the applicant discuss the basic approaches and programs used to manage aging effects for
 
inaccessible external surfaces of SSCs within the scope of license renewal.
3-137 In its response by letter dated December 17, 2004, the applicant stated that the Systems Walkdown Program relies on visual inspections of accessible external surfaces to detect
 
aging effects. The evidence of aging, however, may apply to both accessible and
 
inaccessible component surfaces depending on the material of the component and the
 
environment to which it is exposed. Personnel performing inspections will be trained in
 
this program element to ensure that age related degradation is properly identified. The
 
applicant further indicated that any evidence of aging on accessible external surfaces
 
generally indicates the condition of inaccessible external surfaces and is considered an
 
effective indicator for managing inaccessible surfaces. As part of the enhancement to
 
the "parameters monitored/inspected" attribute described in original LRA
 
Section B2.1.33 to "provide guidance for assessment of identified deterioration" the
 
applicant confirmed that it will include direction to evaluate potentially susceptible
 
inaccessible areas when evidence of aging is detected. The staff agreed with this
 
enhancement procedure.
In the updated response to RAI B2.1.33-4 dated August 12, 2005, the applicant pointed out that no change to the RAI response was required because the Systems Walkdown
 
Program was modified and incorporated into the ALRA after the RAI response with no
 
change in intent. ALRA Section B2.1.33 under the program description heading has
 
been reworded to state:
The Systems Walkdown Program is an existing plant-specific program that consists of the ten elements described in Appendix A of
 
NUREG-1800 (Reference 1). The Systems Walkdown Program manages
 
aging effects for accessible external surfaces of systems and components
 
WSLR at NMPNS. The aging effects of concern are material degradation
 
and loss of material from external surfaces of pumps, valves, piping, bolts, heat exchangers, tanks, HVAC components, and other
 
components. The program also identifies adverse conditions that can lead
 
to aggressive environments for syst ems or components within the scope of LR. Program activities include system engineer walkdowns (i.e., field
 
evaluations of system components to assess material condition),
documentation and evaluation of inspection results, and appropriate
 
corrective actions.
The applicant stated that although the paragraph has been reworded to provide clarification the response to RAI B2.1.33-4 dated December 17, 2004, remains valid.
The staff reviewed information in the ALRA and found the applicant's approaches to detecting and managing aging effects for accessible and inaccessible surfaces of SSCs
 
within the scope of license renewal reasonable and acceptable. Therefore, the staff's
 
concern described in RAI B2.1.33-4 is resolved.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.4 and concludes that this program attribute is acceptable.  (5)Monitoring and Trending - In the original LRA Section B2.1.33 the applicant stated that the Systems Walkdown Program describes the monitoring and assessment of SSCs but has no requirements for monitoring and trending of applicable parameters. The staff 3-138 agreed that system engineers will document the aging effects of the assigned SSCs and that trending is not required.
The staff confirmed that this program element satisfies the criteria of the GALL Report and SRP-LR Section A.1.2.3.5 and concludes that this program attribute is acceptable.    (6)Acceptance Criteria - In original LRA Section B2.1.33 the applicant stated that the Systems Walkdown Program includes specific acceptance criteria for applicable
 
parameters. A list of walkdown attributes is available to system engineers for use in developing walkdown checklists.
In RAI B2.1.33-3 dated November 17, 2004, the staff requested that the applicant provide more detailed information according to the guidelines delineated in SRP-LR
 
Appendix A to describe the acceptance criteria for the program.
In its December 17, 2004, response to RAI B2.1.33-3 the applicant stated that the "acceptance criteria" program element in original LRA Section B2.1.33 states that, "A list
 
of walkdown attributes is available to system engineers for use in developing walkdown checklists." This statement acknowledged t hat system engineers conduct walkdowns for a variety of reasons (i.e., maintenance rule assessments, system readiness reviews, pre-outage reviews, license renewal, et cetera). The system engineer adapts the general
 
checklist to focus on attributes applicable to the walkdown. The applicant stated that the
 
license renewal walkdown focuses on attributes applicable to aging. The applicant
 
further stated that the current program administrative procedure (S-TDP-REL-0101, Systems Walkdown Program) states that "evidence of aging shall be documented on a
 
CR and recorded on the System Walkdown Report" (CR is the NMPNS document for
 
entering issues into the CAP). The applicant stated that as part of the enhancement to
 
the "acceptance criteria" attribute of original LRA Section B2.1.33 it intends to use EPRI
 
reports on detection of aging issues to train system engineers to recognize evidence of (acceptance criteria for) various aging effects. These EPRI reports are listed above
 
under "parameters monitored/inspected" (NMP1 Commitment 30, NMP2
 
Commitment 28). The staff found the applicant's approach to detection of evidence of
 
aging and implementation of corrective measures reasonable.
In the updated response to RAI B2.1.33-3 dated August 12, 2005, the applicant stated that the original response to this RAI remains valid and unchanged by the ALRA
 
reworded to state that incorporation of acceptance criteria into the program procedures
 
is an enhancement and that the updated RAI response provides additional information
 
for use. The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.6 and concludes that this program attribute is acceptable. Therefore, the
 
staff's concern described in RAI B2.1.33-3 is resolved. (10)Operating Experience - In ALRA Section B2.1.33, the applicant explained that the Systems Walkdown Program has relied upon sy stem health reports to document the overall material condition of various plant systems. As such, operating experience has
 
been incorporated into the system health r eports and not directly into the Systems Walkdown Program. Enhancements will be made to this program to include previous 3-139 operating experience and to ensure future operating experience is properly incorporated.
A review of the corrective action history related to material condition demonstrates the
 
past usefulness of walkdowns in identifying visually detectable age-related degradation (e.g., general corrosion of bolting, supports, and component surfaces). As additional
 
operating experience is obtained, lessons learned will be used to adjust the System
 
Walkdown Program as needed.
The staff confirmed that this program element satisfies the criteria of the GALL Report and SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.
UFSAR and USAR Supplements. In ALRA Sections A1.1.35 and A2.1.35, the applicant provided the respective UFSAR and USAR s upplements for the Systems Walkdown Program.
The staff reviewed these sections and determined that the information in the supplements
 
provide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Systems Walkdown Program, the staff concludes that the applicant demonstrated that the effects of aging will be adequately
 
managed so that the intended functions 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
 
UFSAR and USAR supplements for this AMP and concludes that they provide an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.3.3  Non-Segregated Bus Inspection Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.34, the applicant described the Non-Segregated Bus Inspection Program, stating that this is an existing, plant-specific program. The Non-Segregated Bus Inspection Program inspects components and materials internal to the non-segregated bus ducts that connect the reserve auxiliary
 
transformers to the 4160V buses required for the recovery of offsite power to both units
 
following an SBO event. Based upon the most recent industry and regulatory license renewal
 
precedence, this program also includes bus ducts associated with power boards feeding
 
components within the scope of license renewal. They are normally energized, and therefore, the bus duct insulation material will experience temperature rise due to energization, which may
 
cause age-related degradation during the extended period of operation.
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B2.1.34, regarding the applicant's demonstration of the
 
Non-Segregated Bus Inspection Program to ensure that the effects of aging, as discussed
 
above, will be adequately managed so that the intended functions will be maintained consistent
 
with the CLB for the period of extended operation.
The staff reviewed the Non-Segregated Bus Inspection Program against the AMP elements of SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 and focused on how the program manages
 
aging effects through the effective incorporation of 10 elements (i.e., "program scope,"
"preventive actions," "parameters monitored or inspected," "detection of aging effects,"
"monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process,"
 
"administrative controls," "and operating experience").
3-140  (1)Scope of Program - In ALRA Section B2.1.34, the applicant stated that this program applies to the bus ducts within the scope of license renewal, i.e., nonsegregated bus
 
ducts that connect the reserve auxiliary transformers to the 4160V buses required for the
 
recovery of offsite power to both units following an SBO event as well those associated
 
with power board feeding components within the scope of license renewal.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.1 and concludes that this program attribute is acceptable.    (2)Preventive Actions - In ALRA Section B2.1.34 the applicant stated that in this inspection program and no actions are taken to prevent or mitigate aging degradation.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.2 and concludes that this program attribute is acceptable.  (3)Parameters Monitored/Inspected - In ALRA Section B2.1.34 the applicant stated that a sample of accessible bolted connections (bus joints and ending devices) for proper
 
torque or the resistance of bolted joints will be checked using a micro-ohm meter of
 
sufficient current capacity suitable for checking bus bar connections. This program also
 
inspects the internal portions of accessible bus ducts for cracks, corrosion, foreign
 
debris, dust buildup, and water intrusion. The bus insulation system is inspected for
 
signs of embrittlement, cracking, melting, swelling, or discoloration which may indicate
 
overheating or age-related degradation. The internal bus supports (insulators) will be
 
inspected for structural integrity and cracking.
Generally vendors do not recommend re-torque of bolted connections unless the joint requires service or the bolted connections are clearly loose. The torque required to turn
 
the fastener in the tightening directions (restart torque) is not a good indicator of the
 
preload once the fastener is in service. After relaxation of the parts of the joint the final
 
loads are likely to be lower than the installed loads and thus, as documented in the Audit
 
and Review Report, the staff asked the applicant to justify technically how re-torquing of
 
bolted connections indicates preload once the fastener is in service.
In response to this request the applicant informed the staff that it will revise ALRA Sections A1.1.27, A2.1.27, and B2.1.34 to delete the torque test/torque checks and
 
include as an alternative to thermography or connection resistance measurement of bolted connection a visual inspection for the accessible bolted connections covered with
 
heat sink tape, sleeving, insulating boots, etc. (NMP1 Commitment 31, NMP2
 
Commitment 29). The staff found the applicant's response acceptable because
 
thermography, resistance checks, or visual inspections of bolted connections covered
 
with heat sink tape, sleeving, or insulating boots will provide reasonable assurance that
 
bolted connections are not loosened by ohmic heating. The staff also determined that
 
the six-year inspection frequency is adequate to prevent bus duct failures as industry
 
experience shows that aging degradation is a slow process. In its letter dated
 
December 1, 2005, the applicant stated that it will revise the ALRA to incorporate the
 
changes.The staff confirmed that this program element satisfies the criterion of GALL Report and SRP-LR Section A.1.2.3.3 and concludes that this program attribute is acceptable.
3-141  (4)Detection of Aging Effects - In ALRA Section B2.1.34 the applicant stated that visual inspections of internal portions of bus ducts detect cracks, corrosion, debris, dust, and
 
evidence of water intrusion and that visual inspections of the bus insulating system
 
detect embrittlement, cracking, melting, swelling, and discoloration. Visual inspections of
 
bus supports (insulators) detect cracking and lack of structural integrity. Internal portions
 
of bus ducts, the bus insulation system, and the bus supports (insulators) are inspected
 
visually approximately every six year
: s. Thermography or connection resistance measurment of the bus ducts or a torque test of a sample of accessible bolted
 
connections will be performed approximately every six years. An initial inspection will be completed before the end of the initial 40-year license term. This period is adequate to
 
identify failures of the bus ducts as experience shows that aging degradation is a slow
 
process. A six-year inspection frequency will provide during a 20-year period up to three
 
data points which can be used to characterize the degradation rate. If unacceptable
 
degradation is found as indicated by either increased resistance or visual anomalies the
 
inspections will be expanded to determine the extent of the condition.
As documented in the Audit and Review Report dated January 18, 2006, the applicant agreed to address the staff's concern and remove the torque test/torque check options
 
as reported in Element 3. The applicant will determine sample size by accepted industry
 
practice or vendor recommendation.
The staff determined that this program element satisfies the criteria of Appendix A.1.2.3.4 of the SRP-LR. Visual inspection of the bus insulating system will
 
detect embrittlement, cracking, melting, swelling, and discoloration which are aging
 
effects and aging effects mechanisms of insulation materials from heating.
 
Thermography or connection resistance measur ement of bolted connections will detect bolting loosening from thermal cycling. The staff also determined that the proposed
 
frequency is acceptable because the expected aging degradation is a slow process.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.4 and concludes that this program attribute is acceptable.    (5)Monitoring and Trending - In ALRA Section B2.1.34 the applicant stated that monitoring and trending are not included as part of this program because the ability to trend
 
inspection results is limited by available dat a; however, inspection results will be used to characterize degradation rates. This exception is consistent with latest industry and
 
regulatory license renewal precedence. Existing inspection procedures will be enhanced
 
to expand visual inspections of the bus duct support and insulation systems. Also, new
 
provisions will be made for either periodic low-range resistance checks of the bus ducts
 
or torque of a statistical sample of accessible bolted connections. The staff found that
 
the absence of trending for testing is acceptable as the test is performed every six years
 
and the staff saw no need for such activities.
The staff confirmed that this program element satisfies the criteria of the GALL Report and SRP-LR Section A.1.2.3.5 and concludes that this program attribute is acceptable.    (6)Acceptance Criteria - In ALRA Section B2.1.34 the applicant stated that bolted connections must meet the manufacturer's minimum torque specifications or the low-
 
resistance value of the bus ducts must be appropriate for the application. Bus ducts are 3-142 to be free from unacceptable visual indications of surface anomalies that suggest conductor insulation degradation. Additional acceptance criteria include no indication of
 
unacceptable corrosion, cracking, foreign debris, excessive dust buildup, or moisture
 
intrusion. Any condition or situation that if not corrected could lead to a loss of intended
 
function is considered unacceptable.
As documented in the Audit and Review Report, the staff expressed its concern during the staff audit about re-torquing of the bolted connections. The applicant informed the
 
staff that it will revise the acceptance criteria to delete the torque test/torque check
 
option and include as an alternative to thermography or connection resistance
 
measurement of bolted connections a visual inspection of the accessible bolted
 
connections covered with heat shrink tape, sleeving insulating, boots, etc. (NMP1
 
Commitment 31, NMP2 Commitment 29). In its letter dated November 17, 2005, , the
 
applicant stated that it has added an enhancement for program document to define
 
acceptance criteria for inspection of the bus duct, their support and insulation system, the low range ohmic checks of connections. This revision resolved the staff's concern.
The staff reviewed this program element to determine whether it satisfies the criteria of SRP-LR Appendix A.1.2.3.6. The staff found the acceptance criteria acceptable as the
 
low resistance value of the bus ducts must be appropriate for the application. Bus ducts
 
are to be free from unacceptable visual indications of surface anomalies that suggest
 
conductor insulation degradation. Additional acceptance criteria include no indication of
 
unacceptable corrosion, cracking, foreign debris, excessive dust buildup, or moisture
 
intrusion.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.6 and concludes that this program attribute is acceptable.    (7)Corrective Actions - The staff's review of the adequacy of the applicant's 10 CFR 50 Appendix B Program associated with this program element is addressed in SER
 
Section 3.0.4.
The staff reviewed other aspects of this program element to determine whether it satisfies the criteria of Appendix A.1.2.3.7 of the SRP-LR. The applicant stated that
 
corrective actions are documented using the CR process. The Quality Assurance
 
Program Topical Report (Appendix B to "Nine Mile Point Nuclear Station Unit 1 Final
 
Safety Analysis Report (Updated)" and Appendix B to "Nine Mile Point Nuclear Station
 
Unit 2 Updated Safety Analysis Report") documents the applicant's commitment to the
 
corrective action criteria of 10 CFR 50 Appendix B, "Quality Assurance Criteria for
 
Nuclear Power Plants and Fuel Reprocessing Plants." The applicant's CAP includes the
 
detection and correction of conditions adverse to quality and the identification, cause
 
determination, correction, prevention of recurrence of conditions significantly adverse to quality. GALL AMP XI.E4, which incorporated ISG-17, "Proposed Aging Management Program (AMP) XI.E4, 'Periodic Inspection of Bus Ducts,'" under corrective actions, states that further investigation and evaluation are performed when acceptance criteria
 
are not met. Corrective actions may include but are not limited to cleaning, drying, increasing inspection frequency, replacing, or repairing the affected metal-enclosed bus
 
components. If an unacceptable condition or situation is detected a determination is
 
made whether the same condition or situation applies to other accessible or inaccessible 3-143 areas. The applicant's CAP does not address the specific requirement of GALLAMP XI.E4. As documented in the Audit and Review Report the staff requested that the
 
applicant revise NMP AMP B2.1.34 to add specific requirements or justify why these
 
corrective actions are not necessary. The applicant informed the staff that it will revise
 
NMP AMP B2.1.34 by adding the following to the "corrective actions" program element:
Further investigation and evaluation are performed when the acceptance criteria are not met. Corrective actions may include
 
but are not limited to cleaning, drying, increased inspection
 
frequency, replacement, or repair of the affected bus duct
 
components. If an unacceptable condition or situation is identified, a determination is made to whether the same condition or
 
situation is applicable to other accessible or inaccessible bus
 
duct/components.
The staff found the applicant's response acceptable because it is consistent with thecorrective actions in GALL AMP XI.E4. In its letter dated December 1, 2005, the
 
applicant stated that it will revise the ALRA to incorporate the changes and on this basis
 
the staff found this program element acceptable.  (8)Confirmation Process - The staff's review of the adequacy of the applicant's 10 CFR 50 Appendix B Program associated with this program element is addressed in SER
 
Section 3.0.4.
The staff reviewed other aspects of this program element to determine whether it satisfies the criteria of Appendix A.1.2.3.8 of the SRP-LR. The staff found the applicant's
 
confirmation process meets the requirements of 10 CFR Part 50 Appendix B.  (9)Administrative Controls - The staff's review of the adequacy of the applicant's 10 CFR 50, Appendix B Program associated with this program element is addressed in
 
SER Section 3.0.4.
The staff reviewed other aspects of this program element to determine whether it satisfies the criteria of Appendix A.1.2.3.9 of the SRP-LR. The staff found the applicant's
 
administrative controls meet the requirements of 10 CFR Part 50 Appendix B.  (10)Operating Experience - In ALRA Section B2.1.34 the applicant explained that inspections of the bus ducts within the scope of license renewal have not revealed any
 
age-related degradation that could cause a loss of intended function.
The staff reviewed the operating experience stated in the ALRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience
 
revealed no degradation not bounded by industry experience.
After review of industry and plant-specific operating experience and discussions with the applicant's technical personnel the staff confirmed that the operating experience
 
program element satisfies the criteria defined SRP-LR Section A.1.2.3.10 and concludes
 
that this program attribute is acceptable.
3-144 UFSAR and USAR Supplements. The applicant provided its UFSAR and USAR supplements for the Non-Segregated Bus Inspection Program in ALRA Appendix A Section A1.1.27 for NMP1
 
and A2.1.27 for NMP2 stating that its Non-Segregated Bus Inspection Program manages aging
 
effects and aging effects mechanisms for components and materials internal to the
 
nonsegregated bus ducts that connect the reserve auxiliary transformer to the 4160V buses
 
required for the recovery of offsite power following an SBO event. Based upon the most recent
 
industry and regulatory license renewal precedence, this program also includes normally
 
energized bus ducts associated with board-feeding components within the scope of license
 
renewal. These normally-energized components are not subject to the environmental qualification requirements of 10 CFR 50.49 but can be affected by elevated temperatures prior
 
to the end of the period of extended operation. Program activities include visual inspections of
 
internal portions of the bus ducts to detect cracks, corrosion, debris, dust, and moisture; visual
 
inspections of the bus insulating system to detec t embrittlement, cracking, melting, swelling, and discoloration; visual inspections of bus supports (insulators) to detect cracking and lack of
 
structural integrity; and a torque test or a resistance test of a sample of accessible bolted
 
connections. The program incorporates applicable technical information and guidance from
 
industry. Analytical trending is not included in th is activity because the ability to trend inspection results is limited. This omission is an except ion to the "monitoring and trending" element in Appendix A.1.2.3.5 of the SPR-LR. Enhancements to the applicant's Non-Segregated Bus
 
Inspection Program include expanded visual inspec tions of the bus ducts, their supports, and insulation systems as well as low range resistance checks of the bus ducts or torque checks
 
from a statistical sample of accessible bolted connections. Enhancements will be implemented prior to the period of extended operations.
Generally vendors do not recommend re-torque of bolted connections unless the joint requires service or the bolted connections are clearly loose. The torque required to turn the fastener in
 
the tightening directions (restart torque) is not a good indicator of preload once the fastener is in
 
service. After relaxation of the parts of the joint the final loads are likely to be lower than the
 
installed loads. As documented in the Audit and Review Report, the staff requested that the
 
applicant justify technically how re-torquing of bolted connections indicates preload once the
 
fastener is in service. In response to this request the applicant informed the staff that it will
 
revise ALRA Sections A1.1.27, A2.1.27, and B2.1.34 to delete the torque test/torque checks
 
and include as an alternative to thermography or connection resistance measurement of bolted connections visual inspection of the accessible bolted connections covered with heat sink tape, sleeving, insulating boots, etc. (NMP1 Commitment 31, NMP2 Commitment 29). The staff found
 
the applicant's response acceptable because thermography, resistance check, or visual
 
inspection of bolted connections covered with heat sink tape, sleeving, or insulating boots will
 
provide reasonable assurance that bolted connections are not loose from ohmic heating. In its
 
letter dated December 1, 2005, the applicant stated that it had revised the ALRA to incorporate
 
such changes.
Conclusion. On the basis of its review and audit of the applicant's Non-Segregated Bus Inspection Program, the staff concludes that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR and USAR supplements fo r this AMP and concludes that they provide an adequate summary description of the program, as required by 10 CFR 54.21(d).
3-145 3.0.3.3.4  Fuse Holder Inspection Program Summary of Technical Information in the Amended Application. In ALRA Section B2.1.35, the applicant described the Fuse Holder Inspection Program, stating that this is a new, plant-specific program. Fuse holders/blocks are classified as a specialized type of terminal
 
block because of the similarity in design and construction. The fuse holders are typically
 
constructed of blocks of rigid insulating material, such as phenolic resins. Metallic clamps are
 
attached to the blocks to hold each end of the fuse. The clamps can be spring-loaded clips that
 
allow the fuse ferrules or blades to slip in, or they can be bolt lugs, to which the fuse ends are
 
bolted. The clamps are typically made of copper. The aging of the fuse holder insulation
 
material will be managed under the program for Electrical Cables and Connections Not Subject
 
to 10 CFR 50.49 Environmental Qualification Requirements. The Fuse Holder Inspection
 
Program includes the following aging stressors: moisture, fatigue, ohmic heating, mechanical
 
stress, vibration, thermal cycling, electrical tr ansients, chemical contamination, oxidation, and corrosion. In-scope fuse holders are tested to provide a direct indication of the condition of the
 
metallic clamps. Fuses may be tested using either thermography or contact resistance.
In the ALRA, the applicant states that only fuse holders located outside active devices and not part of larger assemblies are included in the program. The applicant also stated that the fuse
 
holders are typically constructed of blocks of rigid insulating material like phenolic resins.
 
Metallic clamps are attached to the blocks to hold each end of the fuse. The clamps can be
 
spring-loaded clips that allow the fuse ferrules or blades to slip in or they can be lugs to which
 
the fuse ends are bolted. The clamps are made typically of copper. In ALRA Table 3.6.2.C-1 the
 
applicant categorized the fuse holder components into insulator materials and copper alloy
 
clamps in the Material column. The applicant stated that the aging of the fuse holder insulation
 
material will be managed under Non-EQ Electr ical Cables and Connection Program (ALRA Section B2.1.29), which was evaluated in SER Section 3.6.2.1. The metallic clamps of the fuse
 
holders are evaluated in this section. The applicant stated in Table 3.6.2.C-1 that the metallic
 
clamps of the fuse holders are subject to the Fuse Holder Inspection Program. The applicant
 
further identified in ALRA Table 3.6.2.C-1 loss of electrical continuity as the AERM.
 
The applicant stated that the aging of the fuse holder copper alloy clamps will be managed
 
under a new program called Fuse Holder Inspection Program as addressed in this SER section
 
3.0.3.3.4 Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B2.1.35, regarding the applicant's demonstration of the Fuse Holder
 
Inspection Program to ensure that the effects of aging, as discussed above, will be adequately
 
managed so that the intended functions will be maintained consistent with the CLB for the
 
period of extended operation. Details of staff evaluation AMP B2.1.35 are as follows:
The staff reviewed the Fuse Holder Inspection Program against the AMP elements found in SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 focusing on how the program manages aging
 
effects through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and
 
trending," "acceptance criteria," "corrective actions," "confirmation process," "administrative
 
controls," "and "operating experience").
The applicant indicated that corrective actions, confirmation process, and administrative 3-146 controls are part of the site-controlled quality assurance program. The staff's evaluation of the quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements
 
are addressed here:    (1)Scope of Program - In ALRA Section B2.1.35 the applicant stated that this program applies to metallic clamps of fuse holders located outside active devices that have aging
 
effects requiring aging management. This application is acceptable to the staff because
 
it is consistent with the GALL Report and complements the information provided by the
 
applicant for insulator material.
The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1 and concludes that this program attribute is acceptable.    (2)Preventive Actions - In ALRA Section B2.1.35 the applicant stated that the Fuse Holder Inspection Program monitors conditions and requires regular inspection of the in-scope
 
components and identification of degraded conditions that would affect the ability of the
 
components to perform intended functions. C onsequently, no specific preventive actions are associated with this program other than identification of the aging effects of concern
 
before a loss of intended function occurs. The staff did not identify the need for any
 
preventive action except condition monito ring including thermography or contact resistance checks.
The staff confirmed that the "preventive acti ons" program element satisfies the criterion of SRP-LR Section A.1.2.3.2 and concludes that this program attribute is acceptable.    (3)Parameters Monitored/Inspected - In ALRA Section B2.1.35 the applicant stated that monitored parameters will include high resistance of the metallic clamp (or clip) portion
 
of the fuse holder to detect fatigue caused by ohmic heating, thermal cycling, electrical
 
transients, mechanical stress, chemical contamination, corrosion, and oxidation. The
 
staff agreed that testing clamp resistance using thermography or contact resistance
 
effectively ensures that the fuse holder clamps will perform their intended function for the
 
extended period of operation.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.3 and concludes that this program attribute is acceptable.  (4)Detection of Aging Effects - In ALRA Section B2.1.35 the applicant stated that the fuse holders will be tested at least every 10 year s by thermography, contact resistance, or other appropriate testing methods. The initial inspection will be prior to the period of
 
extended operation and thereafter a 10-year inspection frequency will be used to provide
 
at least two data points during the 20-year period of extended operation. The staff
 
agreed that the aging degradation of fuse holder clamps is a slow process and that a
 
10-year inspection frequency is adequate to prevent failures of fuse holder clamps.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.4 and concludes that this program attribute is acceptable.    (5)Monitoring and Trending - In ALRA Section B2.1.35 the applicant stated that monitoring and trending are not included in this program because the parameters monitored may
 
vary depending upon the test method used. The staff concurred with this policy because 3-147 thermography or connection resistance test will be performed at 10-year intervals, appropriate methods can be used for subsequent tests, and so long the test results
 
confirm no loosening of the fuse holder clamps there is no need for monitoring and
 
trending the test results.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.5 and concludes that this program attribute is acceptable.    (6)Acceptance Criteria - In ALRA Section B2.1.35 the applicant stated that the acceptance criteria for each fuse holder clamp will depend on the specific test performed and the
 
specific fuse holder clamp tested. As explained in the "monitoring and trending" program
 
element, the staff concurred that acceptance criteria should depend on the type of test
 
and the type of clamp.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.6 and concludes that this program attribute is acceptable.    (10)Operating Experience - In ALRA Section B2.1.35 the applicant stated that the Fuse Holder Inspection Program is a new program at NMPNS and, therefore, no
 
programmatic operating experience is available. However, the applicant stated that
 
operating experienced lessons learned will be used to adjust this program as needed.
 
The applicant committed to develop the Fuse Holder Inspection Program with
 
specifications stated in ALRA Section B2.1.35 (NMP1 Commitment 32 and NMP2
 
Commitment 30). The staff agreed that the proposed program will provide reasonable
 
assurance of detection of loosening of fuse holder clamps prior to significant
 
degradation.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.
UFSAR and USAR Supplements. In ALRA Sections A1.1.21 and A2.1.21, the applicant provided the respective UFSAR and USAR supplements for the Fuse Holder Inspection
 
Program. The staff reviewed these sections and determined that the information in the
 
supplements provide adequate summary descriptions of the program, as required by
 
10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Fuse Holder Inspection Program, the staff concludes that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR and USAR supplements for this AMP and concludes that they provide an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.3.5  Non-EQ Electrical Cable Metallic Connections Inspection Program
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.39, the applicant described the Non-EQ Electrical Cable Metallic Connections Inspection Program, stating that this is a new, plant-specific program. Most electrical connections involve insulating
 
material and metallic parts. This program will address the aging effects of the metallic parts
 
used to connect cable conductors to other cables or electrical devices. The Non-EQ Electrical 3-148 Cables and Connections Program will address the aging effects of the cable insulation material.
The electrical connections used in nuclear power plants include: splices (butt or bolted),
crimp-type ring lugs, and terminal blocks. The aging stressors to these connections addressed
 
by this program include: thermal cycling, ohmic heat ing, electrical transients, vibration, chemical contamination, corrosion, and oxidation. The specific mechanism for each of these aging
 
stressors is described in the most recent industry and regulatory license renewal precedence.
 
The specific test performed will be determined prior to the initial test, and will be a proven test
 
for detecting loose connections, such as thermography, contact resistance testing, or other
 
appropriate testing. The applicant indicated that this program will be implemented prior to the
 
period of extended operation (NMP1 Commitment 35, NMP2 Commitment 33).
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B2.1.39, regarding the applicant's demonstration of the Non-EQ
 
Electrical Cable Metallic Connections Inspecti on Program against the AMP elements of SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 focusing on how the program manages aging effects
 
through the effective incorporation of 10 element s (i.e., "program scope," "preventive actions,"
"parameters monitored or inspected," "detection of aging effects," "monitoring and trending,"
 
"acceptance criteria," "corrective actions," "confir mation process," "administrative controls," "and "operating experience").
The applicant indicated that corrective actions, confirmation process, and administrative controls are parts of the site-controlled quality assurance program. The staff's evaluation of the
 
quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements
 
are addressed here.  (1)Scope of Program - In ALRA Section B2.1.39 the applicant stated that this program applies to the metallic portion of non-EQ electrical cable connections. The staff found the
 
"scope of the program" acceptable as consistent with the GALL Report and
 
complementary to the information provided by the applicant for conductor insulation for
 
electrical cables and connectors.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.1 and concludes that this program attribute is acceptable.    (2)Preventive Actions - In ALRA Section B2.1.39, the applicant stated that the Non-EQ Electrical Cable Metallic Connections Inspection Program requires regular inspection of
 
in-scope components and detection of degraded conditions that would affect the ability
 
of components to perform intended functions. No specific preventive actions are
 
associated with this program except identification of the aging effects of concern before
 
a loss of intended function occurs. The staff did not identify the need for any preventive
 
action except the condition monitoring program.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.2 and concludes that this program attribute is acceptable.    (3)Parameters Monitored/Inspected - In ALRA Section B2.1.39 the applicant stated that monitored parameters will include testing representative samples for loosening of bolted
 
connections. The sample will be assessed on application voltage (high, medium, and low
 
voltage systems), circuit loading, and location (high temperature, high humidity, vibration, etc.). The staff agreed that testing of representative samples using 3-149 thermography or contact resistance effectively ensures performance of conductor connector intended function for the extended period of operation.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.3 and concludes that this program attribute is acceptable.  (4)Detection of Aging Effects - In ALRA Section B2.1.39 the applicant stated that loosening of the electrical connections can be caused by one or more aging stressors, namely, thermal cycling, ohmic heating, electrical tr ansients, vibrations, chemical contamination, corrosion, and oxidation. The applicant stated that one or more of the proven tests, thermography, contact resistence, or other appropriate testing, will be performed case by
 
case.The applicant stated that the initial inspection of this program will be performed prior to the period of the extended operation and that thereafter a 10-year inspection frequency
 
will be used to provide at least two data points during the 20-year period of extended operation. The applicant stated that for the slow degradation of the Non-EQ electrical
 
cable connections the 10-year test frequency for this program is adequate. The staff
 
agreed that industry experience shows that aging degradation of cable connections is a
 
slow process and 10-year inspection frequency is adequate to prevent failures of cable
 
connections. The staff also agreed that thermography or connection resistance
 
measurement is effective in detecting connection degradation.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.4 and concludes that this program attribute is acceptable.  (5)Monitoring and Trending - In ALRA Section B2.1.39 the applicant stated that monitoring and trending are not included in this program because the parameters monitored may
 
vary depending upon the test method. The staff concurred with this because the
 
thermography or connection resistance test s will be performed at 10-year intervals, different methods can be used for subsequent tests, and so long as the test results
 
confirm no loosening of bolted connections there is no need for monitoring and trending
 
the test results.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.5 and concludes that this program attribute is acceptable.    (6)Acceptance Criteria - In ALRA Section B2.1.39 the applicant stated that the acceptance criteria for each conductor connector will depend on the specific test used and the
 
specific conductor connector tested. The staff concurred that acceptance criteria should
 
depend on the type of test and the type of the conductor connector.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.6 and concludes that this program attribute is acceptable.    (10)Operating Experience - In ALRA Section B2.1.39 the applicant stated that the Non-EQ Electrical Cable Metallic Connections Inspection Program is new at NMP; therefore, no
 
programmatic operating experience is available. As operating experience is obtained
 
lessons learned will be used to adjust this program as needed.
3-150 The staff confirmed that this program element satisfies the criteria of the GALL Report and SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.
UFSAR and USAR Supplements. In ALRA Sections A1.1.41 and A2.1.39, the applicant provided the respective UFSAR and USAR supplements for the Non-EQ Electrical Cable
 
Metallic Connections Inspection Program. The staff reviewed these sections and determined
 
that the information in the supplements prov ide adequate summary descriptions of the program, as required by 10 CFR 54.21(d).
Conclusion. After review of the applicant's Non-EQ Electrical Cable Metallic Connections Inspection Program, the staff concludes that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 UFSAR and USAR supplements fo r this AMP and concludes that they provide an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.3.6  Wooden Power Pole Inspection Program (NMP2 Only)
 
Summary of Technical Information in the Amended Application. In ALRA Section B2.1.40, the applicant described the Wooden Power Pole Inspection Program for NMP2, stating that this is a
 
new, plant-specific program. The Wooden Power Pole Inspection Program manages the aging
 
of wooden power poles that are within the scope for license renewal because they provide
 
structural support for the transmission lines in the recovery path for station blackout. Qualified
 
personnel perform inspections, conducted prior to the period of extended operation and every
 
10 years thereafter, that manage material loss, degradation, and physical damage. Activities
 
include visual inspections of the entire structure, including cross members and hardware, pole
 
soundings, circumferential measurements, and below grade inspections. If necessary, core boring, application of preservatives, and pesticide treatments are performed if soundings
 
suggest degradation has occurred. Corrective actions may include pole reinforcement or
 
replacement. The program inspection activities ensure that in-scope electrical support
 
structures retain their intended functions between inspection cycles.
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B2.1.40, regarding the applicant's demonstration of the Wooden
 
Power Pole Inspection Program to ensure that the effects of aging, as discussed above, will be
 
adequately managed so that the intended functions will be maintained consistent with the CLB
 
for the period of extended operation.
The applicant stated that the new plant-specific Wooden Power Pole Inspection Program (NMP2 Commitment 34) that will manage the aging of wooden power poles within the scope of
 
license renewal because they provide structural support for the transmission lines in the SBO
 
recovery path.
The staff understands that the applicant's Wooden Power Pole Inspection Program is a sub-program of its Structures Monitoring Program. In Appendices A and B of the ALRA for the
 
applicant's Masonry Wall Program, also a Structures Monitoring Program sub-program, this
 
relationship is addressed. In ALRA Section A2.1.40 for the Wooden Power Pole Program this
 
relationship with the applicant's Structures Monitoring Program is not addressed. As
 
documented in the Audit and Review Report, the staff requested the applicant to explain the
 
inconsistency.
3-151 In its letter dated December 1, 2005, the applicant stated that ALRA Sections A2.1.40 and B2.1.40 had been modified at the end of the first paragraph by adding: "The Wooden Power
 
Pole Inspection Program is implemented by t he Structures Monitoring Program for managing specific aging effects." Also the applicant stated that the Wooden Power Pole Inspection
 
Program had been modified at the end of the program description paragraph by adding: "The
 
Wooden Power Pole Inspection Program is implemented by the Structures Monitoring Program (B2.1.28) for managing specific aging effects."
The staff reviewed information provided in the ALRA and supplemental letters and found it acceptable. With the clarifying statements added by the applicant to ALRA Sections A2.1.40
 
and B2.1.40 the relationship between its Wooden Power Pole Inspection Program and its
 
Structures Monitoring Program is addressed.
The staff reviewed the Wooden Power Pole Inspection Program against the AMP elements of SRP-LR Section A.1.2.3, and SRP-LR Table A.1-1 focusing on how the program will manage aging effects through the effective incorporation of 10 elements (i.e., "program scope,"
 
"preventive actions," "parameters monitored or inspected," "detection of aging effects,"
"monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process,"
 
"administrative controls," "and "operating experience") addressed here.  (1)Scope of Program - In ALRA Section B2.1.40 the applicant stated that this program applies to wooden power poles relied upon for SBO recovery within the scope of license
 
renewal and subject to and AMR. The program includes visual inspections of the entire
 
structure, pole sounding and circumference measurements, below-grade inspections, any necessary core boring, preservative application, and pesticide treatments.
The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1 and concludes that this program attribute is acceptable.    (2)Preventive Actions - In ALRA Section B2.1.40 the applicant stated that this program monitors conditions as described in SRP-LR Appendix A.1.1. The program provides for
 
timely detection of loss of material and degradation and physical damage, not preventive or mitigating actions.
As documented in the Audit and Review Report, the staff noted that at ALRA page B2-89 under scope of program for NMP AMP B2.1.40 the applicant states that the
 
program includes visual inspections of the entire structure, pole sounding and
 
circumference measurements, below-grade inspections, any necessary core boring, preservative application, and pesticide treatments. However, the applicant stated in the
 
preceding paragraph that the Wooden Power Pole Inspection Program monitors
 
conditions and does not support preventive or mitigating actions. The staff requested the
 
applicant to explain why preservative applications are not preventive actions and
 
pesticide treatments are not mitigating actions.
In its letter dated December 1, 2005, the applicant stated that preservative applications and pesticide treatments will enhance the lives of the poles by minimizing their
 
deterioration; however; the license renewal AMP is not based on these actions and does
 
not credit them. The aging management monitors conditions. The inspection frequency, repair, and replacement of poles are based on the condition of the poles at the time of
 
inspection.
3-152 The staff reviewed the applicant's response and found it acceptable. Although application of preservatives and pesticides to the wooden power poles is part of the
 
Wooden Power Pole Inspection Program license renewal aging management is not
 
based on these actions. For any one pole decreasing the inspection frequency to less
 
than every ten years and repairing or replacing it depends on the condition of the pole at
 
the time of the condition monitoring inspection. Application of preservatives or pesticides
 
is relied upon to prevent aging effects/mechanisms of the wooden power poles under
 
license renewal.
The staff determined that this program element satisfies the criterion of SRP-LR Appendix A.1.2.3.2 and that inspections under the applicant's Wooden Power Pole
 
Inspection Program only monitor the condition of the wooden power poles and perform
 
no preventive or mitigating action for aging effects and aging effects mechanisms . On
 
this basis, the staff found the applicant's preventive actions acceptable.  (3)Parameters Monitored/Inspected - In ALRA Section B2.1.40 the applicant stated that wooden power poles will be inspected for material loss, degradation, and physical
 
damage. Techniques include visual examinations of the entire structure including cross
 
members and hardware, pole soundings, circ umferential measurements, and below-grade inspections. If necessary core boring, preservative applications, and pesticide
 
treatments are performed if soundings suggest degradation. Visual inspections check
 
the pole for physical or mechanical damage that can affect the life of the pole (lean or
 
tilt, splitting or cracked tops, changes to grade, and shell or butt rot and decay).
 
Excavations will be performed to a depth of approximately 18 inches to detect loss of
 
material or degradation or damage. Pole sounding will be performed by a qualified
 
inspector at various pole locations to detect internal rot/decay, insect damage or
 
infestations, or hollow areas. Core boring of the pole may be performed based on the
 
inspection and sounding results to detect internal decay, insect infestation, or hollow
 
areas. If insect infestation is found the area will be treated with a fumigant prior to
 
plugging of the bored core region. Preservative treatment of the excavated surfaces (including moisture barrier/wrapping) also will be performed prior to recovering. Effective
 
circumference measurements evaluate the pole-loading capacity.
The program also monitors proper pole tagging and labeling with treatment information and application dates.
The staff determined that this program element satisfies the criterion of SRP-LR Appendix A.1.2.3.3 and that the applicant has identified clearly the parameters of
 
wooden power poles that need inspection for aging effects and aging effects
 
mechanisms affecting the ability of the wooden power poles to perform their intended
 
function. Visual examinations of the entire wooden power pole structure with core boring
 
and soundings as needed will check each pole for physical or mechanical damage that
 
can affect the life of the pole. Parameters monitored include lean or tilt, splitting or
 
cracked tops, changes to buried depth, shell or butt rot or decay, internal rot/decay, insect damage or infestations, circumferential measurements, and hollow areas. For
 
these reasons the staff found the applicant's "parameters monitored or inspected"
 
program element acceptable.  (4)Detection of Aging Effects - In ALRA Section B2.1.40 the applicant stated that the inspections in the new program shall be by qualified personnel on components within the 3-153 scope of license renewal within five years of the expiration of the current operating license. Subsequent visual inspections and testing for the wooden poles will be every
 
ten years. This frequency is based on industry experience, which shows that although
 
the typical wooden pole life is expected to be 30 to 40 years routine inspection and
 
treatment can extend this life by 50 percent or more. Typical industry inspection
 
frequencies for wooden poles currently range from 8 to15 years.
The 10-year visual inspections and testing will detect degradation and identify deficiencies before there is a loss of intended function. All inspections will provide the
 
level of detail and examination necessary to ensure that intended functions are
 
preserved through each subsequent inspection cycle.
The staff determined that this program element satisfies the criteria of SRP-LR Appendix A.1.2.3.4 and that the applicant has identified the frequency of inspection of
 
the wooden power poles as within five years of the expiration of the current operating
 
license and every 10 years after based on industry experience. Every wooden power
 
pole within the scope of license renewal will be inspected. Visual examinations of the
 
entire wooden power pole structure with core boring and soundings as needed are
 
adequate methods to gather data on the condition of the wooden power poles. For these
 
reasons the staff found the applicant's "detection of aging effects" program element
 
acceptable.  (5)Monitoring and Trending - In ALRA Section B2.1.40 the applicant stated that this program shall retain all previous inspection records. These are plant records available
 
for review during the subsequent inspection cycle. Reviews of previous inspection
 
results will provide for trending of long-term degradation or deterioration. This
 
information also could help in evaluating the potential for degradation before the next
 
inspection.
Additionally, the program shall provide for appropriate engineering reviews of the inspection results. Although the inspections may be performed by an outside vendor or
 
contractor or by the applicant's personnel in-house reviews of the results will confirm that
 
the wooden poles are capable of continuing to perform their intended functions through
 
the next inspection cycle.
The staff determined that for visual inspection this program element satisfies the criteria of SRP-LR Appendix A.1.2.3.5. The staff found that the applicant intends to retain all
 
inspection records under its Wooden Power Pole Inspection Program. Reviews of
 
previous inspections will be done so that long-term degradation can be trended.
 
In-house reviews of the results shall be performed to confirm that the wooden poles are
 
capable of continuing to perform their intended functions through the next inspection
 
cycle. For these reasons the staff found the applicant's "monitoring and trending"
 
program element acceptable.  (6)Acceptance Criteria - In ALRA Section B2.1.40 the applicant stated that this program will specify qualification and experience requirements in the inspection, treatment, and
 
reinforcement of wooden power poles for personnel performing inspections. For
 
inspections contracted to outside vendors or contractors all required qualifications
 
including minimum years of experience, pesticide applicator licenses or certifications, and wood treatment and fumigant qualifications are specified. All work by the applicant 3-154 or vendor/contractor shall be performed to the criteria or standards stated in the NMP activity and through site-specific procedures.
The program will detail the inspection methods with any applicable acceptance/rejection criteria. Any pole found to have loss of material, degradation, or physical damage will be
 
assessed and treated. The capability of a degraded pole to continue performing
 
load-carrying intended functions will be evaluat ed. Additionally, the program will identify and label wooden poles warranting immediate rejection due to dangerous conditions as
 
well as those with serious but lesser defects requiring repair, reinforcement, or
 
nonemergent replacement. All poles classified as rejected or dangerous will be labeled
 
or tagged during the inspection denoting the degradation severity level.
The staff reviewed this program element to determine whether it satisfies the criteria of SRP-LR Appendix A.1.2.3.6. The staff determined that the applicant intends under its
 
Wooden Power Pole Inspection Program to specify the inspection methods and any
 
applicable acceptance/rejection criteria. In addition detailed qualification and experience
 
requirements will be developed for personnel performing the inspections. The inspection
 
results will be used to evaluate the capability of a degraded pole to continue performing
 
its load-carrying intended functions. For these reasons the staff found the applicant's
 
acceptance criteria acceptable.  (7)Corrective Actions - The adequacy of the applicant's 10 CFR 50 Appendix B Program associated with this program element reviewed by the staff is addressed in SER
 
Section 3.0.4.
In ALRA Section B2.1.40 the applicant stated that the Quality Assurance Program Topical Report documents its commitment to the corrective action criteria of 10 CFR 50
 
Appendix B. The applicant's Wooden Power Pole Inspection Program will direct the use
 
of the site CAP when conditions adverse to quality are identified. These actions include
 
evaluations of adverse or degraded conditions and wooden pole reinforcement or
 
replacement.
The staff reviewed other aspects of this program element to determine whether it satisfies the criteria of SRP-LR Appendix A.1.2.3.7. The staff determined that the
 
applicant intends to take action to correct conditions adverse to wooden power pole
 
quality by performing evaluations for wooden pole reinforcement or replacement. For
 
these reasons the staff found the applicant's corrective actions acceptable.  (8)Confirmation Process - The adequacy of the applicant's 10 CFR 50 Appendix B Program associated with this program element reviewed by the staff is addressed in SER
 
Section 3.0.4 In ALRA Section B2.1.40 the applicant stated that the Quality Assurance Program Topical Report documents the confirmation process for it under the corrective action
 
criterion. The applicant's confirmation process is implemented through corrective action
 
effectiveness reviews and is performed for selected hardware-related and other
 
conditions significantly adverse to quality. The applicant's CAP includes but is not limited
 
to SR, NSR, and fire protection SSCs. Therefore, those SSCs within the scope of license
 
renewal are addressed as part of the applicant's current CAP.
3-155 The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.8 and concludes that this program attribute is acceptable.  (9)Administrative Controls - The adequacy of the applicant's 10 CFR 50 Appendix B Program associated with this program element reviewed by the staff is addressed in
 
SER Section 3.0.4.
In ALRA Section B2.1.40 the applicant stated that its Wooden Power Pole Inspection Program will be implemented through procedures subject to the 10 CFR 50 Appendix B
 
administrative controls program. The administrat ive controls for NMP are discussed in its Conduct of Operations description and the Quality Assurance Program Topical Report.
The staff reviewed other aspects of this program element to determine whether it satisfies the criteria of SRP-LR Appendix A.1.2.3.9 and determined that the applicant's
 
Wooden Power Pole Inspection Program has regulatory and administrative controls
 
providing a formal review and approval proc ess of the program. For these reasons the staff found the applicant's administrative controls acceptable.  (10)Operating Experience - In ALRA Section B2.1.40 the applicant stated that the Wooden Power Pole Inspection Program is defined and implemented for license renewal; thus, there is no plant-specific operating experience. Review of corrective action process
 
reports yielded nothing applicable to wooden pole aging or degradation. Inspection
 
scheduling and performance as discussed in the other SRP-LR attributes will provide
 
plant-specific inspection data and experience prior to the end of the current operating
 
period. The staff recognized that the applicant's CAP which records internal and external plant operating experience will ensure that operating experience is reviewed and incorporated
 
in the future for objective evidence to support the conclusion that the effects of aging are
 
adequately managed.
After discussions with the applicant's technical personnel the staff concludes that the applicant's Wooden Power Pole Inspection Program (NMP2 Only) will manage
 
adequately the aging effects and aging effects mechanisms identified in the ALRA for
 
which this AMP is credited.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.
USAR Supplement. In ALRA Section A2.1.40, the applicant provided the USAR supplement for the Wooden Power Pole Inspection Program. The staff reviewed this section and determined
 
that the information in the USAR supplement provide an adequate summary description of the
 
program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Wooden Power Pole Inspection Program, the staff concludes that the applicant demonstrated that the effects of
 
aging will be adequately managed so that the intended functions 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 USAR supplement for this AMP and concludes that they provide an adequate
 
summary description of the program, as required by 10 CFR 54.21(d).
3-156 3.0.3.3.7  Torus Corrosion Monitoring Program (NMP1 Only)
Summary of Technical Information in the Amended Application. In ALRA Section B3.3, the applicant described the Torus Corrosion Monitoring Program for NMP1, stating that this is an
 
existing, plant-specific program. The Torus Corrosion Monitoring Program credited for aging
 
management of the NMP1 suppression chamber (torus). This program is based on a prior commitment to periodically monitor torus condition as described in an NRC SER dated
 
August 11, 1994 (NUDOCS: 80615:233-244). The staff reviewed the ALRA to determine
 
whether the applicant has demonstrated that the Torus Corrosion Monitoring Program will
 
manage adequately the aging effects of the NMP1 torus during the period of extended operation
 
as required by 10 CFR 54.21(a)(3).
The applicant states in the ALRA that the Torus Corrosion Monitoring Program manages corrosion of the NMP1 torus through inspection and analysis. This program is designed to
 
ensure that the torus shell and support structure minimum thickness limits are not exceeded.
 
This program provides for the following inspection and analysis methods:
* determination of torus shell thickness through UT measurement
* determination of corrosion rate through analysis of material coupons
* visual inspection of accessible external surfaces of the torus support structure for corrosion Observations of the torus shell and support structure conditions ensure that timely action can be taken to correct degradation that could lead to loss of intended function. The minimum allowable
 
torus wall thickness is established as 0.431 inches. This program requires in addition to wall
 
thickness measurements determination of corrosion rates from inspection results and the
 
remaining corrosion allowance. The aging evaluation that specifies minimum wall thickness for
 
the NMP1 torus shell is a TLAA for license renewal. The Torus Corrosion Monitoring Program
 
ensures that the NMP1 torus wall and support structure thickness limits are not exceeded. This
 
program applies only to NMP1 because NMP2 is a Mark II containment with no torus.
Staff Evaluation. In accordance with 10 CFR 54.21(a)(3), the staff reviewed the information included in ALRA Section B3.3, regarding the applicant's demonstration of the Torus Corrosion
 
Monitoring Program to ensure that the effects of aging, as discussed above, will be adequately
 
managed so that the intended functions will be maintained consistent with the CLB for the
 
period of extended operation.
The staff reviewed the Torus Corrosion Monitoring Program against the AMP elements found in SRP-LR Section A.1.2.3 and SRP-LR Table A.1-1 focusing on how the program manages aging
 
effects through the effective incorporation of 10 elements (i.e., "program scope," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and
 
trending," "acceptance criteria," "corrective actions," "confirmation process," "administrative
 
controls," "and "operating experience").
The applicant indicated that the corrective actions, confirmation process, and administrative controls are parts of the site-controlled quality assurance program. The staff's evaluation of the
 
quality assurance program is addressed in SER Section 3.0.4. The remaining seven elements
 
are discussed here.
3-157  (1)Scope of Program - In ALRA Section B3.3 the applicant stated that the NMP1 Torus Corrosion Monitoring Program determines torus shell thickness through UT
 
measurement, determination of corrosion rate through analysis of material coupons, and
 
visual inspection of accessible external surfaces of the torus support structure for
 
corrosion. The staff found the scope of the Torus Corrosion Monitoring Program
 
acceptable because it is comprehensive in its surveillance of the torus and its support
 
structure.
The staff confirmed that this element satisfies the criterion of SRP-LR Section A.1.2.3.1 and concludes that this program attribute is acceptable.    (2)Preventive Actions - In ALRA Section B3.3 the applicant stated that the Torus Corrosion Monitoring Program monitors conditions and requires no specific preventive actions. The staff agreed that the purpose of the program is to monitor material thickness and
 
corrosion rate to ensure that the torus shell and support structure meet the qualification
 
bases and that no preventive actions are required for this program.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.2 and concludes that this program attribute is acceptable.    (3)Parameters Monitored or Inspected - In ALRA Section B3.3 the applicant stated that the torus wall thickness is measured through UT measurements and torus coupon activities.
 
The condition of the torus external supports is monitored by visual inspection. The staff
 
found that the applicant has selected parameters to be inspected or monitored that can
 
provide evidence of corrosion to ensure that timely action can be taken to correct
 
degradation that could threaten the minimum material thickness requirement.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.3 and concludes that this program attribute is acceptable.  (4)Detection of Aging Effects - In ALRA Section B3.3 the applicant stated that torus wall UT measurements are obtained at approximately si x-month intervals over a predefined grid system and that corrosion sample coupons are analyzed during each refueling outage.
 
Corrosion rates are determined through analysis of both data sets and the most
 
conservative corrosion rate for a particular torus bay is used to evaluate aging of the
 
structure. The staff found that monitoring in this manner ensures the torus shell material
 
will meet the minimum required wall thickness and that any degradation is detected
 
before a loss of intended function.
The staff confirmed that this program element satisfies the criterion of SRP-LR Section A.1.2.3.4 and concludes that this program attribute is acceptable.  (5)Monitoring and Trending - In ALRA Section B3.3 the applicant stated that measurements are performed on a predefined schedule that allows for analysis of the corrosion and
 
thickness data for the torus shell over time. The UT results and corrosion data are
 
trended for future reference. Analysis determines the most conservative value for the
 
corrosion rate. Visual inspection findings for the external support structure are compared
 
to previous inspection results. The staff found that the overall monitoring and trending
 
techniques proposed by the applicant manage the applicable aging effects effectively
 
and are acceptable.
3-158 The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.5 and concludes that this program attribute is acceptable.  (6)Acceptance Criteria - In ALRA Section B3.3 the applicant stated that the Torus Corrosion Monitoring Program establishes acceptance criteria for local thickness, average thickness, and corrosion rate of the torus wall. The minimum wall thickness and
 
corrosion rate limits are defined to ensure that wall thickness meets its required value
 
until the next scheduled inspection. The external support structures also are evaluated
 
to ensure that the intended functions are not lost prior to the next scheduled inspection.
 
The staff found these criteria acceptable as consistent with the criteria of the staff's
 
August 11, 1994, SER. The criteria ensure that the torus will continue to meet ASME
 
code requirements that the average minimum wall thickness of the torus shell be not
 
less than 0.431 inch.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.6 and concludes that this program attribute is acceptable.    (10)Operating Experience - In ALRA Section B3.3 the applicant stated that torus wall thinning was observed in the late 1980s following an extended plant shutdown. The
 
applicant stated that the wall thinning was attributed to the layup conditions inside the
 
torus during the extended shutdown. To cope with this plant-specific experience the staff
 
approved the NMP1 Torus Corrosion Monitoring Program in the SER dated August 25, 1992. The program later was updated and the staff evaluation of the updated program
 
was documented in the SER dated August 11, 1994. The applicant stated that review of
 
plant-specific operating experience revealed no discrepancies in the Torus Corrosion
 
Monitoring Program examinations. The applicant also stated that the Torus Corrosion
 
Monitoring Program is adjusted continually to account for industry experience and
 
research. The staff reviewed past inspection reports which indicate no significant
 
changes in the torus wall corrosion rate. Following this review the staff found that this
 
program will manage adequately aging effects on the torus wall and torus support
 
structure.
The staff confirmed that this program element satisfies the criteria of SRP-LR Section A.1.2.3.10 and concludes that this program attribute is acceptable.
UFSAR Supplement. In ALRA Section A1.1.36, the applicant provided the UFSAR supplement for the Torus Corrosion Monitoring Program. The staff reviewed this section and determined that
 
the information in the UFSAR supplement provides an adequate summary description of the
 
program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its review and audit of the applicant's Torus Corrosion Monitoring Program, the staff concludes that the applicant demonstrated that the effects of aging will be
 
adequately managed so that the intended functions 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 UFSAR supplement for this AMP and concludes that it provides an adequate summary
 
description of the program, as required by 10 CFR 54.21(d).
3-1593.0.4  Quality Assurance Program Attribut es Integral to Aging Management Programs Pursuant to 10 CFR 54.21(a)(3), a license renewal applicant is required to demonstrate that the effects of aging on structures and components subject to an AMR will be adequately managed
 
so that their intended functions will be maintained consistent with the CLB for the period of
 
extended operation. SRP-LR, Branch Technical Position RLSB-1, "Aging Management Review -
 
Generic," describes ten attributes of an acceptable AMP. Three of these ten attributes are
 
associated with the quality assurance activities of corrective action, confirmation processes, and
 
administrative controls. Table A.1-1, "Element s of an Aging Management Program for License Renewal," of Branch Technical Position RLSB-1 provides the following description of these
 
quality attributes:
* corrective actions - including root cause determination and prevention of recurrence, should be timely
* confirmation process - should ensure that preventive actions are adequate and that appropriate corrective actions have been completed and are effective
* administrative controls - should pr ovide a formal review and approval process SRP-LR, Branch Technical Position IQMB-1, "Quality Assurance For Aging Management Programs," notes that those aspects of the aging management program that affect quality of
 
safety-related structures, systems, and components are subject to the quality assurance
 
requirements of 10 CFR Part 50 Appendix B. Additionally, for NSR structures and components
 
subject to an AM the existing 10 CFR Part 50 Appendix B QA program may be used by the
 
applicant to address the elements of corrective actions, the confirmation process, and
 
administrative controls. Branch Technical Position IQMB-1 provides the following guidance with
 
regard to the quality assurance attributes of AMPs:
* SR structures and components are subject to 10 CFR Part 50 Appendix B requirements, which are adequate to address all quality-related aspects of an aging management
 
program consistent with the CLB of the facility for the period of extended operation.
* For NSR structures and components that are subject to an AMR for license renewal, an applicant has an option to expand the scope of its 10 CFR Part 50 Appendix B program
 
to include these structures and components to address corrective actions, the
 
confirmation process, and administrative controls for aging management during the
 
period of extended operation. In this case, the applicant should document such a
 
commitment in the NMP1 UFSAR and NMP2 USAR supplements according to
 
10 CFR 54.21(d).
3.0.4.1  Summary of Technical Information in the Amended Application In the original LRA and ALRA Appendix B.1.3, "Quality Assurance Program and Administrative Controls," the applicant described the quality attributes of the plant-specific AMPs. The
 
applicant stated that the 10 CFR Part 50 Appendix B program provides corrective actions, confirmation processes, and administrative contro ls for LR AMPs. Additionally, the scope of the program includes both SR and NSR SSCs subject to an AM for license renewal. In the original
 
LRA and ALRA Section B.1.3, the applicant provided the following generic description of the
 
quality attributes common to all the plant-specific AMPs:
3-160
* Corrective Actions - A single corrective actions process is applied regardless of the safety classification of the structure or component. Corrective actions are implemented through the initiation of a CR according to plant procedures established under
 
10 CFR 50 Appendix B. Site documents that implement aging management activities for
 
license renewal will direct that a CR be prepared according to those procedures
 
whenever unacceptable conditions are found (i.e., the acceptance criteria are not met).
Equipment deficiencies are corrected through the initiation of a Work Order (WO) according to plant procedures. Although equipment deficiencies may initially be
 
documented by a WO the corrective action process specifies that a CR also be initiated
 
if required.
* Confirmation Process - The focus of the confirmation process is on the follow-up actions that must be taken to verify effective im plementation of corrective actions. The measure of effectiveness is in correcting the adverse condition and preventing recurrence of
 
conditions significantly adverse to quality. Plant procedures include provisions for timely
 
evaluation of adverse conditions and implement ation of any corrective actions required including root cause determinations and prevention of recurrence. These procedures
 
provide for tracking, coordinating, monitoring, reviewing, verifying, validating, and
 
approving effective corrective actions to ensure that they are taken. The CR process
 
also monitors for potentially adverse tr ends. An adverse trend due to recurring adverse conditions will result in a CR. Aging management activities required for license renewal
 
also would uncover any unacceptable condition due to ineffective corrective action.
* Administrative Controls - Administrative controls provide information on procedures and other forms of administrative control documents as well as guidance on classification
 
documents into document types.
3.0.4.2  Staff Evaluation The staff reviewed the applicant's AMPs described in the original LRA and ALRA Appendices A,"Safety Analysis Report Supplement," and B, "Aging Management Programs and Activities."
This review was to assure that the aging management activities were consistent with the staff's
 
guidance of SRP-LR Section A.2, "Quality A ssurance for Aging Management Programs (Branch Technical Position IQMB-1)," on quality assurance attributes of AMPs.
The staff's evaluation found the descriptions and applicability of the plant-specific AMPs and their associated quality attributes, provided in the original LRA and ALRA Section B1.3, consistent with the staff's position on quality assurance for aging management. However, the
 
applicant has not described sufficiently the use of the quality assurance program and its
 
associated attributes (corrective action, confirmation process, and administrative controls) in the
 
narrations of AMPs in the original LRA and ALRA Sections A1, "NMP1 Updated Final Safety
 
Analysis Report (UFSAR) Supplement," and A2, "NMP2 Updated Safety Analysis Report (USAR) Supplement." In RAI 2.1-8 dated November 22, 2004 the staff requested that the applicant supplement the descriptions in Sections A1 and A2 to include a description including references to pertinent
 
guidance as necessary of the quality assurance program attributes credited for the programs
 
described in the original LRA and ALRA Section B1.3. The descriptions in ALRA Sections A1
 
and A2 should provide sufficient information for the staff to determine if the quality attributes for 3-161 the ALRA Sections A1 and A2 AMPs are consistent with the review acceptance criteria of SRP-LR Section A.2, "Quality Assurance fo r Aging Management Programs (Branch Technical Position IQMB-1)." In response to RAI 2.1-8 by letter dated December 22, 2004, the applicant stated, in part, that the original LRA Sections A1.2 and A2.5 were added to reflect the application of the quality
 
assurance program to the attributes of corrective action, confirmation, and document control.
 
Specifically, the additions in each section contained the following description along with
 
descriptions of each of the elements.
 
The quality assurance program implements the requirements of 10 CFR 50 Appendix B and is
 
consistent with the summary in SRP-LR Appendix A.2, "Standard Review Plan for the Review of
 
License Renewal Applications for Nuclear Power Plants," published July 2001. The "corrective
 
action," "confirmation process," and "administrative controls" elements of the quality assurance
 
program are applicable to both SR and NSR SSCs subject to an AM.
Furthermore, the applicant provided the staff with an ALRA submittal dated July 14, 2005, with additional details on the application of the quality assurance program to these three attributes.
 
The staff confirmed that the ALRA description was consistent with the prior response to the
 
request for additional information and the results of the staff's audit of the scoping and
 
screening methodology. On the basis of the supplemental information provided by the applicant
 
in response to the staff's request for information and the incorporation of that information into
 
the ALRA submittal the staff found that the applicant has addressed the request for additional
 
information adequately. Therefore, the staff's concern is resolved.
3.0.4.3  Conclusion The applicant described the quality attributes of the programs and activities for managing aging effects for both SR and NSR SSCs within the scope of license renewal and stated that the
 
10 CFR Part 50 Appendix B quality assurance program provides "corrective actions,"
 
"confirmation processes," and "administrative controls." The staff concludes that the quality
 
attributes of the applicant's AMPs, as described in the original LRA and ALRA Appendices A
 
and B, are consistent with 10 CFR 54.21(a)(3). Therefore, the applicant's quality assurance
 
description for its AMPs is acceptable.
 
===3.1 Aging===
Management of Reactor V essel, Internals, and Reactor CoolantSystems 3.1A  NMP1 Aging Management of Reactor Vessel, Internals, and Reactor CoolantSystems This section of the SER documents the staff's review of the applicant's AMR results for the reactor vessel, internals, and reactor coolant systems components and component groups
 
associated with the following NMP1 systems:
* reactor pressure vessel
* reactor pressure vessel internals
* reactor pressure vessel instrumentation system 3-162
* reactor recirculation system
* control rod drive system3.1A.1  Summary of Technical Information in the Amended Application In ALRA Section 3.1, the applicant provided AMR results for the reactor vessel, internals, and reactor coolant systems components and component groups. In ALRA Table 3.1.1.A, "NMP1 Summary of Aging Management Programs for the Reactor Vessel, Internals, and Reactor
 
Coolant Systems Evaluated in Chapter IV of NUREG-1801," the applicant provided a summary
 
comparison of its AMRs with the AMRs evaluated in the GALL Report for the reactor vessel, internals, and reactor coolant systems components and component groups.
The applicant's AMRs incorporated applicable operating experience in the determination of AERMs. These reviews included evaluation of plant-specific and industry operating experience.
 
The plant-specific evaluation included reviews of condition reports and discussions with
 
appropriate site personnel to identify AERMs. The applicant's review of industry operating
 
experience included a review of the GALL Report and operating experience issues identified
 
since the issuance of the GALL Report.
3.1A.2  Staff Evaluation The staff reviewed ALRA Section 3.1 to determine if the applicant provided sufficient information to demonstrate that the effects of aging for the reactor vessel, internals, and reactor coolant
 
systems components that are within the scope of license renewal and subject to an AMR will be adequately managed so that the intended functions will be maintained consistent with the CLB
 
for the period of extended operation, as required by 10 CFR 54.21(a)(3).
The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain identified 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 ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.
 
The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's
 
audit evaluation are documented in the Audit and Review Report and are summarized in SER
 
Section 3.1A.2.1.
In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicant's further
 
evaluations were consistent with the acceptance criteria in SRP-LR Section 3.1.2.2. The staff's
 
audit evaluations are documented in the Audit and Review Report and are summarized in SER
 
Section 3.1A.2.2.
In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were not consistent with, or not addressed in, the GALL Report. The audit and technical review
 
included evaluating whether all plausible aging effects were identified and evaluating whether
 
the aging effects listed were appropriate for the combination of materials and environments
 
specified. The staff's audit evaluations are documented in the Audit and Review Report and are
 
summarized in SER Section 3.1A.2.3. The staff's evaluation of its technical review is also
 
documented in SER Section 3.1A.2.3.
3-163 Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure that they provided an adequate description of the programs credited with managing or
 
monitoring aging for the reactor vessel, internals, and reactor coolant systems components.
Table 3.1A-1 below provides a summary of t he staff's evaluation of NMP1 components, aging effects and aging effects mechanisms , and AMPs listed in ALRA Section 3.1, that are
 
addressed in the GALL Report.
Table 3.1A-1  Staff Evaluation for NMP1 Reactor Vessel, Internals, and Reactor CoolantSystems Components in the GALL ReportComponent GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation Reactor coolant pressure boundary
 
components (Item Number
 
3.1.1.A-01)
Cumulative fatigue damageTLAA, evaluated inaccordance with 10 CFR 54.21(c)TLAAThis TLAA is evaluated in
 
Section 4.3, Metal Fatigue Analysis Steam generator shell assembly (Item Number
 
3.1.1.A-02)
Loss of material due to pitting and
 
crevice corrosion Inservice inspection;water chemistry Not applicable,PWR only Isolation condenser (Item Number
 
3.1.1.A-03)
Loss of material due to general, pitting, and crevice
 
corrosion Inservice inspection;water chemistry Preventive Maintenance
 
Program (B2.1.32),
ASME Sections XI
 
Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1), Water Chemistry Control
 
Program (B2.1.2)Consistent withGALL with exception, which
 
recommends further
 
evaluation (See
 
Section 3.1A.2.2.2)
Pressure vessel ferritic materials that
 
have a neutron
 
fluence greater than
 
10 17 n/cm 2 (E > 1 MeV)
(Item Number
 
3.1.1.A-04)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlementTLAA, evaluated inaccordance with
 
Appendix G of 10 CFR 50 and
 
RG 1.99TLAAThis TLAA is evaluated in
 
Section 4.2, Reactor
 
Vessel Neutron
 
Embrittlement Analysis Reactor vessel beltline shell and welds (Item Number
 
3.1.1.A-05)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlement Reactor vessel surveillance Reactor Vessel Surveillance
 
Program (B2.1.19)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.1A.2.2.3)Westinghouse and B&W baffle/former
 
bolts (Item Number 
 
3.1.1.A-06)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlement and void swellingPlant-specificNot applicable,PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-164 Small-bore reactorcoolant system and connected systems
 
piping (Item Number
 
3.1.1.A-07)
Crack initiation andgrowth due to SCC, intergranular SCC, and thermal and
 
mechanical loading Inservice inspection;water chemistry;
 
one-time inspectionASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1); Water Chemistry Control
 
Program (B2.1.2);
One-Time Inspection Program (B2.1.20) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.1A.2.2.4)
Jet pump sensing line, and reactor
 
vessel flange leak
 
detection line (Item Number
 
3.1.1.A-08)
Crack initiation andgrowth due to SCC, intergranular stress
 
corrosion cracking (IGSCC), or cyclic
 
loadingPlant-specificASME Sections XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1), Water Chemistry Control
 
Program (B2.1.2),
One-Time Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.1A.2.2.4)
Isolation condenser (Item Number
 
3.1.1.A-09)
Crack initiation andgrowth due to stress
 
corrosion cracking (SCC) or cyclic
 
loading Inservice inspection;water chemistryASME Sections XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1), Water Chemistry Control
 
Program (B2.1.2),
Preventive
 
Maintenance
 
Program (B2.1.32) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.1A.2.2.4)
Vessel shell (Item Number
 
3.1.1.A-10)Crack growth due tocyclic loadingTLAANot applicable,PWR only Reactor internals (Item Number
 
3.1.1.A-11)
Changes in dimension due to void swellingPlant-specificNot applicable,PWR onlyPWR core support pads, instrument
 
tubes (bottom head
 
penetrations),
pressurizer spray
 
heads, and nozzles
 
for the steam
 
generator instruments and
 
drains (Item Number
 
3.1.1.A-12)
Crack initiation andgrowth due to SCC
 
and/or primary water stress
 
corrosion cracking (PWSCC)Plant-specificNot applicable,PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-165 Cast austenitic stainless steel (CASS) reactor coolant system
 
piping (Item Number
 
3.1.1.A-13)
Crack initiation andgrowth due to SCCPlant-specificNot applicable,PWR only Pressurizer instrumentation
 
penetrations and
 
heater sheaths and
 
sleeves made of Ni-alloys (Item Number
 
3.1.1.A-14)
Crack initiation andgrowth due to
 
PWSCC Inservice inspection;water chemistry Not applicable,PWR onlyWestinghouse and B&W baffle former
 
bolts (Item Number
 
3.1.1.A-15)
Crack initiation andgrowth due to SCC
 
and IASCCPlant-specificNot applicable,PWR onlyWestinghouse and B&W baffle former
 
bolts (Item Number
 
3.1.1.A-16)
Loss of preload dueto stress relaxationPlant-specificNot applicable,PWR only Steam generatorfeedwater impingement plate
 
and support (Item Number
 
3.1.1.A-17)
Loss of section thickness due to
 
erosionPlant-specificNot applicable,PWR only(Alloy 600) Steam generator tubes, repair sleeves, and
 
plugs (Item Number
 
3.1.1.A-18)
Crack initiation andgrowth due to PWSCC, outside
 
diameter stress
 
corrosion cracking (ODSCC), and/or
 
intergranular attack (IGA) or loss of
 
material due to wastage and pitting
 
corrosion, and fretting and wear; or
 
deformation due to
 
corrosion at tube
 
support plate
 
intersections Steam generatortubing integrity; water chemistry Not applicable,PWR onlyTube support lattice bars made of
 
carbon steel (Item Number
 
3.1.1.A-19)
Loss of section thickness due to
 
FACPlant-specificNot applicable,PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-166 Carbon steel tube support plate (Item Number
 
3.1.1.A-20)
Ligament cracking due to corrosionPlant-specificNot applicable,PWR only Steam generatorfeedwater inlet ring
 
and supports (Item Number
 
3.1.1.A-21)
Loss of material dueto flow-corrosion Combustion engineering (CE)
 
steam generator feedwater ring
 
inspection Not applicable,PWR only Reactor vessel closure studs and
 
stud assembly (Item Number
 
3.1.1.A-22)
Crack initiation andgrowth due to SCC
 
and/or IGSCC Reactor head closure studs Reactor Head Closure Studs
 
Program (B2.1.3) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1.1)
CASS pump casing and valve body
 
pump casing and
 
valve body (Item Number
 
3.1.1.A-23)
Loss of fracture toughness due to
 
thermal aging
 
embrittlementInservice inspectionASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1)CASS piping (Item Number
 
3.1.1.A-24)
Loss of fracture toughness due to
 
thermal aging
 
embrittlementThermal aging embrittlement of
 
CASS Not applicable (CASS piping does
 
not exist)BWR piping and fittings; steam
 
generator components (Item Number
 
3.1.1.A-25)Wall thinning due toflow-accelerated
 
corrosionFlow-accelerated corrosionFlow-Accelerated Corrosion Program (B2.1.9)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1)Not applicable,PWR only.Reactor coolant pressure boundary (RCPB) valve
 
closure bolting, manway and
 
holding bolting, and
 
closure bolting in
 
high pressure and
 
high temperature systems (Item Number
 
3.1.1.A-26)
Loss of material dueto wear; loss of
 
preload due to stress relaxation;
 
crack initiation and growth due to cyclic
 
loading and/or SCCBolting integrityB olting Integrity Program (B2.1.36)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1)Not applicable,PWR only.
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-167Feedwater and control rod drive (CRD) return line
 
nozzles (Item Number
 
3.1.1.A-27)
Crack initiation andgrowth due to cyclic
 
loadingFeedwater nozzle; CRD return line
 
nozzleBWR Feedwater Nozzle Program (B2.1.5), BWR
 
Control Rod Drive
 
Return Line (CRDRL) Nozzle
 
Program (B2.1.37) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1.6)
Vessel shellattachment welds (Item Number
 
3.1.1.A-28)
Crack initiation andgrowth due to SCC, IGSCC BWR vessel IDattachment welds; water chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Vessel ID Attachment Welds (B2.1.4)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1)Nozzle safe ends, recirculation pump
 
casing, connected systems piping and fittings, body and
 
bonnet of valves (Item Number
 
3.1.1.A-29)
Crack initiation andgrowth due to SCC, IGSCC BWR stress corrosion cracking; water chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Stress Corrosion
 
Cracking Program (B2.1.6)Consistent withGALL, which
 
recommends no
 
further evaluation (See Sections 3.1A.2.1)
Penetrations (Item Number
 
3.1.1.A-30)
Crack initiation andgrowth due to SCC, IGSCC, cyclic
 
loadingBWR penetrations;water chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Vessel Internals
 
Program (B2.1.8),
BWR Penetrations
 
Program (B2.1.6)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1.3)
Core shroud and core plate, support
 
structure, top guide, core spray lines and
 
spargers, jet pump
 
assemblies, control
 
rod drive housing, nuclear instrumentation
 
guide tubes (Item Number
 
3.1.1.A-31)
Crack initiation andgrowth due to SCC, IGSCC, IASCC BWR vesselinternals; water
 
chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Vessel Internals
 
Program (B2.1.8)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1A.2.1)Core shroud and core plate access hole cover (welded
 
and mechanical
 
covers)
(Item Number
 
3.1.1.A-32)
Crack initiation andgrowth due to SCC, IGSCC, IASCCASME Section XI inservice inspection; water chemistry BWR Vessel Internals Program (B2.1.8), Water Chemistry Control
 
Program (B2.1.2)Consistent withGALL with exceptions (access
 
hole cover does not
 
exist in NMP1)
(See Section
 
3.1A.2.1)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-168 Jet pump assembly castings; orificed
 
fuel support (Item Number
 
3.1.1.A-33)
Loss of fracture toughness due to
 
thermal aging and
 
neutron irradiation
 
embrittlementThermal aging and neutron irradiation
 
embrittlement BWR Vessel Internals Program (B2.1.8)Consistent with GALL (See Section
 
3.1A.2.1.5)
Not applicable for jet pump components Unclad top head and nozzles (Item Number
 
3.1.1.A-34)
Loss of material due to general, pitting, and crevice
 
corrosion Inservice inspection;water chemistry Not applicable (NMP1 does not
 
have unclad top
 
head enclosure and
 
nozzles)CRD nozzle (Item Number
 
3.1.1.A-35)
Crack initiation andgrowth due to
 
PWSCCNi-alloy nozzles andpenetrations; water
 
chemistry Not applicable,PWR only Reactor vessel nozzles safe ends
 
and CRD housing;
 
reactor coolant system components (except CASS and
 
bolting)
(Item Number
 
3.1.1.A-36)
Crack initiation andgrowth due to cyclic
 
loading, and/or SCC and PWSCC Inservice inspection;water chemistry Not applicable,PWR only Reactor vessel internals CASS
 
components (Item Number
 
3.1.1.A-37)
Loss of fracture toughness due to
 
thermal aging, neutron irradiation
 
embrittlement, and void swellingThermal aging and neutron irradiation
 
embrittlement Not applicable,PWR only External surfaces of carbon steel
 
components in
 
reactor coolant system pressure
 
boundary (Item Number
 
3.1.1.A-38)
Loss of material due to boric acid
 
corrosionBoric acid corrosionNot applicable,PWR only Steam generatorsecondary manways
 
and handholds (CS)
(Item Number
 
3.1.1.A-39)
Loss of material due to erosionInservice inspectionNot applicable,PWR only Reactor internals, reactor vessel
 
closure studs, and
 
core support pads (Item Number
 
3.1.1.A-40)
Loss of material dueto wearInservice inspectionNot applicable,PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-169 Pressurizer integral support (Item Number
 
3.1.1.A-41)
Crack initiation andgrowth due to cyclic
 
loadingInservice inspectionNot applicable,PWR onlyUpper and lower internals assembly (Westinghouse)
(Item Number
 
3.1.1.A-42)
Loss of preload dueto stress relaxation Inservice inspection; loose part and/or
 
neutron noise
 
monitoring Not applicable,PWR only Reactor vessel internals in fuel
 
zone region [except Westinghouse and Babcock & Wilcox (B&W) baffle bolts]
(Item Number
 
3.1.1.A-43)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlement, and void swelling PWR vesselinternals; water
 
chemistry Not applicable,PWR only Steam generatorupper and lower
 
heads; tubesheets; primary nozzles and
 
safe ends (Item Number
 
3.1.1.A-44)
Crack initiation andgrowth due to SCC, PWSCC, IASCC Inservice inspection;water chemistry Not applicable,PWR only Vessel internals (except Westinghouse and
 
B&W baffle former
 
bolts)
(Item Number
 
3.1.1.A-45)
Crack initiation andgrowth due to SCC
 
and IASCC PWR vesselinternals; water
 
chemistry Not applicable,PWR only Reactor internals(B&W screws and
 
bolts)
(Item Number
 
3.1.1.A-46)
Loss of preload dueto stress relaxation Inservice inspection; loose part
 
monitoring Not applicable,PWR only Reactor vessel closure studs and
 
stud assembly (Item Number
 
3.1.1.A-47)
Loss of material dueto wear Reactor head closure studs Not applicable,PWR only Reactor internals(Westinghouse upper and lower
 
internal assemblies;
 
CE bolts and tie
 
rods)
(Item Number
 
3.1.1.A-48)
Loss of preload dueto stress relaxation Inservice inspection; loose part
 
monitoring Not applicable,PWR only 3-170 The staff's review of the NMP1 component groups followed one of several approaches. One approach, documented in SER Section 3.1A.2.1, discusses the staff's review of the AMR results
 
for components in the reactor vessel, internals, and reactor coolant systems that the applicant
 
indicated are consistent with the GALL Report and do not require further evaluation. Another
 
approach, documented in SER Section 3.1A.2.2, discusses the staff's review of the AMR results
 
for components in the reactor vessel, internals, and reactor coolant systems that the applicant
 
indicated are consistent with the GALL Report and for which further evaluation is recommended.
 
A third approach, documented in SER Section 3.1A.2.3, discusses the staff's review of the AMR
 
results for components in the reactor vessel, internals, and reactor coolant systems that the
 
applicant indicated are not consistent with, or not addressed in, the GALL Report. The staff's
 
review of AMPs that are credited to manage or monitor aging effects of the reactor vessel, internals, and reactor coolant systems components is documented in SER Section 3.0.3.3.1A.2.1  AMR Results That Are Consistent with the GALL Report Summary of Technical Information in the Amended Application. In ALRA Section 3.1.2.A, the applicant identified the materials, environments, and AERMs. The applicant identified the
 
following programs that manage the aging effects related to the reactor vessel, internals, and
 
reactor coolant systems components:
* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Water Chemistry Control Program
* Reactor Head Closure Studs Program
* BWR Vessel ID Attachment Welds Program
* BWR Feedwater Nozzle Program
* BWR Stress Corrosion Cracking Program
* BWR Penetrations Program
* BWR Vessel Internals Program
* Flow-Accelerated Corrosion Program
* Reactor Vessel Surveillance Program
* One-Time Inspection Program
* Selective Leaching of Materials Program
* Systems Walkdown Program
* Bolting Integrity Program
* BWR Control Rod Drive Return Line (CRDRL) Nozzle Program Staff Evaluation. In ALRA Tables 3.1.2.A-1 through 3.1.2.A-5, the applicant provided a summary of AMRs for the reactor vessel, internals, and reactor coolant systems components, and
 
identified which AMRs it considered to be consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report does not recommend further
 
evaluation, the staff performed an audit and review to determine whether the plant-specific
 
components contained in these GALL Report component groups were bounded by the GALL
 
Report evaluation.
The applicant provided a note for each AMR line item. The notes indicate how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with
 
Notes A through E, which indicate that the AMR is consistent with the GALL Report.
3-171 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report and the 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been
 
reviewed and accepted by the staff. The staff also determined whether the AMP identified by the
 
applicant was consistent with the AMP identified in the GALL Report 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 AMP identified by the GALL Report. This note indicates that the applicant
 
was unable to find a listing of some system components in the GALL Report. However, the
 
applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was 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 AMP identified in the GALL Report. 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. The staff verified whether
 
the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The
 
staff also determined whether the AMP identified by the applicant was consistent with the AMP
 
identified in the GALL Report 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 a different agi ng management program is credited. The staff audited these line items to verify consistency with the GALL Report. The staff also determined
 
whether the identified AMP would manage the aging effect consistent with the AMP identified by
 
the GALL Report and whether the AMR was valid for the site-specific conditions.
The staff conducted an audit and review of the information provided in the ALRA, as documented in the Audit and Review Report dated January 5, 2006. 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 ALRA was applicable and that the applicant identified the appropriate
 
GALL Report AMRs. The staff's evaluation is discussed below.
3.1A.2.1.1  Crack Initiation and Growth Due to SCC and/or IGSCC
 
In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-22, the applicant stated that loss of material due to general corrosion of closure head studs and nuts will be managed using the
 
Reactor Head Closure Studs Program. As documented in the Audit and Review Report, the staff 3-172 noted that ALRA Table 3.1.1.A, Item 3.1.1.A-22 applies to managing the aging effect and aging effect mechanism of cracking and requested that the applicant provide clarification In its letter dated December 1, 2005, the applicant responded revising the ALRA Table 3.1.1.A, Item 3.1.1.A-22 discussion column by deleting the reference to managing loss of material and
 
crediting the aging effect and aging effect mechanism of crack initiation and growth due to SCC.
 
The staff found this change consistent with the GALL Report and therefore acceptable.
In its review, the staff found that the applicant had addressed the aging effect and aging effect mechanism appropriately as recommended by the GALL Report.
3.1A.2.1.2  Loss of Material Due to Wear; Loss of Preload Due to Stress Relaxation; Crack Initiation and Growth Due to Cyclic Loading and/or SCC In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-26, the applicant stated that loss of material due to wear; loss of preload due to stress relaxation, crack initiation and growth due
 
to cyclic loading and/or SCC of the reactor coolant pressure boundary (RCPB) valve closure
 
bolting, manway and holding bolting, and closure bolting in high-pressure and high-temperature
 
systems will be managed using the Bolting Integr ity Program. As documented in the Audit and Review Report, the staff asked the applicant why Note E is used in ALRA Tables 3.1.2.A-3 and
 
3.1.2.A-5 when closure bolting will be managed with the applicant's Bolting Integrity Program.
In a letter dated December 1, 2005, the applicant stated that Note E in ALRA Tables 3.1.2.A-3 and 3.1.2.A-5 will be changed to Note B. The staff found this change consistent with the GALL
 
Report and, therefore, acceptable.
In its review the staff found that the applicant had addressed the aging effect and aging effect mechanism appropriately as recommended by the GALL Report.
3.1A.2.1.3  Crack Initiation and Growth Due to SCC, IGSCC, and/or Cyclic Loading
 
In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-30 the applicant stated that crack initiation and growth due to SCC, IGSCC, and/or cyclic loading of penetrations will be managed
 
using the Water Chemistry Control Program and BWR Vessel Internals Program. The applicant
 
also stated that aging of the CRD stub tube penetrations is managed according to BWRVIP-47, "BWR Lower Plenum Inspection and Flaw Evaluation Guidelines," of the applicant's BWR
 
Vessel Internals Program and plant-specific commitments contained in the NRC safety
 
evaluation dated March 25, 1987.
In RAI 3.1.2-1 dated January 13, 2005, the staff requested that the applicant address the difference between the alternative repair roll/expansion techniques and acceptable ASME Code
 
weld repair methods for NMP1 CRD stub tube penetrations experiencing leakage.
In its response by letter dated February 14, 2005, the applicant stated, "NMP committed to implement a strategy whereby during the peri od of extended operation a leaking control rod drive (CRD) stub tube penetration would be roll repaired. If following the roll repair, this stub
 
tube was to leak within acceptable limits, then a weld repair would be effected no later than one
 
operating cycle following discovery of the leakage." In the original LRA, the applicant stated that
 
it will follow the status of the proposed ASME Code change as to roll/expansion techniques of
 
CRD stub tubes and will implement the final code change or provide an alternative plan for the 3-173 NMP1 period of extended operation at least one year prior to the expiration of the current operating license (NMP1 Commitment 36).
As documented in the Audit and Review Report, the staff noted that the wording in ALRA Table 3.1.1.A, Item 3.1.1.A-1 and in the applicant's response to RAI 3.1.2-1 imply that NMP1
 
will operate with CRD stub tube leakage for one operating cycle (two years). The staff did not
 
consider this implication acceptable for the period of extended operation. The safety evaluation
 
dated March 25, 1987, allowing NMP1 to operate with CRD stub tube leakage was acceptable
 
only as a temporary repair. Specifically, Item (6) of the staff's conclusions in the safety
 
evaluation stated, "The proposed leakage criteria provides sufficient time to complete the final
 
development of the prototype mechanical seal and associated tooling and investigate other
 
methods such as weld repair."
In a-RAI 3.1.2-1 dated November 2, 2005, the staff requested that the applicant justify the CRD stub tube leakage repair operation.
In its response by letter dated November 30, 2005, the applicant stated that it had removed the statement of plant-specific commitments contained in the NRC safety evaluation dated
 
March 25, 1987, and replaced it with the following statements:
If the 10/19/05 draft of Code Case N-730 is approved by the ASME, NMP1 will implement the final code case as conditioned by the NRC. If the code case is not
 
approved by the ASME, NMP1 will seek NRC approval of the 10/19/05 code
 
case draft on a plant specific basis as conditioned by the NRC.
During the period of extended operation, should a CRD stub tube rolled in accordance with the provisions of the code case resume leaking, NMP will
 
implement one of the following zero leakage permanent repair strategies prior to
 
startup from the outage in which the leakage was detected:1.A welded repair consistent with BWRVIP-58-A, "BWRVIP Internal Access Weld Repair" and Code Case N-606-1, as endorsed by
 
the NRC in Regulatory Guide 1.147.2.A variation of the welded repair geometry specified in BWRVIP-58-A subject to the approval of the NRC using Code
 
Case N-606-1.3.A future developed mechanical/welded repair method subject to the approval of the NRC.
The staff reviewed the applicant's response and found it consistent with the GALL Report and, therefore, acceptable.
In ALRA Table 3.1.2.A-1, the applicant stated that crack initiation and growth due to SCC, IGSCC, and/or cyclic loading of penetrations will be managed using the Water Chemistry Control Program, BWR Penetrations Program, and BWR Vessel Internals Program. As
 
documented in the Audit and Review Report, the staff asked the applicant to clarify which
 
components were managed by its BWR Vessel Internals Program. The applicant responded 3-174 that the component type penetrations discussed on ALRA Table 3.1.2.A-1include the CRD stub tube and flux monitor penetrations covered by BWRVIP-47. The staff noted that GALL AMP XI.M8, "BWR Penetration Program," covers BWRVIP-27, which addresses the standby liquid control system nozzle or housing, and BWRVIP-49, which
 
provides guidance for instrument penetrations. As documented in the audit and review, the
 
applicant responded that the CRD stub tube and flux monitor penetrations are managed by
 
BWRVIP-47, which is part of the BWR Vessel Internals Program. The applicant also responded
 
that its Water Chemistry Control Program is applicable to all vessel penetrations; therefore, the
 
line in the ALRA crediting the applicant's BWR Vessel Internals Program also should include the
 
applicant's Water Chemistry Control Program.
In its letter dated December 1, 2005, the applicant supplemented its ALRA with the following changes: (1) the discussion column for ALRA Table 3.1.1.A, Item 3.1.1.A-30 was revised to add
 
the flux monitor penetrations managed by the app licant's BWR Vessel Internals Program; (2) the line item entry for the BWR Vessel Internals Program for penetrations in ALRA
 
Table 3.1.2.A-1 was revised to include the Water Chemistry Control Program. The staff
 
reviewed the applicant's response and found it consistent with the GALL Report and, therefore, acceptable. Therefore, the staff's concern described in a-RAI 3.1.2-1 is resolved.
In its review the staff found that the applicant had addressed the aging effect and aging effect mechanism appropriately as recommended by the GALL Report.
3.1A.2.1.4  Crack Initiation and Growth Due to SCC, IGSCC and/or IASCC
 
In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-31 the applicant stated that crack initiation and growth due to SCC, IGSCC, and/or IASCC of the core shroud and core plate, support structure, top guide, core spray lines and spargers, control rod drive housing, and
 
nuclear instrumentation guide tubes will be managed using the Water Chemistry Control
 
Program and BWR Vessel Internals Program. As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.1.2.A-2, for example, the applicant's use of Note D, which
 
is credited for the control rod guide tube (CRGT), is not appropriate when comparing CRGTs
 
with the GALL Report and asked the applicant to clarify why Note D is used.
The applicant responded that Note D should be replaced with Note B. Note B is used because the applicant takes exception for its Water Chemistry Control Program. The latest version of the
 
water chemistry guidelines will be implemented in lieu of the guideline provided in BWRVIP-29 (TR-103515), "BWR Water Chemistry Guidelines - Normal and Hydrogen Water Chemistry."
 
The staff found this implementation acceptable as consistent with the definition of Note B as
 
identified in Nuclear Energy Institute (NEI) 95-10.
In ALRA Table 3.1.2.A-2 the applicant stated that core shroud head bolts and collars will be managed by its BWR Vessel Internals Program with Note D. The staff review found no specific
 
BWR Vessel Internals Program report for this component type. As documented in the Audit and
 
Review Report, the staff asked the applicant to provide additional information as to how its BWR
 
Vessel Internals Program will manage this item along with details of how the applicant inspects
 
core shroud head bolts based on operating experience. The applicant explained that its BWR
 
Vessel Internals Program manages aging of core shroud head bolts and collars. The applicant's
 
BWR Vessel Internals Program includes inspection of NSR components that could impact plant
 
operations. These inspections rely heavily on industry operating experience and such vendor 3-175 information as GE Nuclear Energy SILs. Based on industry operating experience (SIL 433 and SIL 433 Supplement 1) the applicant's BWR Vessel Internals Program includes a UT inspection
 
program for the shroud head bolts and collars susceptible to IGSCC. Additionally, plant-specific
 
operating experience (SIL 554) already has found evidence of fretting wear of the locking pins and improperly locked shroud head bolts. For thes e reasons the applicant implemented its BWR Vessel Internals Program to manage aging of core shroud head bolts and collars. As
 
documented in the Audit and Review Report, the staff reviewed the applicant's program basis
 
document and determined that aging of core shroud head bolts and collars is adequately
 
managed using the applicant's BWR Vessel Internals Program.
In ALRA Table 3.1.2.A-2 the applicant credited its BWR Vessel Internals Program for managing aging of the liquid poison spray line and sparger. As documented in the Audit and Review
 
Report, the staff noted that there was no specific BWRVIP report for this component type and
 
asked the applicant to clarify how BWRVIP manages the item with no report for it.
As documented in the Audit and Review Report, the applicant stated that BWRVIP-27, "BWR Vessel and Internals Project, BWR Standby Liquid Control System/Core Plate P Inspection and Flaw Evaluation Guidelines," and BWRVIP-47-A, "BWR Lower Plenum Inspection and Flaw
 
Evaluation Guidelines," are in the basis documents for management of spray line and sparger
 
aging. The basis for BWRVIP-27 aging management is that the spray line connection to the
 
vessel requires inspection while the sparger does not. Both components, however, fall within
 
BWRVIP-47-A baseline requirements. BWRVIP-47-A requires baseline inspection of all
 
components located below the core plate when access is provided. In addition the NRC
 
approval letter of BWRVIP-47-A required at a minimum visual inspection of 5 percent of all
 
welds or components within the first six years of the period, including the liquid poison line and
 
sparger below the core plates. The staff found this basis consistent with the recommendation of
 
the GALL Report and, therefore, acceptable.
In its review the staff found that the applicant had addressed the aging effect and aging effect mechanism appropriately as recommended by the GALL Report.
3.1A.2.1.5  Loss of Fracture Toughness Due to Thermal Aging and Neutron Irradiation Embrittlement In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-33 the applicant stated that this item is not applicable for the jet pump components as NMP1 has no jet pumps. Aging
 
management of the orificed fuel supports is conducted according to BWRVIP-47 using GALL AMP XI.M9, "BWR Vessel Internals Program."The GALL Report recommends GALL AMP XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement," to manage the aging effect and aging effect mechanism of loss of fracture
 
toughness due to thermal aging and neutron embrittlement. In a letter dated November 17, 2005, the applicant revised its AMP B2.1.8, "BWR Vessel Internals Program," to address the
 
management of loss of fracture toughness due to neutron fluence and thermal embrittlement for
 
CASS components. The staff's review and evaluation of the applicant's BWR Vessel Internals
 
Program are documented in SER Sections 3.0.3.2.6. The staff found the applicant's BWR
 
Vessel Internals Program acceptable for managing the loss of fracture toughness because the applicant stated that it will meet the GALL AMP XI.M13 recommendations.
3-176 In its review the staff found that the applicant had addressed the aging effect and aging effect mechanism appropriately as recommended by the GALL Report.
3.1A.2.1.6  Crack Initiation and Growth Due to Cyclic Loading
 
In the discussion section of ALRA Table 3.1.1.A, Item 3.1.1.A-27 the applicant stated that NMP1 manages aging of feedwater nozzles with the BWR Feedwater Nozzle Program, consistently with GALL AMP XI.M5, "Feedwater Nozzle." The applicant also stated that GALL AMP X1.M5 is
 
credited with managing cracking of feedwater nozzle thermal sleeves due to SCC. The absence
 
of nozzle cracking proves that the thermal sleeve intended function is not degraded. In addition
 
the applicant stated that for CRDRL nozzles NMP1 manages aging with the BWR CRDRL
 
Nozzle Program, which is consistent with GALL AMP XI.M6, "BWR Control Rod Drive ReturnLine Nozzle." The applicant also credited GALL AMP X1.M6 with managing CRDRL nozzle
 
thermal sleeves cracking due to SCC. The applicant stated that the absence of nozzle cracking
 
proves that the thermal sleeve intended function is not degraded. In a letter dated September
 
15, 2005, the applicant stated that its BWR Feedwater Nozzle and BWR CRDRL Nozzle
 
Programs had been removed as the programs credited for the feedwater nozzle and CRDRL
 
nozzle thermal sleeves.
As documented in the Audit and Review Report, the staff asked the applicant to address the aging management for the thermal sleeves. In a letter dated December 1, 2005, the applicant
 
responded that it will use inspections performed under the BWR Vessel Internals Program using
 
surrogate components more readily accessible for examination. For NMP1 the surrogate components will be the feedwater sparger end bracket welds. In this letter the applicant also
 
provided its basis for choosing the feedwater sparger end bracket welds:
The NMP1 feedwater nozzle thermal sleeves are fabricated from nickel-based Alloy 600 (Inconel 600). A full penetration weld joins the thermal sleeve to the
 
outboard end of the carbon steel feedwater sparger. This weld was made with
 
Alloy 82 and Alloy 182 weld fillers. The thermal-sleeve to sparger weld, or the
 
heat affected zone in the Alloy 600 base material, is considered the most likely
 
location for IGSCC in the thermal sleeve.
The applicant added that each feedwater sparger is supported by end brackets which provide a spring force that helps hold the thermal sleeve in place. The feedwater sparger end bracket
 
welds consist of three welds, the sparger arm to sparger end plate welds (Weld #1), sparger
 
end plate to bracket end plate weld (Weld #2), and the sparger bracket end plate to end bracket
 
assembly welds (Weld #3), which are dissimilar metal welds that use Alloy 182 or 82 weld fillers.
In addition the applicant stated that SCC of the feedwater thermal sleeves or the associated welds is possible but is considered less likely than for other welds with the same weld filler as
 
the feedwater sparger because the inconel-to-carbon steel welds are heat-treated shop welds
 
and not creviced. Service experience has demonstr ated that Alloy 82 is resistant to IGSCC in BWR coolant. Alloy 182 is less resistant to IGSCC than Alloy 82 but has performed acceptably
 
with aggravating factors like lack of fusion or a creviced condition. These conditions are more
 
likely in field welds. The Alloy 600-to-carbon steel welds in the thermal sleeve are full-
 
penetration welds and do not create a creviced condition. Additionally, the thermal sleeve
 
assembly was heat-treated after welding. The #1 end bracket welds use Alloy 182 filler metal in
 
a mildly creviced condition, making them more susceptible to IGSCC than the thermal
 
sleeve-to-sparger welds. Additionally, the #1 weld s are exposed on the outer diameter to reactor 3-177 coolant chemistry which has a higher ECP and thus is more likely to cause IGSCC than feedwater, which has a much lower ECP. Therefore, the applicant stated, if cracking is not
 
found in the #1 welds inspection of the thermal sleeve-to-sparger welds is not necessary.
Furthermore, the applicant stated that the most susceptible of the three feedwater sparger end bracket welds (Weld #2) are subject to EVT-1 under BWRVIP. If cracking is found in these
 
welds the other end bracket welds (#1 and #3) are inspected. If cracking is found in the less
 
susceptible end bracket welds the necessity to inspect the thermal sleeve-to-sparger welds will
 
be evaluated. The applicant's BWR Vessel Internals Program will, therefore, be credited with
 
managing cracking of the thermal sleeve as the susceptibility of the critical thermal sleeve weld
 
to IGSCC is bounded by other welds inspected under the applicant's BWR Vessel Internals
 
Program. In its letter dated December 1, 2005, the applicant revised the ALRA to add an EVT-1
 
examination of the NMP1 feedwater sparger brackets as an enhancement to the BWR Vessel
 
Internals Program to address this issue. The staff reviewed the applicant's response and found
 
it acceptable because the applicant demonstrated that inspection of surrogate components
 
bounds the feedwater thermal sleeve.
In a letter dated December 1, 2005, the applicant also provided operating experience to address the CRDRL nozzle thermal sleeves as follows:
The inspections of the CRDRL nozzle and safe-ends in 1978 identified IGSCC cracking of the safe-end material, but did not identify fatigue-related cracking.
 
The CRDRL safe-end and the thermal sleeve were replaced in 1978 with design
 
changes to improve resistance to both IGSCC and fatigue. The replacement
 
thermal sleeve material is IGSCC resistant low carbon Type 316L stainless steel
 
material. The thermal sleeve is welded to the safe-end with low carbon Type
 
308L weld filler. To reduce the probability of fatigue, the thermal sleeve pipe
 
protrudes 7 inches out from the flow shie ld which promotes mixing away from the vessel wall thus preventing thermal cycling at the vessel wall and at the flow
 
shield.The applicant stated that as a result of industry operating experience from 2002 and 2003 it completed detailed thermal fatigue assessments and augmented inspections of the safe-end, the thermal sleeve attachment weld to the safe-end, and the thermal sleeve weld to the flow
 
shield. These inspections were performed in 2004 and 2005. The inspections to date have
 
detected no IGSCC or thermal fatigue-related cracking. Because the 2003 operating experience
 
identified cracking of the thermal shield flow baffle on the thermal shield additional EVT-1s of
 
the thermal shield to flow shield weld from the vessel ID are planned for 2007 and at a 10-year
 
frequency thereafter consistent with the ISI inspection interval. This EVT-1 examination of the
 
CRDRL thermal sleeve flow shield weld visible from the vessel ID during each ISI interval is
 
consistent with the frequency adopted for the feedwater nozzle surrogate weld location on the
 
feedwater end brackets.
In addition the applicant stated that a one-time UT of the CRDRL safe-end base metal was performed in 2004 under the NMP augmented ISI pr ogram 26 years of operation after the 1978 replacement (three outages prior to the license renewal term). This inspection detected no
 
IGSCC or thermal fatigue cracking of the safe-end location. The inspection was a manual
 
performance demonstration initiative (PDI) qualified inspection and the PDI mockup included the
 
thermal sleeve attachment weld to the safe-end. The exam records note the presence of the
 
thermal sleeve attachment weld. This exam is considered sufficient to detect significant 3-178 circumferential IGSCC cracking of the thermal sleeve at the thermal sleeve attachment weld; however, consistent with the surrogate weld inspection methodology employed for the
 
feedwater nozzle thermal sleeve, the EVT-1 inspection of the thermal sleeve flow shield weld
 
also will be used as a surrogate weld inspection location for the thermal sleeve to safe-end
 
attachment weld.
In addition to the inspections, the applicant added, temperature monitoring for thermal cycling was performed to confirm that the CRD return flow rates were sufficient at NMP1 to ensure that
 
no unstable thermal cycling from hot reactor water return flow occurs at NMP1. The testing and
 
analyses confirmed the sufficiency of the CRD return flow for stable return line conditions with
 
no reverse flow, The overall assessment, according to the applicant, was that the safe-end and thermal sleeve replacement with IGSCC-resistant materials and the one-time UT of the thermal sleeve
 
attachment weld after 26 years confirms that the thermal sleeve attachment weld is not a high-
 
risk IGSCC location. In addition the thermal monitoring of this location and the inspection after
 
26 years of operation also confirmed that no high-cycle thermal fatigue conditions at this
 
location could create high thermal cycle fatigue-related cracking.
Furthermore, the applicant continued, the analyses and one-time inspections in 2004-2005 are adequate to detect potential cracking from either IGSCC or fatigue of the CRDRL nozzle
 
thermal sleeve to safe-end attachment weld. Even though IGSCC is considered a low
 
probability for this location because of the materials of construction the BWRVIP program will
 
include an enhancement starting in 2007. An EVT-1 inspection of the thermal shield to flow
 
shield weld from the vessel ID will be performed at that time and at a 10-year frequency
 
consistently with the ISI interval.
The applicant also stated that in addition to the condition of the flow shield weld this EVT-1 inspection of the thermal sleeve flow shield weld will be a surrogate inspection of the thermal
 
sleeve to the safe-end attachment weld. In its letter dated December 1, 2005, the applicant
 
revised its ALRA as follows:1.ALRA Sections A1.1.12, A1.4, and B2.1.8 were revised to incorporate the commitment [NMP1 Commitment 40] to perform the EVT-1 inspection of
 
the thermal shield to flow shield weld starting in 2007 and proceeding at a
 
10-year frequency consistent with the ISI inspection interval thereafter.2.ALRA Table 3.1.1.A-1, Item 3.1.1.A-27 and ALRA Table 3.1.2.A-1 were revised to reflect the changes.
The staff reviewed the applicant's response and found it acceptable as the applicant's surrogate weld inspection, in addition to the results of its one-time inspections in 2004 to 2005, provide
 
adequate aging management for the CRDRL thermal sleeve.
In its review the staff found that the applicant had addressed the aging effect and aging effect mechanism appropriately for NMP1 CRDRL nozzle thermal sleeves to meet the
 
recommendation of the GALL Report.
Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicant's consideration of recent operating 3-179 experience and proposals for managing associated 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 consistent with the AMRs in the GALL Report. Therefore, the staff concludes
 
that there is reasonable assurance that the applicant had 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 for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).3.1A.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended Summary of Technical Information in the Amended Application. In Section 3.1.2.C of its letter dated August 19, 2005, the applicant provided further evaluation of aging management, for
 
NMPNS, as recommended by the GALL Report for the reactor vessel, internals, and reactor
 
coolant systems components. The applicant provi ded information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* loss of material due to pitting and crevice corrosion
* loss of fracture toughness due to neutron irradiation embrittlement
* crack initiation and growth due to thermal and mechanical loading or stress corrosion cracking
* crack growth due to cyclic loading
* changes in dimension due to void swelling
* crack initiation and growth due to stress corrosion cracking or primary water stress corrosion cracking
* crack initiation and growth due to stress corrosion cracking or irradiation-assisted stress corrosion cracking
* loss of preload due to stress relaxation
* loss of section thickness due to erosion
* crack initiation and growth due to PWSCC, ODSCC, or intergranular attack or loss of material due to wastage and pitting corrosion or loss of section thickness due to fretting
 
and wear or denting due to corrosion of carbon steel tube support plate
* loss of section thickness due to flow-accelerated corrosion
* ligament cracking due to corrosion
* loss of material due to flow-accelerated corrosion Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends
 
further evaluation, the staff audited and reviewed the applicant's evaluation to determine
 
whether it adequately addressed the issues that were further evaluated. In addition, the staff
 
reviewed the applicant's further evaluations against the criteria contained in SRP-LR 3-180 Section 3.1.2.2. Details of the staff's audit are documented in the staff's Audit and Review Report. The staff's evaluation of the aging effects is discussed in the following sections.
3.1A.2.2.1  Cumulative Fatigue Damage
 
In Section 3.1.2.C.1 of its letter dated August 19, 2005, the applicant stated 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 staff's review of the applicant's evaluation
 
of this TLAA.
As documented in the Audit and Review Report, the staff noted that on ALRA Table 3.1.2.A-2 fatigue damage of CRD assemblies (including drive mechanism and housing) will be managed
 
through the TLAA but in ALRA Sections B.2.1-8 the applicant stated that there were no TLAAs.
 
The staff asked the applicant to explain how the specified components are managed for NMP1.
 
The applicant responded that the only reactor vessel internals components for NMP1 with
 
calculations or analyses meeting TLAA criteria are the core shroud tie rod assemblies, the
 
clamps, and the CRD assemblies (including drive mechanism and housing). The tie rod
 
assemblies and clamps are repairs for horizontal and vertical core shroud welds which had
 
ASME III-type stress and fatigue analyses performed during the design process. The pressure
 
boundary portion of the CRD assemblies was evaluated for fatigue. A cumulative usage factor
 
was determined for the CRD penetration including the stub tube, CRD housing, and the stub
 
tube-to-vessel weld and housing-to-stub tube weld. The AMR for the stub tube is addressed in
 
ALRA Table 3.1.2.A-1. The applicant also responded that for reactor vessel internals
 
components where there is no analysis meeting TLAA criteria the AMP column of ALRA
 
Table 3.1.2.A-2 will be modified to replace "TLAA evaluated in accordance with 10 CFR
 
54.21(c)" with "None." A plant-specific note referencing the relevant BWRVIP inspection and
 
evaluation guideline or other basis for not managing fatigue will be added to ALRA
 
Table 3.1.2.A-2 for each component with "None" in the AMP column for the aging effect and
 
aging effect mechanism of cumulative fatigue damage or where the TLAA is applicable only to a
 
subset of the component type.
In its letter dated December 1, 2005, the applicant responded by revising ALRA Tables 3.1.2.A-2 and 3.1.2.B-2 to address this issue. The staff determined that a high
 
cumulative fatigue usage factor indicates a high potential for crack initiation. Although the
 
applicant's response removed the aging effect of cumulative fatigue damage for those
 
components identified in the December 1, 2005 letter the aging effect of cracking is adequately
 
managed through other AMPs.
The staff reviewed the response and found the applicant's action consistent with the GALL Report and therefore acceptable.
3.1A.2.2.2  Loss of Material Due to Pitting and Crevice Corrosion
 
The staff reviewed Section 3.1.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.2.
In Section 3.1.2.C.2 of a letter dated August 19, 2005, the applicant addressed loss of material of isolation condenser components due to general pitting and crevice corrosion.
3-181 SRP-LR Section 3.1.2.2.2.2 states that loss of material due to pitting and crevice corrosion could occur in BWR isolation condenser components. The existing program relies on control of reactor water chemistry to mitigate corrosion and on ASME Sections XI ISI. However, the
 
existing program should be augmented to detect loss of material due to pitting or crevice
 
corrosion. The GALL Report recommends an augmented program to include temperature and
 
radioactivity monitoring of the shell-side water and eddy current testing of tubes to ensure that
 
the component's intended function will be maintained during the period of extended operation.
The applicant stated in Section 3.1.2.C.2 of its letter dated August 19, 2005, that NMP1 has emergency (isolation) condensers (ECs). The design of the emergency condensers features
 
end bells welded to the EC shell that are not designed to be removed; therefore, eddy current
 
testing of the tubing is not possible. Loss of material is managed by a combination of several
 
programs. The Water Chemistry Control Program controls chemical contaminants in both the tube and shell side water to prevent conditions that would promote pitting and crevice corrosion.
 
The EC tube side, which is ASME Class 2, is subject to a system inservice pressure test under the ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program. The pressure test would
 
detect a tube leak caused by pitting or crevice corrosion. The EC shell is ASME Class 3 and
 
subject to a functional test under the applicant's Inservice Pressure Testing Program, which is part of its ASME Sections XI (Subsections IWB, IWC, and IWD) ISI Program. The functional test
 
would detect loss of material due to pitting and crevice corrosion if the corrosion caused a
 
through-wall leak of the EC shell.
In Section 3.1.2.C.2 of its letter dated August 19, 2005, the applicant also stated that for additional verification that a tube leak does not exist NMP1 will implement an online tube
 
leakage test. The test will be performed by isolating the makeup and drain valves to the
 
emergency condenser tube side and monitoring the shell side level for 24 to 48 hours for any
 
increase in water level on the shell side indicating tube leakage. The online test will be
 
incorporated as a new activity in the Prev entive Maintenance Program and will be implemented prior to the period of extended operation.
The staff's review and evaluations of the applicant's Water Chemistry Control and ASMESections XI (Subsections IWB, IWC, and IWD) ISI and Preventive Maintenance Programs are
 
documented in SER Sections 3.0.3.2.2, 3.0.3.2.1, and 3.0.3.3.1, respectively.
The applicant further stated in Section 3.1.2.C.2 of its letter dated August 19, 2005, that its Preventive Maintenance Program is also credited for managing loss of material due to pitting
 
and crevice corrosion because it includes the temperature monitoring of the emergency cooling
 
system including the heat exchangers. Continuous radiation monitoring of the EC shell side vents also would indicate a tube leak.
In addition in Section 3.1.2.C.2 of its letter dated August 19, 2005, the applicant stated that because none of the activities would detect loss of material due to pitting and crevice corrosion
 
before a leak occurred these activities will be supplemented by a visual inspection for cracking
 
and loss of material of the accessible outer surfaces of the peripheral tubes, tube sheet, and
 
emergency condenser shell. This activity also will be incorporated into the applicant's
 
Preventive Maintenance Program.
As documented in the Audit and Review Report dated January 18, 2006, the staff noted that inaccessibility alone cannot justify exemption from inspection where required for aging
 
management and operating experience (documented in IEB 76-01, "BWR Isolation Condenser 3-182 Tube Failure") indicates tube cracking as an issue. As documented in the Audit and Review Report, the staff asked the applicant to provide additional justification addressing this issue. The
 
applicant responded that the aging management activities provide adequate assurance with no
 
need for eddy current testing that any tube degradation in the isolation condensers will not lead
 
to a loss of intended function. These activities include water chemistry control, temperature
 
monitoring of the shell side and tube side water, continuous radioactivity monitoring of the
 
condenser vent line, periodic performance testing, and a future on-line tube leakage test. NMP1
 
has experienced tube leakage previously and replaced the whole tube bundle with upgraded
 
material in 1997. A keep-fill modification also was installed to eliminate the stressor which
 
caused the tube failures. Therefore, the applicant continued because the original isolation
 
condenser tubes lasted 28 years with an aging stressor the new tubes are expected to perform
 
their intended function through the period of extended operation with improved material and
 
upgraded system design and monitoring.
As documented in the Audit and Review Report dated January 18, 2006, the staff during its audits in the week of September 19, 2005, asked the applicant to provide its basis for not
 
performing eddy current testing. In its letter dated December 1, 2005, the applicant provided its
 
basis as follows:1) Monitoring and detection of conditions in the steam inlet (tube side) and shell side of the isolation condensers ensures conditions will not re-occur.
a)Water temperature b)Water chemistry (conductively, chloride, nitrates, sulfates)2)A commitment has been made to perform a tube leak test at operating pressure to detect small leaks (NMP1 Commitment 29 and NMP2 Commitment 27).
The staff reviewed the applicant's nuclear commitment tracking list to confirm that the online tube leakage test will be implemented as a new ac tivity in the Preventive Maintenance Program as indicated in Commitment 29 of ALRA Section A1.4. The staff reviewed the applicant's
 
response and determined that NMP1 isolation condenser tube aging is adequately managed
 
and that the tubes will be able to perform their intended function for at least an additional 23
 
years to the end of the period of extended operation.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.1.2.2.2. For those line items that
 
apply to Section 3.1.2.C.2 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.1A.2.2.3  Loss of Fracture Toughness due to Neutron Irradiation Embrittlement
 
The staff reviewed Section 3.1.2.C.3 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.1.2.2.3.
In Section 3.1.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of fracture toughness due to neutron irradiation embrittlement of the reactor vessel.
3-183 SRP-LR Section 3.1.2.2.3 states that certain aspects of neutron irradiation embrittlement are TLAAs as defined in 10 CFR 54.3 and that TLAAs must be evaluated in accordance with
 
10 CFR 54.21(c)(1). SER Section 4.2 documents the staff's review of the applicant's evaluation
 
of this TLAA.
SRP-LR Section 3.1.2.2.3 states that a loss of fracture toughness due to neutron irradiation embrittlement could occur in the reactor vessel.
The Reactor Vessel Surveillance Program monitors neutron irradiation embrittlement of the reactor vessel.
In ALRA Table 3.1.2.A-1 the applicant stated that loss of fracture toughness of vessel shells (beltline, lower shell, upper nozzle shell and upper RPV shell, and vessel shell welds including
 
attachment welds) will be managed using its Reactor Vessel Surveillance Program. As
 
documented in the Audit and Review Report, the staff asked the applicant to clarify which areas
 
have neutron fluence exceeding 1E17 n/cm 2 (E>1MeV).
The applicant responded that vessel shells - beltline and vessel shells - lower and the beltline welds have a neutron fluence exceeding 1E17 n/cm
: 2. Aging of these components is managed by the applicant's Reactor Vessel Surveill ance Program. The component type, attachment welds, does not need to be managed by the applicant's Reactor Vessel Surveillance Program
 
because even though these welds receive a neutron fluence greater than or equal to 1E17
 
n/cm 2 they are not ferritic material. The applicant modified ALRA Table 3.1.2.A-1 to reflect those components managed through its Reactor Vessel Surveillance Program. The staff found this
 
management consistent with the GALL Report and therefore acceptable. In a letter dated
 
December 1, 2005, the applicant revised its ALRA Table 3.1.2.A-1 to address this issue. The
 
staff's review and evaluation of the applicant's Reactor Vessel Surveillance Program are
 
documented in SER Sections 3.0.3.2.16.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.1.2.2.3. For those line items that
 
apply to Section 3.1.2.C.3 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.1A.2.2.4  Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress Corrosion Cracking The staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.1.2.2.4.
In Section 3.1.2.C.4 of a letter dated August 19, 2005, the applicant addressed crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that could occur
 
in small-bore reactor coolant systems and connec ted system piping less than nominal pipe size (NPS) 4.SRP-LR Section 3.1.2.2.4 states that crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) could occur in small-bore reactor coolant systems and 3-184 connected system piping less than NPS 4. The existing program relies on ASME Section XI ISI and on control of water chemistry to mitigate SCC. The GALL Report recommends that a
 
plant-specific destructive examination or a nondestructive examination (NDE) that permits inspection of the inside surfaces of the piping be conducted to ensure that cracking has not
 
occurred and that the component intended function will be maintained during the extended
 
period. The AMPs should be augmented to verify that service-induced weld cracking is not
 
occurring in the small-bore piping less than NPS 4 including pipe, fittings, and branch
 
connections. A one-time inspection of a sample of locations is an acceptable method to ensure
 
that the aging effect and aging effect mechanism is not occurring and that the component's
 
intended function will be maintained during the period of extended operation.
In the ALRA, the applicant also stated that for NMP1 aging of the subject small-bore piping ismanaged by the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program, Water
 
Chemistry Control Program, and One-Time Inspection Program.
Additionally, the applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that forsmall-bore piping and fittings in the NMP1 CRD system not part of its ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program, it credits only its Water Chemistry Control and
 
One-Time Inspection Programs for aging management.
The applicant further stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for thesmall-bore piping whether included in its ASME Sections Xl (Subsections IWB, IWC, and IWD)
 
ISI Program or not the inspections conducted under its One-Time Inspection Program will
 
consist of either NDEs using methods with demonstrated capability to detect cracks on the
 
inside surfaces of the piping or destructive examinations. Both nondestructive and destructive examinations will be of a sample of the piping.
In ALRA Table 3.1.2.A-5 the applicant stated that aging of CASS valves will be managed usingits ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, One-Time Inspection, and Water
 
Chemistry Control Programs. The intended functions of the CASS valve are leakage boundary (spatial) (LBS) and structural integrity attached (SIA). As documented in the Audit and Review
 
Report, the staff noted that LBS and SIA apply only to NSR components. The applicant was
 
informed and replied that its statement was an editorial mistake. The applicant revised ALRA Table 3.1.2.A-5 to assign its ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, One-Time
 
Inspection, and Water Chemistry Control Programs to manage aging of the pressure boundary
 
valves and its One-Time Inspection and Water Chemistry Control Programs to manage aging of the LBS and SIA valves. In a letter dated December 1, 2005, the applicant revised
 
ALRA Table 3.1.2.A-5 to address this issue. The staff found this revision consistent with the
 
GALL Report and therefore acceptable. The staff's review and evaluation of the applicant's ASME Sections XI (Subsection IWB, IWC, and IWD) ISI, One-Time Inspection, and Water Chemistry Control Programs are documented in
 
SER Sections 3.0.3.2.1, 3.0.3.1.4 and 3.0.3.2.2, respectively.
In addition the staff reviewed ALRA Sections 3.1.2.C.4 against the criteria in SRP-LR Section 3.1.2.2.4.2.
Also in Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that
 
could occur in BWR vessel flange leak detection lines and BWR jet pump sensing lines.
3-185 SRP-LR Section 3.1.2.2.4 also states that crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) could occur in the BWR vessel flange leak
 
detection line and the BWR jet pump sensing line. The GALL Report recommends that a
 
plant-specific aging management program be evaluated to mitigate or detect crack initiation and
 
growth due to SCC of vessel flange leak detection lines.
The applicant stated in the letter dated August 19, 2005, that for NMP1 cracking of the vesselflange leak detection lines is managed by the ASME Section Xl (Subsections IWB, IWC, and
 
IWD) ISI Program, One-Time Inspection Progr am, and Water Chemistry Control Program. The inspections conducted under the applicant's One-Time Inspection Program consist of either NDEs using methods with a demonstrated capability to detect cracks on the inside surfaces of
 
the piping or destructive examinations. Both nondestructive and destructive examinations will be of a sample of the piping.
The applicant also stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that NMP1 has no jet pump sensing line; therefore, the aging effect and aging effect mechanism of jet
 
pump sensing lines cracking is not applicable to NMP1.
In ALRA Table 3.1.2.A-1, the applicant stated that aging of wrought austenitic stainless steel(WASS) valves will be managed by its ASME Section Xl (Subsection IWB, IWC, and IWD) ISI, One-Time Inspection, and Water Chemistry Control Programs. The intended functions of the
 
component are LBS and SIA associated with NSR components. As documented in the Audit
 
and Review Report, the staff asked the applicant to explain why NSR components are managed
 
by ASME ISI and why ALRA Table 3.1.1.A, Item 3.1.1.A-08 was determined to belong to this
 
component type if it is NSR. The applicant stated that small-bore valves associated with the
 
vessel flange leak detection lines are NSR for NMP1. These lines/valves have an ISI pressure
 
test performed when there is an RFO; hence, WASS valves are managed by the applicant's ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program. The staff found this
 
management acceptable as consistent with the GALL Report. The staff's review and evaluation of the applicant's ASME Section XI (Subsections IWB, IWC, and IWD) ISI, One-Time Inspection, and Water Chemistry Control Programs are documented in
 
SER Sections 3.0.3.2.1, 3.0.3.1.4 and 3.0.3.2.2, respectively.
In addition the staff reviewed ALRA Section 3.1.2.C.4 against the criteria of SRP-LR Section 3.1.2.2.4.3.
Also in Section 3.1.2.C.4 of the letter dated August 19, 2005, the applicant addressed crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that
 
could occur in BWR isolation condenser components. SRP-LR Section 3.1.2.2.4.3 states that
 
crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC)
 
could occur in BWR isolation condenser components. The program relies on control of reactor water chemistry to mitigate SCC and on ASME Section XI ISI; however, the program should be
 
augmented to detect cracking due to SCC or cyclic loading. The GALL Report recommends an
 
augmented program to include temperature and radioac tivity monitoring of the shell-side water and eddy current testing of tubes to ensure that the component's intended function will be
 
maintained during the period of extended operation.
The applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that NMP1 has ECs. The EC design features end bells welded to the EC shell not designed to be removed; 3-186 therefore, eddy current testing of the tubing is not possible. Cracking is managed by several programs. The Water Chemistry Control Program controls chemical contaminants in both tube and shell side water to prevent conditions that would promote cracking. The EC tube side, which is ASME Class 2, is subject to a system inservice pressure test under the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program. The pressure test detects tube leaks
 
caused by cracking. The EC shell is ASME Class 3 and subject to a functional test under the applicant's Inservice Pressure Testing Program which is part of its ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program. The functional test would detect cracking due to
 
SCC or cyclic loading if the crack caused a through-wall leak of the EC shell.
In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant also stated that for additional confirmation of no tube leaks NMP1 will implement an online tube leakage test. The
 
test will isolate the makeup and drain valves to the EC tube side and monitor the shell side
 
water level for 24 to 48 hours. A water level rise on the shell side during the test would indicate
 
tube leakage. The online test will be incorporated as a new activity in the Preventive
 
Maintenance Program. The new activity will be implemented prior to the period of extended operation.
In addition the applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that its Preventive Maintenance Program is also credited for detecting cracking because it includes the
 
temperature monitoring of the emergency c ooling system including the heat exchangers.
Temperature monitoring can indicate tube leaks quickly. Continuous radiation monitoring of the
 
EC shell side vents also would detect a tube leak.
In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant also stated that because none of these activities would detect crack initiation or SCC before a leak occurred they will be
 
supplemented by a visual inspection for cracking from the accessible outer surfaces of the
 
peripheral tubes, tube sheet, and EC shell. This inspection also will be incorporated into the
 
applicant's Preventive Maintenance Program.The staff's review and evaluation of the applicant's Water Chemistry Control, ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, and Preventive Maintenance Programs are documented
 
in SER Sections 3.0.3.2.2, 3.0.3.2.1 and 3.0.3.3.1, respectively.
As documented in the Audit and Review Report dated January 18, 2006, the staff noted that inaccessibility alone cannot justify exemption from inspection required for aging management
 
and operating experience (documented in Inspection and Enforcement Bulletin (IEB) 76-01, "BWR Isolation Condenser Tube Failure") indicates cracking as an issue. As documented in the
 
Audit and Review Report, the staff asked the applicant to provide additional justification to
 
address this issue. The applicant responded that the aging management activities provide
 
adequate assurance with no need for eddy current testing that any tube degradation in the
 
isolation condensers will not lead to a loss of intended function. These activities include water
 
chemistry control, temperature monitoring of the shell side and tube side water, continuous
 
radioactivity monitoring of the condenser vent line, periodic performance testing, and a future
 
on-line tube leakage test. NMP1 experienced t ube leakage previously and replaced the whole tube bundle with upgraded material in 1997. A keep fill modification also was installed to
 
eliminate the stressor which caused the tube failures. Therefore, the applicant continued in
 
response, because the original isolation condenser tubes lasted 28 years with an aging stressor
 
the new tubes are expected to perform their intended function through the period of extended
 
operation with improved material, upgraded system design, and monitoring.
3-187 As documented in the Audit and Review Report dated January 18, 2006, the staff asked the applicant during its audits in the week of September 19, 2005, to provide its basis for not
 
performing eddy current testing. In a letter dated December 1, 2005, the applicant provided its
 
basis: 1)Condition and stresses that are precursors to SCC of tubes have been eliminated by:a)Lowering temperature of the tubes primary and shell side waterb)Maintaining shell side water chemistry c)Maintaining BWR primary water chemistry2)The susceptibility of the tubes to SCC has been improved by design changes to:a)Replace the tube bundle material with Type 316 stainless steel (low carbon)b)Install a keep fill system to maintain steam water interface above top of tube bundle (no thermal cycles)3)Monitoring and detecting in the steam inlet (tube) side and shell side of the isolation condensers ensure that conditions will not recura)Water temperatureb)Water chemistry (conductively, chloride, nitrates, sulfates)4)A commitment has been made to perform a tube leak test at operating pressure to detect small leaks.
The staff reviewed the applicant's nuclear commitment tracking list to confirm that the online tube leakage test will be implemented as a new ac tivity in the Preventive Maintenance Program as stated in NMP1 Commitment 29. The staff reviewed the applicant's response and determined
 
that NMP1 isolation condenser tube aging is adequately managed and that the tubes will be
 
able to perform their intended function at least an additional 23 years to the end of the period of
 
extended operation.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.1.2.2.4. For those line items that
 
apply to Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.1A.2.2.5  Crack Growth due to Cyclic Loading (NMP1)
 
The staff reviewed Section 3.1.2.C.5 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.5.
In Section 3.1.2.C.5 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
3-188 SRP-LR Section 3.1.2.2.5 states that crack growth due to cyclic loading could occur in the reactor vessel shell and the reactor coolant system piping and fittings. SRP-LR Table 3.1-1
 
states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.6  Changes in Dimension due to Void Swelling
 
The staff reviewed Section 3.1.2.C.6 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.6.
In Section 3.1.2.C.6 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.6 states that changes in dimension due to void swelling could occur in reactor internal components. SRP-LR Table 3.1-1 states that further evaluation for this aging
 
effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.7  Crack Initiation and Growth due to Stress Corrosion Cracking or Primary Water Stress Corrosion Cracking The staff reviewed Section 3.1.2.C.7 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.7.
In Section 3.1.2.C.7 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.7 states that crack initiation and growth due to SCC and PWSCC could occur: (1) in PWR core support pads (or core guide lugs), instrument tubes (bottom head
 
penetrations), pressurizer spray heads, and nozzles for the steam generator instruments and
 
drains; (2) in PWR CASS reactor coolant system piping and fittings and pressurizer surge line
 
nozzles; and (3) in PWR pressurizer instrumentation penetrations and heater sheaths and
 
sleeves made of Ni alloys. SRP-LR Table 3.1-1 states that further evaluation for this aging effect
 
is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.8  Crack Initiation and Growth due to Stress Corrosion Cracking or Irradiation-Assisted Stress Corrosion Cracking The staff reviewed Section 3.1.2.C.8 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.8.
In Section 3.1.2.C.8 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
3-189 SRP-LR Section 3.1.2.2.8 states that crack initiation and growth due to SCC or IASCC could occur in baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states that
 
further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.9  Loss of Preload due to Stress Relaxation
 
The staff reviewed Section 3.1.2.C.9 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.9.
In Section 3.1.2.C.9 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation could occur in baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states that further
 
evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.10  Loss of Section Thickness due to Erosion
 
The staff reviewed Section 3.1.2.C.10 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.10.
In Section 3.1.2.C.10 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.10 states that loss of section thickness due to erosion could occur in steam generator feedwater impingement plates and supports. SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.11  Crack Initiation and Growth due to PWSCC, ODSCC, or Intergranular Attack or Loss of Material due to Wastage and Pitting Corrosion or Loss of Section Thickness due to
 
Fretting and Wear or Denting due to Corrosion of Carbon Steel Tube Support Plate The staff reviewed Section 3.1.2.C.11 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.11.
In Section 3.1.2.C.11 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.11 states that crack initiation and growth due to PWSCC, ODSCC, or IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion
 
could occur in alloy 600 components of the steam generator tubes, repair sleeves and plugs.
 
SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR
 
plants.
3-190 The staff found that this aging effect is not applicable to NMP1.
3.1A.2.2.12  Loss of Section Thickness due to Flow-accelerated Corrosion
 
The staff reviewed Section 3.1.2.C.12 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.12.
In Section 3.1.2.C.12 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.12 states that loss of section thickness due to flow-accelerated corrosion could occur in tube support lattice bars made of carbon steel. SRP-LR Table 3.1-1
 
states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.13  Ligament Cracking due to Corrosion
 
The staff reviewed Section 3.1.2.C.13 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.13.
In Section 3.1.2.C.13 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in carbon steel components in the steam generator tube support plate. SRP-LR Table 3.1-1 states that
 
further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.14  Loss of Material due to Flow-accelerated Corrosion
 
The staff reviewed Section 3.1.2.C.14 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.14.
In Section 3.1.2.C.14 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.14 states that loss of material due to flow-accelerated corrosion could occur in feedwater inlet ring and supports. SRP-LR Table 3.1-1 states that further evaluation for
 
this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP1.
 
3.1A.2.2.15  Quality Assurance for Aging Management of Nonsafety-Related Components
 
SER Section 3.0.4 provides the staff's evaluation of the applicant's quality assurance program.
 
Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL 3-191 Report recommends further evaluation, the staff determined that the applicant adequately addressed the issues that were further evaluated. The staff found that the applicant had
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).3.1A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report Summary of Technical Information in the Amended Application. In ALRA Tables 3.1.2.A-1 through 3.1.2.A-5, the staff reviewed additional details of the results of the AMRs for material, environment, AERM, and AMP combinations that are not consistent with the GALL Report, or
 
that are not addressed in the GALL Report.
In ALRA Tables 3.1.2.A-1 through 3.1.2.A-5, 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, and provided inform ation concerning how the aging effect will be managed. 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, materi al, 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.
Staff Evaluation. For component type, material, and environment combinations that are not evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine
 
whether the applicant had 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. The staff's evaluation is discussed in the following sections.
The staff's review as provided in the following sections of this safety evaluation is limited to those components not consistent with or not addressed in the GALL Report for the following
 
systems in the NMP1 reactor coolant system (RCS) group, the RPV, RPV internals, RPV instrumentation system, and CRD system. The asse ssment for the NMP1 RPV valves, reactor recirculation system components, and the CRD system valves are addressed in SER Section 3.1A.2.3.4.
3.1A.2.3.1  Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor Pressure Vessel - Summary of Aging Management Evaluation - ALRA Table 3.1.2.A-1 The NMP1 RPV contains and supports the reactor core, reactor internals, and the reactor coolant/moderator. The RPV forms part of the reactor coolant pressure boundary (RCPB) and
 
serves as a barrier against leakage of radioactive materials to the drywell. The NMP1 RPV is a
 
vertical, cylindrical pressure vessel with hemispherical heads. The cylindrical shell and
 
hemispherical heads are fabricated from low-alloy carbon steel clad on the interior with stainless
 
steel weld overlay. The top head secured to the vessel with studs and nuts includes two
 
concentric seal-rings between the vessel head flange and the vessel flange to prevent reactor
 
coolant leakage. The top head leak detection line taps off of the vessel head between the seal 3-192 rings to detect leakage if the inner seal-ring fails. The top head also includes nine safety valves that prevent overpressurization of the RPV. The vessel shell and bottom head include
 
penetration nozzles for the various systems that comprise the RCPB including the CRD housing
 
and in-core instrumentation thimbles. The RPV is supported by a steel skirt welded to the
 
bottom head. The base of the skirt is supported circumferentially by a ring girder and sole plate
 
fastened to a concrete foundation which carries the load of the reactor building foundation slab.
Summary of Technical Information in the Application. The applicant's plant-specific AMRs for the RPV components are listed in ALRA Table 3.1.2.A-1. The specific RPV components for
 
NMP1 that have AMR results not consistent with or not addressed in the GALL Report and
 
within the scope of ALRA Table 3.1.2.A-1 include:
* RPV core differential pressure, CRD stub tube, flux monitor, instrumentation, and vessel drain penetrations
* RPV support skirt and attachment welds
* RPV top head closure studs and nuts
* RPV valves The applicant identified the materials of fabrication for these RPV components as carbon steel and low alloy steel. The applicant identified the applicable environments for these RPV
 
components as containment air, non-borated water, and treated water (including steam).
The applicant credited the FAC Program with managing loss of material for the RPV core differential pressure, CRD stub tube, flux monitor, instrumentation, and vessel drain penetrations. The ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program is credited
 
for the managing loss of material for the RPV support skirt and attachment welds. The Water
 
Chemistry Control Program and the One-Time Inspection Program are credited for managing the loss of material for the RPV valves. The applicant credited the Reactor Head Closure Studs
 
Program with managing loss of material for the RPV top head closure studs and nuts. In
 
addition, the applicant credited TLAA 4.3, "Thermal Fatigue," with managing cumulative fatigue
 
damage of the RPV top head closure studs and nuts. The applicant credited the Selective
 
Leaching of Materials Program and the Water Chemistry Control Program with managing loss of
 
material for the CRD system valves.
 
Staff Evaluation. The staff reviewed ALRA Table 3.1.2.A-1, which summarizes the results of AMR evaluations for the RPV component groups. The staff's assessment of the RPV
 
components not consistent with or not addressed in the GALL Report for NMP1 is provided in
 
this section. The assessment for the NMP1 RPV valves is provided in SER Section 3.1A.2.3.4. RPV Core Differential Pressure, CRD Stub Tube, Flux Monitor, Instrumentation, and Vessel Drain Penetrations Identification of Aging Effects - In ALRA Table 3.1.2.A-1, the applicant indicated that loss of material due to FAC is an aging effect for the core differential pressure, CRD stub tube, flux
 
monitor, instrumentation, and vessel drain penetrations fabricated from carbon or low-alloy steel
 
and exposed to a treated water or steam in a high-temperature environment.
3-193 FAC is a phenomenon in which repetitive cycles of corrosion and erosion cause wall thinning of carbon or low-alloy steel components exposed to high temperature, high velocity water or
 
water-steam environments. Normally, FAC occurs only if the environmental temperatures areabove 200 &deg;F. The rate of metal loss depends on a complex interplay of many factors like water
 
chemistry, material composition, and hydrodynamics.
The staff determined that the applicant indicated adequately that loss of material due to FAC is an AERM for the core differential pressure, CRD stub tube, flux monitor, instrumentation, and
 
vessel drain penetrations exposed to these environments. This aging effect is not addressed in
 
the GALL Report Volume 2 for these components, materials, and environments; therefore, the
 
staff found the applicant's approach acceptable because it is conservative relative to the GALL
 
Report Volume 2 and is consistent with the EPRI Report, "Recommendations for an Effective
 
Flow-Accelerated Corrosion Program."Aging Management Programs - In ALRA Table 3.1.2.A-1, the applicant credits the FAC Program with aging management of the core differential pressure, CRD stub tube, flux monitor, instrumentation, and vessel drain penetrations for loss of material due to FAC. Even though the
 
GALL Report Volume 2 does not address an AMP for these components, materials, and
 
environments, it does recommend crediting the Flow-Accelerated Corrosion Program with
 
managing wall thinning of carbon steel piping and fitting components due to FAC; therefore, the
 
staff found the applicant's proposal conservative relative to the GALL Report Volume 2, and
 
acceptable. The applicant's FAC Program is an AMP entirely consistent with GALL AMP XI.M17. The staff's evaluation of the FAC Program is in SER Section 3.0.3.1.3. RPV Support Skirt and Attachment Welds Identification of Aging Effects - In ALRA Table 3.1.2.A-1, the applicant indicated that loss of material due to general corrosion is an aging effect for RPV support skirt and attachment welds
 
fabricated from carbon or low-alloy steel and exposed to an environment of "air with thermal
 
fatigue." The applicant definition of "air with thermal fatigue" is "this environment is applied to
 
components exposed to air, that are also subject to thermal cycles of sufficient magnitude for
 
thermal fatigue to be a concern." The air environment is the containment air surrounding the
 
RPV and the support skirt.
GALL Report Volume 2 does not identify loss of material due to general corrosion as an aging effect in carbon and low-alloy steel when these materials are exposed to an environment of
 
containment air; however, carbon and low-alloy steel may rust or corrode in air with elevated
 
humidity. The staff concludes that the applicant has addressed this issue conservatively;
 
therefore, the staff found the applicant's identification of this AERM acceptable for the RPV
 
support skirt and attachment welds. Aging Management Programs - In ALRA Table 3.1.2.A-1, the applicant credits the ASMESection XI (Subsections IWB, IWC, and IWD) ISI Program with aging management of the RPV
 
support skirt and attachment welds for loss of material due to general corrosion. By letter dated
 
November 22, 2005, the staff indicated that it agreed with the applicant in crediting the ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program with managing the RPV attachment
 
welds for loss of material due to general corrosion; however, the staff requested that the applicant address why the ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program
 
was credited with managing the RPV support skirt for loss of material due to general corrosion.
 
Instead, the staff recommended that this aging effect in the RPV support skirt be managed by 3-194the ASME Section XI (Subsection IWF) ISI Program because the RPV support skirt is an ASME Class MC support. By letter dated December 5, 2005, the applicant revised Table 3.1.2.A-1 to
 
indicate that the AERM of loss of material of the RPV support skirt would be managed by the ASME Section XI (Subsection IWF) ISI Program. The staff found the applicant's response
 
acceptable because the RPV support skirt is an ASME Class MC component and, therefore, is
 
managed appropriately by the ASME Section XI (Subsection IWF) ISI Program.
 
GALL Report Volume 2 does not identify an AMP for managing loss of material due to general
 
corrosion for these components, materials, and environments. The staff found the applicant's
 
proposal conservative relative to the GALL Report Volume 2 and, therefore, acceptable. The applicant's ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program is an AMP consistent with GALL AMP XI.M1 with exceptions. The staff's evaluation of the ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program is in SER Section 3.0.3.2.1. The applicant's ASME Section XI (Subsection IWF) Program is an AMP consistent with GALL AMP XI.S3 with exceptions. The staff's evaluation of the ASME Section XI (Subsection IWF)
 
Program is in SER Section 3.0.3.2.19.
RPV Top Head Closure Studs and Nuts Identification of Aging Effects - In ALRA Table 3.1.2.A-1, the applicant indicated that loss of material due to general, crevice, and pitting corrosion is an aging effect applicable to the RPV
 
top head closure studs and nuts fabricated from carbon or low-alloy steel and exposed to an
 
environment of non-borated water systems with operating temperatures > 212 &deg;F leaking fluid (i.e., leakage of the reactor coolant).
GALL Report Volume 2 identifies crack initiation and growth, SCC and IGSCC as aging effects for RPV top head closure studs and nuts fabricated from carbon or low alloy steel exposed to air, leaking reactor coolant water, or steam at 288 &deg;C, but does not identify loss of material due
 
to crevice, general, and pitting corrosion as aging effects in carbon and low-alloy steel exposed
 
to leakage of the non-borated reactor coolant or the steam environment. However, carbon and
 
low-alloy steel may rust or corrode when exposed to aqueous liquids. The staff concludes that
 
the applicant has conservatively addressed this issue; therefore, the staff found the applicant's
 
identification of this AERM acceptable.
Also, in ALRA Table 3.1.2.A-1, the applicant indicated that cumulative fatigue damage is an aging effect applicable to the RPV top head closure studs and nuts because of thermal cycling
 
of heatup and cooldown and other transient operating conditions of these components. The staff
 
found this indication acceptable because it meets the provisions in SRP-LR Chapter 3.1-1800
 
Revision 1 Report for assessing cumulative fatigue damage in ASME Code Class 1
 
components. SER Section 4.3 discusses the staff's assessment of those plant components
 
required to have thermal fatigue analyses for license renewal.Aging Management Programs - In ALRA Table 3.1.2.A-1, the applicant credits the Reactor Head Closure Studs Program with aging management of loss of material due to general, pitting, and crevice corrosion of the RPV top head closure studs and nuts. Even though the GALL
 
Report Volume 2 does not identify an AMP for these components, materials, and environments
 
the staff found the applicant's proposal conservative relative to the GALL Report Volume 2 and, therefore, acceptable. The applicant's Reactor Head Closure Studs Program is an AMP consistent with an exception with GALL AMP XI.M3. The staff's evaluation of the Reactor Head
 
Closure Studs Program is in SER Section 3.0.3.2.3.
3-195 In ALRA Table 3.1.2.A-1, the applicant proposed in ALRA Section 4.3 to use the TLAA for assessing cumulative fatigue damage of the RPV top head closure studs and nuts. This
 
proposal is consistent with the GALL Report Revision 1 and is, therefore, acceptable. The staff's
 
evaluation of the applicant's TLAA on thermal fatigue of ASME Code Class 1 components is in
 
SER Section 4.3.
RPV Valves The review of the RPV valves is provided in SER Section 3.1A.2.3.4.
 
Conclusion. The staff has reviewed the applicant's plant-specific AMRs for the RPV components exposed to the containment air, non-borated water, and treated water (including steam) environments. For these AMRs, the staff has determined that the applicant has identified the
 
aging effects applicable for these components exposed to these environments. The staff has
 
also determined that the applicant has credited either an appropriate inspection-based AMP, an
 
appropriate mitigation-based AMP, a TLAA, or combination of these strategies to manage the
 
aging effects applicable to the RPV components exposed to these environments. On the basis
 
of its review, as discussed above, the staff concludes that there is reasonable assurance that
 
the applicant has demonstrated that the aging effects associated with the NMP1 RPV will be
 
adequately managed so that the intended functions will be maintained consistent with the CLB
 
for the period of extended operation, as required by 10 CFR 54.21(a)(3).
3.1A.2.3.2  Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor Pressure Vessel Internals - Summary of Aging Management Evaluation - ALRA Table 3.1.2.A-2 The NMP1 RPV internals support the core and other internal components, maintain fuel configuration (coolable geometry) during normal operation and accident conditions, and
 
maintain reactor coolant flow through the core. The RPV internals consist of the components
 
internal to the RPV, mainly the reactor core, core shroud, core shroud stabilizers, core shroud
 
support structures, top guide, CRD guide tubes, feedwater sparger, core spray spargers, liquid
 
poison sparger, steam separator assembly, and the steam dryer assembly. All of the RPV
 
internals except the shroud support assembly and springs in the fuel assemblies are fabricated
 
from stainless steel. The shroud support plates, spacers, tie rods, head bolts, and associated
 
welds are fabricated from nickel-based alloys. The shroud support essentially sustains all of the
 
vertical weight of the core structure and the steam separator assembly. Each guide tube with its
 
fuel support casing bears the weight of four fuel assemblies and rests on a CRD housing
 
welded to the stub tube mounted on the vessel bottom head.
The applicant's plant-specific AMRs for the RPV internal components are identified in ALRA Table 3.1.2.A-2. The staff determined that no RPV internal components for NMP1 have
 
AMR results not consistent with or addressed in the GALL Report. Therefore, in this review, the
 
staff did not perform an evaluation of the NMP1 RPV internal components.
3.1A.2.3.3  Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor Vessel Instrumentation System - Summary of Agi ng Management Evaluation - ALRA Table 3.1.2.A-3 The NMP1 RPV instrumentation system monito rs and transmits information about key RPV operating parameters during normal and emergency operations. Instrumentation is installed to
 
monitor reactor parameters and indicate these on meters, chart recorders, and hydraulic 3-196 indicator units located in the control room, on remote shutdown panels, and in instrument rooms. The parameters monitored are RPV temperature, water level and pressure, core
 
differential pressure, core spray sparger break (differential pressure), and reactor safety valve
 
position. This system also provides control si gnals to various systems which in turn initiate appropriate actions required if a monitored par ameter exceeds a desired set point. Systems receiving control signals from the RPV instrum entation system include the reactor protection, automatic depressurization, anticipated transient without scram (ATWS), feedwater/high
 
pressure coolant injection (HPCI), and shutdown cooling systems. The top head leak detection
 
line is addressed with the RPV (ALRA Section 2.3.1.A.1). The RPV instrumentation system
 
consists of piping, valves, and excess flow check valves that provide a fluid path from the RPV to various instrumentation.
The applicant's plant-specific AMRs for the RPV instrumentation system components are identified in ALRA Table 3.1.2.A-3. The staff determined that no RPV instrumentation system
 
components for NMP1 have AMR results not consistent with or not addressed in the GALL
 
Report. Therefore, in this review, the staff did not perform an evaluation of the NMP1 RPV
 
instrumentation system components.
3.1A.2.3.4  Reactor Vessel, Internals, and Reactor Coolant System - NMP1 Reactor Recirculation System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.A-4 Summary of Technical Information in the Application. The description of the reactor recirculation system, recirculation flow control, and the control of the reactor recirculation pumps can be
 
found in ALRA Section 2.3.1.A.4. The portion of the reactor recirculation system containing
 
components subject to AMR includes the entire main reactor recirculation flow path which
 
begins at the suction nozzle to and ends at the discharge nozzle of each recirculation loop for
 
NMP1. SR instrument piping and associated components connected to the recirculation loops
 
are also subject to AMR. The components requiring an AMR for the reactor recirculation system
 
and their intended functions are shown in ALRA Table 2.3.1.A.4-1. The AMR results for these
 
components are provided in ALRA Table 3.1.2.A-4. However, the staff has used in its evaluation
 
the following information provided in the original LRA pertinent to the reactor recirculation system. The materials of construction for NMP1 are carbon or low-alloy steel (yield strength < 100 Ksi and > 100 Ksi), cast austenitic stainless steel, and wrought austenitic stainless steel.
In the original LRA Section 3.1.2.A.4 the applicant lists the following environments to which the NMP1 Reactor Recirculation System components are exposed:
* air
* closure bolting for non-borated water systems with operating temperatures > 212 &deg;F
* treated water, temperature < 140 &deg;F, low flow
* treated water or steam, temperature > 482 &deg;F
* treated water or steam, temperature > 482 &deg;F, low flow The following AMPs manage these aging effects in the NMP1 reactor recirculation system components:
* ASME Code Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Bolting Integrity Program 3-197
* BWR Stress Corrosion Cracking Program
* One-Time Inspection Program
* Water Chemistry Control Program
* System Walkdown Program Staff Evaluation. The applicant described its AMR for the reactor recirculation system in ALRA Section 3.1. The staff reviewed this section to determine whether the applicant had identified all
 
aging effects applicable to components in these systems and demonstrated that the effects of aging on the components will be adequately managed during the period of extended operation
 
as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplements for the
 
AMPs to ensure that the program descriptions adequately describe them.
The applicant identified the following aging effects for the reactor recirculation system:
* cracking
* cumulative fatigue damage
* loss of fracture toughness
* loss of material
* loss of preload In ALRA Table 3.1.2.A-4 the applicant identified cracking and cumulative fatigue damage as aging effects applicable to the recirculation system closure bolting, piping and fittings, recirculation pumps, and valves. Cumulative fatigue damage is evaluated in SER Section 4.3, "Metal Fatigue Analysis." The aging effect of loss of fracture toughness is associated with the
 
pressure boundary materials in reactor recirculation pumps and in valves made of cast austenitic stainless steel and operating at or above 480 &deg;F. Loss of material has been detected
 
as an aging effect in carbon or low-alloy steel and austenitic stainless steel with treated water environment operating below 140 &deg;F for such components as piping and fittings, valves, and
 
restriction orifices in the reactor recirculation system. The loss of preload is an aging effect applicable to closure bolting for non-borated water systems operating at or above 212 &deg;F. The
 
staff notes that this assessment is consistent with the GALL Report.
The applicant identified cracking as an aging effect applicable to the recirculation system austenitic stainless steel components (piping and fittings, tubing, valve bodies, flow elements, thermowells, restricting orifices) and to the high-strength low-alloy steel primary pressure
 
closure bolting exposed to reactor coolant water. The applicant also identified this aging effect
 
for cast stainless steel components exposed to reactor coolant water. The applicant identified
 
crack initiation and growth due to thermal and mechanical loading as an aging effect applicable
 
to small-bore stainless steel piping and fittings and low-alloy steel pressure boundary closure
 
bolting in the reactor recirculation system. The staff notes that this assessment is consistent
 
with the GALL Report. The staff requested confirmation that the applicant had no flaws
 
evaluated according to IWB-3600, "Analytical Evaluation of Flaws," under the ASME Code Section XI ISI Program as such an evaluation would require a TLAA under the regulation. The
 
applicant's response indicated that the NMP1 Reactor Recirculation System contains five welds
 
that had flaw evaluations performed according to IWB-3600. Re-inspection of each weld found
 
no growth of the indication. The applicant's evaluation determined that each of the indications
 
was related to the fabrication of the component and was not caused by IGSCC. The staff
 
previously had accepted the applicant's evaluation. Therefore, there is no TLAA required for any
 
of the subject flaw evaluations.
3-198 The applicant stated under item number 3.1.1.A-07 in ALRA Table 3.1.1.A, that for small-bore reactor coolant system and connected systems pi ping a plant-specific destructive examination or an NDE of the inside surfaces will be conducted as part of a one-time inspection to verify that
 
service-induced weld cracking has not occurred. Additionally, for small bore piping and fittings in
 
the NMP1 CRD system not part of the ISI progr am NMP1 credits only the Water Chemistry and One-Time Inspection Programs. The applicant's One-Time Inspection AMP is described in
 
ALRA Section B.2.1.20 and the applicant states that it is consistent with GALL Report AMP XI.M32, "One-Time Inspection."
In ALRA Table 3.1.2.A-1, applicable to the vessel drain line, the applicant identified cumulative fatigue damage and cracking as aging effects requiring management. The applicant uses TLAA
 
to manage cumulative fatigue damage and the BWR Penetration Program and Water Chemistry
 
Control Program to manage cracking. Because of the size of the drain line volumetric examination is not required by ASME Code Section XI. In response to the staff's request for
 
information about the adequacy of the AMP applicable to the reactor vessel drain line not volumetrically examined the applicant stated that the ASME Code Section XI pressure test is
 
performed at every refueling outage. As a function of the pressure test a concurrent VT-2
 
examination is performed according to acceptance standards stated in Subsection IWB-3522.
 
The source of any leakage detected during this examination is required to be located and
 
evaluated according to Subsection IWA-5250 prior to return of the system to service. One
 
source of leakage could be through-wall pitting or crevice corrosion as the loss of material
 
mechanism applicable to stainless steel piping and components. Also performed at every
 
inspection interval under the ISI program according to the acceptance standards stated in
 
Subsection IWB-3517 is a VT-1 examination of all reactor vessel drain line bolting, studs, and
 
nuts. The staff considers the AMPs of the reactor vessel drain line effective for the period of
 
extended operation.
In ALRA Table 3.1.1.A-1, item number 3.1.1.A-09, the applicant identified SCC and cyclic loading as aging effects for isolation condensers and credits the Preventive Maintenance
 
Program for managing them. The isolation condensers are parts of the reactor coolant pressure boundary and, therefore, should be inspected according to ASME Code Section XI. The
 
Preventive Maintenance Program does not require volu metric examination for structural integrity of pressure boundary material or welds. In response to the staff's request for information on the
 
management of aging effects of cracking in stainless steel tubes and in shell welds the applicant stated that ASME Section XI Inservice Inspection (Subsections IWB, IWC, and IWD) and the
 
Water Chemistry Control Programs are credited in addition to the Preventive Maintenance
 
Program for managing the aging effect of cracking in stainless steel tubes and in shell welds.
 
Continuous radiation monitoring of the isolation condenser shell also is credited. These changes
 
utilize detection methods in addition to visual inspection to ensure detection and correction of
 
aging degradation prior to a loss of intended function. These revisions to ALRA Table 3.1.1.A
 
bring the credited programs in line with the guidance of GALL Report Item IV.C1.4-a for the
 
NMP1 isolation condensers.
In reviewing ALARA Table 3.1.1.A-1, the staff requested that the applicant to submit additional information about its plant-specific experience with IGSCC of the reactor coolant pressure
 
boundary piping, mitigative actions taken, and revised inspection schedules following the
 
BWRVIP-75A guidelines. The staff requested that the applicant provide information on how its
 
implementation of HWC and NMCA at NMP1 has affected monitoring of water chemistry
 
parameters. In its response, the applicant stated that recent plant-specific experience at NMP1
 
had detected indications in four reactor recirculation system welds during the 1999 refueling 3-199 outage. The applicant performed its re-inspection evaluations, and determined that the indications were fabrication-related and not from IGSCC. The scope and schedule of inspection
 
for IGSCC are according to GL 88-01 as modified by BWRVIP-75A. The current inspection
 
schedule except for Category A welds subsumed in the alternate Risk-Informed ISI Program is
 
consistent with the revised inspection frequency allowed by BWRVIP-75A for normal water
 
chemistry. In implementing HWC and NMCA, NMP1 began treating the reactor vessel internals
 
with noble metal chemicals in May 2000 and began injecting hydrogen into reactor water in
 
June 2000. The impact for NMP1 operating under HWC versus normal water chemistry is that
 
the electrochemical potential is monitored with a goal of < -0.23V SHE (standard hydrogen
 
reference electrode) to verify the effectiveness of HWC.
The staff's review concludes that the applicant has identified the appropriate aging effects for the components in the NMP1 reactor recirculation system.
Conclusion.The staff concludes that there is reasonable assurance that the applicant adequately identified the aging effects and the AMPs credited for managing them for the reactor
 
recirculation system and that the components' intended functions will be maintained consistently
 
with the CLB for the period of extended operation as required by 10 CFR 54.21(a)(3). The staff
 
also reviewed the applicable UFSAR supplement program descriptions and concludes that the
 
UFSAR supplement provides an adequate program description of the AMPs credited for
 
managing aging in the reactor coolant system
- recirculation system as required by 10 CFR 54.21(d).
3.1A.2.3.5  Reactor Vessel, Internals, and Reac tor Coolant System - NMP1 Control Rod Drive System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.A-5 The NMP1 CRD system is designed to change core reactivity by changing the position of control rods within the reactor core in response to manual control signals and to scram the
 
reactor in response to manual or automatic si gnals. The system also provides high-pressure makeup to the RPV for a specified leakage of 25 gpm and provides core cooling in the case of a
 
small line break (up to 0.003 ft 2). The CRD system also provides water to the RPV level instrumentation reference leg backfill system and to the keep-fill system for the emergency cooling system.
Summary of Technical Information in the Application. The applicant's plant-specific AMRs for the CRD system components are given in ALRA Table 3.1.2.A-5 and in the revised
 
Table 3.1.2.A-5 of the applicant's letter dated December 20, 2005. The specific CRD system
 
components for NMP1 that have AMR results that are not consistent with, or not addressed in, the GALL Report include:
* CRD system valves
* CRD pumps The applicant identifies that the materials of fabrication for these CRD system components include copper alloys, aluminum bronze, and wrought austenitic stainless steel. The applicant identifies that the applicable environment s for these CRD system components include treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow environments (i.e., the reactor coolant environment).
3-200 The applicant credits the One-Time Inspection Program and the Water Chemistry Control Program to manage loss of material for the CRD system valves. The applicant also credits the
 
One-Time Inspection Program and the Water C hemistry Control Program to manage cracking of the CRD pumps.
Staff Evaluation. The staff reviewed ALRA Table 3.1.2.A-5, and the revised Table 3.1.2.A-5 of the applicant's letter dated December 20, 2005, which summarizes the results of AMR
 
evaluations for the CRD system components fo r NMP1. The staff's assessment of the CRD system components that are not consistent with, or not addressed in, the GALL Report for
 
NMP1 is provided below. It should be noted that the assessments for the NMP1 CRD system
 
valves are addressed in SER Section 3.1A.2.3.4.
Identification of Aging Effects - In Table 3.1.2.A-5 of the applicant's letter dated December 20, 2005, the applicant identified that cracking is an applicable aging effect for the CRD pumps that
 
are fabricated from wrought austenitic stainl ess steel and are exposed to an environment of treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow environments. These components are made from materials and exposed to environment s that are similar to those for the wrought austenitic stainless steel CRD system valves exposed to reactor coolant, as identified in the
 
GALL Report
 
The applicant identified cracking as an aging effect in wrought austenitic stainless steel when
 
these materials are exposed to the reactor coolant. Based on this analysis, the staff found that
 
the applicant's determination is acceptable.Aging Management Programs - In Table 3.1.2.A-5 of the applicant's letter dated December 20, 2005, the applicant credits the One-Time Inspection and Water Chemistry Control Programs
 
with aging management of cracking for the CRD pumps. The GALL Report does not address an
 
AMP for these component, material, and environment combinations. However, the GALL Report
 
does address the AMPs (One-Time Inspection and Water Chemistry Control Programs) for this
 
material and environment combination that are consistent with the programs that the applicant
 
has identified to manage cracking. Therefore, the staff found the applicant's proposal to be
 
acceptable. The applicant's One-Time Inspection Program is a new AMP that is entirely consistent with GALL AMP XI.M32. The staff's evaluation of the One-Time Inspection Program
 
is in SER Section 3.0.3.1.4. The applicant's Water Chemistry Control Program is an existing AMP that is entirely consistent with GALL AMP XI.M2. The staff's evaluation of the Water
 
Chemistry Program is in SER Section 3.0.3.2.2.
Conclusion. The staff has reviewed the applicant's plant-specific AMRs for the CRD system components that are exposed to the treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow environments. For these AMRs, the staff determined that the applicant identified the aging
 
effects that are applicable for these components under exposure to these environments. The
 
staff also determined that the applicant credited either an appropriate inspection-based AMP, an
 
appropriate mitigation-based AMP, or combination of these management strategies to manage
 
the aging effects that are applicable to the CRD system components under exposure to these
 
environments. On the basis of its review, as discussed above, the staff concludes that there is
 
reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the NMP1 CRD system components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3-201 3.1A.3  Conclusion On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the NMP1
 
RPV, RPV internals, and RCS components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation as
 
required by 10 CFR 54.21(a)(3).
3.1B  NMP2 Aging Management of Reactor Vessel, Internals, and Reactor CoolantSystems This section of the SER documents the staff's review of the applicant's AMR results for the reactor vessel, internals, and reactor coolant systems components and component groups
 
associated with the following NMP2 systems:
* reactor pressure vessel
* reactor pressure vessel internals
* reactor pressure vessel instrumentation system
* reactor recirculation system
* control rod drive system3.1B.1  Summary of Technical Information in the Amended Application In ALRA Section 3.1, the applicant provided AMR results for the reactor vessel, internals, and reactor coolant systems components and component groups. In ALRA Table 3.1.1.B, "NMP2 Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant
 
Systems Evaluated in Chapter IV of NUREG-1801," the applicant provided a summary
 
comparison of its AMRs with the AMRs evaluated in the GALL Report for the reactor vessel, internals, and reactor coolant systems components and component groups.
The applicant's AMRs incorporated applicable operating experience in the determination of AERMs. These reviews included evaluation of plant-specific and industry operating experience.
 
The plant-specific evaluation included reviews of condition reports and discussions with
 
appropriate site personnel to identify AERMs. The applicant's review of industry operating
 
experience included a review of the GALL Report and operating experience issues identified
 
since the issuance of the GALL Report.
3.1B.2  Staff Evaluation The staff reviewed ALRA Section 3.1 to determine if the applicant provided sufficient information to demonstrate that the effects of aging for the reactor vessel, internals, and reactor coolant
 
systems components that are within the scope of license renewal and subject to an AMR will be adequately managed so that the intended functions will be maintained consistent with the CLB
 
for the period of extended operation, as required by 10 CFR 54.21(a)(3).
The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain identified 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 ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.
 
The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's 3-202 audit evaluation are documented in the Audit and Review Report and are summarized in SER Section 3.1B.2.1.
In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicant's further
 
evaluations were consistent with the acceptance criteria in SRP-LR Section 3.1.2.2. The staff's
 
audit evaluations are documented in the Audit and Review Report and are summarized in SER
 
Section 3.1B.2.2.
In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were not consistent with, or not addressed in, the GALL Report. The audit and technical review
 
included evaluating whether all plausible aging effects were identified and evaluating whether
 
the aging effects listed were appropriate for the combination of materials and environments
 
specified. The staff's audit evaluations are documented in the Audit and Review Report and are
 
summarized in SER Section 3.1B.2.3. The staff's evaluation of its technical review is also
 
documented in SER Section 3.1B.2.3.
Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure that they provide an adequate description of the programs credited with managing or monitoring aging for the reactor vessel, internals, and reactor coolant systems components.
Table 3.1B-1 below provides a summary of t he staff's evaluation of NMP2 components, aging effects and aging effects mechanisms , and AMPs listed in ALRA Section 3.1, that are
 
addressed in the GALL Report.
Table 3.1B-1  Staff Evaluation for NMP2 Reactor Vessel, Internals, and Reactor CoolantSystems Components in the GALL ReportComponent GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation Reactor coolant pressure boundary
 
components (Item Number
 
3.1.1.B-01)
Cumulative fatigue damageTLAA, evaluated inaccordance with 10 CFR 54.21(c)TLAAThis TLAA is evaluated in Section 4.3, Metal Fatigue Analysis Steam generator shell assembly (Item Number
 
3.1.1.B-02)
Loss of material due to pitting and
 
crevice corrosion Inservice inspection;water chemistryNot applicable, PWR only Isolation condenser (Item Number
 
3.1.1.B-03)
Loss of material due to general, pitting, and crevice
 
corrosion Inservice inspection;water chemistry Not applicable (isolation condenser
 
does not exist - See
 
Section 3.1B.2.2.2)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-203 Pressure vessel ferritic materials that
 
have a neutron
 
fluence greater than
 
10 17 n/cm 2 (E > 1 MeV)
(Item Number
 
3.1.1.B-04)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlementTLAA, evaluated inaccordance with
 
Appendix G of 10 CFR 50 and
 
RG 1.99TLAAThis TLAA is evaluated in Section
 
4.2, Reactor Vessel
 
Neutron Embrittlement Analysis Reactor vessel beltline shell and welds (Item Number
 
3.1.1.B-05)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlement Reactor vessel surveillance Reactor Vessel Surveillance
 
Program (B2.1.19)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.1B.2.2.3)Westinghouse and B&W baffle/former
 
bolts (Item Number
 
3.1.1.B-06)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlement and void swellingPlant-specificNot applicable, PWR only Small-bore reactorcoolant system and connected systems
 
piping (Item Number
 
3.1.1.B-07)
Crack initiation andgrowth due to SCC, intergranular SCC, and thermal and
 
mechanical loading Inservice inspection;water chemistry;
 
one-time inspectionASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1); Water Chemistry Control
 
Program (B2.1.2);
One-Time Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.1B.2.2.4)
Jet pump sensing line, and reactor
 
vessel flange leak
 
detection line (Item Number
 
3.1.1.B-08)
Crack initiation andgrowth due to SCC, intergranular stress
 
corrosion cracking (IGSCC), or cyclic
 
loadingPlant-specificASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1); Water Chemistry Control
 
Program (B2.1.2);
One-Time Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (see
 
Section 3.1B.2.2.4)
Isolation condenser (Item Number
 
3.1.1.B-09)
Crack initiation andgrowth due to stress
 
corrosion cracking (SCC) or cyclic
 
loading Inservice inspection;water chemistry Not applicable (isolation condenser
 
does not exist - (see
 
Section 3.1B.2.2.4))
Vessel shell (Item Number
 
3.1.1.B-10)Crack growth due tocyclic loadingTLAANot applicable, PWR only Reactor internals (Item Number
 
3.1.1.B-11)
Changes in dimension due to void swellingPlant-specificNot applicable, PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-204PWR core support pads, instrument
 
tubes (bottom head
 
penetrations),
pressurizer spray
 
heads, and nozzles
 
for the steam
 
generator instruments and
 
drains (Item Number
 
3.1.1.B-12)
Crack initiation andgrowth due to SCC
 
and/or primary water stress
 
corrosion cracking (PWSCC)Plant-specificNot applicable, PWR only Cast austenitic stainless steel (CASS) reactor coolant system
 
piping (Item Number
 
3.1.1.B-13)
Crack initiation andgrowth due to SCCPlant-specificNot applicable, PWR only Pressurizer instrumentation
 
penetrations and
 
heater sheaths and
 
sleeves made of Ni-alloys (Item Number
 
3.1.1.B-14)
Crack initiation andgrowth due to
 
PWSCC Inservice inspection;water chemistryNot applicable, PWR onlyWestinghouse and B&W baffle former
 
bolts (Item Number
 
3.1.1.B-15)
Crack initiation andgrowth due to SCC
 
and IASCCPlant-specificNot applicable, PWR onlyWestinghouse and B&W baffle former
 
bolts (Item Number
 
3.1.1.B-16)
Loss of preload dueto stress relaxationPlant-specificNot applicable, PWR only Steam generatorfeedwater impingement plate
 
and support (Item Number
 
3.1.1.B-17)
Loss of section thickness due to
 
erosionPlant-specificNot applicable, PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-205(Alloy 600) Steam generator tubes, repair sleeves, and
 
plugs (Item Number
 
3.1.1.B-18)
Crack initiation andgrowth due to PWSCC, outside
 
diameter stress
 
corrosion cracking (ODSCC), and/or
 
intergranular attack (IGA) or loss of
 
material due to wastage and pitting
 
corrosion, and fretting and wear; or
 
deformation due to
 
corrosion at tube
 
support plate
 
intersections Steam generatortubing integrity; water chemistryNot applicable, PWR onlyTube support lattice bars made of
 
carbon steel (Item Number
 
3.1.1.B-19)
Loss of section thickness due to
 
FACPlant-specificNot applicable, PWR only Carbon steel tube support plate (Item Number
 
3.1.1.B-20)
Ligament cracking due to corrosionPlant-specificNot applicable, PWR only Steam generatorfeedwater inlet ring
 
and supports (Item Number
 
3.1.1.B-21)
Loss of material dueto flow-corrosion Combustion engineering (CE)
 
steam generator feedwater ring
 
inspectionNot applicable, PWR only Reactor vessel closure studs and
 
stud assembly (Item Number
 
3.1.1.B-22)
Crack initiation andgrowth due to SCC
 
and/or IGSCC Reactor head closure studs Reactor Head Closure Studs
 
Program (B2.1.3)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1.1)
CASS pump casing and valve body (Item Number
 
3.1.1.B-23)
Loss of fracture toughness due to
 
thermal aging
 
embrittlementInservice inspectionASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)CASS piping (Item Number
 
3.1.1.B-24)
Loss of fracture toughness due to
 
thermal aging
 
embrittlementThermal aging embrittlement of
 
CASS Not applicable (CASS piping does
 
not exist)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-206BWR piping and fittings; steam
 
generator components (Item Number
 
3.1.1.B-25)Wall thinning due toflow-accelerated
 
corrosionFlow-accelerated corrosionFlow Accelerated Corrosion Program (B2.1.9)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)Not applicable, PWR only Reactor coolant pressure boundary (RCPB) valve
 
closure bolting, manway and
 
holding bolting, and
 
closure bolting in
 
high pressure and
 
high temperature systems (Item Number
 
3.1.1.B-26)
Loss of material dueto wear; loss of
 
preload due to stress relaxation;
 
crack initiation and growth due to cyclic
 
loading and/or SCCBolting integrityB olting Integrity Program (B2.1.36)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)Not applicable, PWR onlyFeedwater and control rod drive (CRD) return line
 
nozzles (Item Number
 
3.1.1.B-27)
Crack initiation andgrowth due to cyclic
 
loadingFeedwater nozzle; CRD return line
 
nozzleBWR Feedwater Nozzle Program (B2.1.5), BWR
 
Control Rod Drive
 
Return Line (CRDRL) Nozzle
 
Program (B2.1.37)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1.2)
Vessel shellattachment welds (Item Number
 
3.1.1.B-28)
Crack initiation andgrowth due to SCC, IGSCC BWR vessel IDattachment welds; water chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Vessel ID Attachment Welds
 
Program (B2.1.4)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)Nozzle safe ends, recirculation pump
 
casing, connected systems piping and fittings, body and
 
bonnet of valves (Item Number
 
3.1.1.B-29)
Crack initiation andgrowth due to SCC, IGSCC BWR stress corrosion cracking; water chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Stress Corrosion
 
Cracking Program (B2.1.6)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)Penetrations (Item Number
 
3.1.1.B-30)
Crack initiation andgrowth due to SCC, IGSCC, cyclic
 
loadingBWR penetrations;water chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Penetrations
 
Program (B2.1.6)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-207 Core shroud and core plate, support
 
structure, top guide, core spray lines and
 
spargers, jet pump
 
assemblies, control
 
rod drive housing, nuclear instrumentation
 
guide tubes (Item Number
 
3.1.1.B-31)
Crack initiation andgrowth due to SCC, IGSCC, IASCC BWR vesselinternals; water
 
chemistry Water Chemistry Control Program (B2.1.2), BWR
 
Vessel Internals
 
Program (B2.1.8)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)Core shroud and core plate access hole cover (welded
 
and mechanical
 
covers)
(Item Number
 
3.1.1.B-32)
Crack initiation andgrowth due to SCC, IGSCC, IASCCASME Section XI inservice inspection; water chemistry BWR Vessel Internals Program (B2.1.8), Water Chemistry Control
 
Program (B2.1.2)Consistent withGALL with exceptions Access hole cover is managed through
 
BWRVIP Jet pump assembly castings; orificed
 
fuel support (Item Number
 
3.1.1.B-33)
Loss of fracture toughness due to
 
thermal aging and
 
neutron irradiation
 
embrittlementThermal aging and neutron irradiation
 
embrittlement BWR Vessel Internals Program (B2.1.8)Consistent with GALL (see Section
 
3.1B.2.1.3)
Unclad top head and nozzles (Item Number
 
3.1.1.B-34)
Loss of material due to general, pitting, and crevice
 
corrosion Inservice inspection;water chemistry Water Chemistry Control Program (B2.1.2), ASME
 
Section XI, Inservice Inspection (Subsections IWB, IWC, IWD) Program (B2.1.1)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.1B.2.1)CRD nozzle (Item Number
 
3.1.1.B-35)
Crack initiation andgrowth due to
 
PWSCCNi-alloy nozzles andpenetrations; water
 
chemistryNot applicable, PWR only Reactor vessel nozzles safe ends
 
and CRD housing;
 
reactor coolant system components (except CASS and
 
bolting)
(Item Number
 
3.1.1.B-36)
Crack initiation andgrowth due to cyclic
 
loading, and/or SCC and PWSCC Inservice inspection;water chemistryNot applicable, PWR only Reactor vessel internals CASS
 
components (Item Number
 
3.1.1.B-37)
Loss of fracture toughness due to
 
thermal aging, neutron irradiation
 
embrittlement, and void swellingThermal aging and neutron irradiation
 
embrittlementNot applicable, PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-208 External surfaces of carbon steel
 
components in
 
reactor coolant system pressure
 
boundary (Item Number
 
3.1.1.B-38)
Loss of material due to boric acid
 
corrosionBoric acid corrosionNot applicable, PWR only Steam generatorsecondary manways
 
and handholds (CS)
(Item Number
 
3.1.1.B-39)
Loss of material due to erosionInservice inspectionNot applicable, PWR only Reactor internals, reactor vessel
 
closure studs, and
 
core support pads (Item Number
 
3.1.1.B-40)
Loss of material dueto wearInservice inspectionNot applicable, PWR only Pressurizer integral support (Item Number
 
3.1.1.B-41)
Crack initiation andgrowth due to cyclic
 
loadingInservice inspectionNot applicable, PWR onlyUpper and lower internals assembly (Westinghouse)
(Item Number
 
3.1.1.B-42)
Loss of preload dueto stress relaxation Inservice inspection; loose part and/or
 
neutron noise
 
monitoringNot applicable, PWR only Reactor vessel internals in fuel
 
zone region [except Westinghouse and Babcock & Wilcox (B&W) baffle bolts]
(Item Number
 
3.1.1.B-43)
Loss of fracture toughness due to
 
neutron irradiation
 
embrittlement, and void swelling PWR vesselinternals; water
 
chemistryNot applicable, PWR only Steam generatorupper and lower
 
heads; tubesheets; primary nozzles and
 
safe ends (Item Number
 
3.1.1.B-44)
Crack initiation andgrowth due to SCC, PWSCC, IASCC Inservice inspection;water chemistryNot applicable, PWR only Vessel internals (except Westinghouse and
 
B&W baffle former
 
bolts)
(Item Number
 
3.1.1.B-45)
Crack initiation andgrowth due to SCC
 
and IASCC PWR vesselinternals; water
 
chemistryNot applicable, PWR only Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-209 Reactor internals(B&W screws and
 
bolts)
(Item Number
 
3.1.1.B-46)
Loss of preload dueto stress relaxation Inservice inspection; loose part
 
monitoringNot applicable, PWR only Reactor vessel closure studs and
 
stud assembly (Item Number
 
3.1.1.B-47)
Loss of material dueto wear Reactor head closure studsNot applicable, PWR only Reactor internals(Westinghouse upper and lower
 
internal assemblies;
 
CE bolts and tie
 
rods)
(Item Number
 
3.1.1.B-48)
Loss of preload dueto stress relaxation Inservice inspection; loose part
 
monitoringNot applicable, PWR only The staff's review of the NMP2 component groups followed one of several approaches. One approach, documented in SER Section 3.1B.2.1, discusses the staff's review of the AMR results
 
for components in the reactor vessel, internals, and reactor coolant systems that the applicant
 
indicated are consistent with the GALL Report and do not require further evaluation. Another
 
approach, documented in SER Section 3.1B.2.2, discusses the staff's review of the AMR results
 
for components in the reactor vessel, internals, and reactor coolant systems that the applicant
 
indicated are consistent with the GALL Report and for which further evaluation is recommended.
 
A third approach, documented in SER Section 3.1B.2.3, discusses the staff's review of the AMR
 
results for components in the reactor vessel, internals, and reactor coolant systems that the
 
applicant indicated are not consistent with, or not addressed in, the GALL Report. The staff's
 
review of AMPs that are credited to manage or monitor aging effects of the reactor vessel, internals, and reactor coolant systems components is documented in SER Section 3.0.3.3.1B.2.1  AMR Results That Are Consistent with the GALL Report Summary of Technical Information in the Amended Application. In ALRA Section 3.1.2.B, the applicant identified the materials, environments, and AERMs. The applicant identified the
 
following programs that manage the aging effects related to the reactor vessel, internals, and
 
reactor coolant systems components:
* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Water Chemistry Control Program
* Reactor Head Closure Studs Program
* BWR Vessel ID Attachment Welds Program
* BWR Feedwater Nozzle Program
* BWR Stress Corrosion Cracking Program
* BWR Penetrations Program
* BWR Vessel Internals Program
* Flow-Accelerated Corrosion Program 3-210
* Reactor Vessel Surveillance Program
* One-Time Inspection Program
* Systems Walkdown Program
* Bolting Integrity Program
* BWR Control Rod Drive Return Line (CRDRL) Nozzle Program Staff Evaluation. In ALRA Tables 3.1.2.B-1 through 3.1.2.B-5, the applicant provided a summary of AMRs for the reactor vessel, internals, and reactor coolant systems components, and
 
identified which AMRs it considered to be consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report does not recommend further
 
evaluation, the staff performed an audit and review to determine whether the plant-specific
 
components contained in these GALL Report component groups were bounded by the GALL
 
Report evaluation.
The applicant provided a note for each AMR line item. The notes indicate how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with
 
Notes A through E, which indicate that 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report and the 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been
 
reviewed and accepted by the staff. The staff also determined whether the AMP identified by the
 
applicant was consistent with the AMP identified in the GALL Report 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 AMP identified by the GALL Report. This note indicates that the applicant
 
was unable to find a listing of some system components in the GALL Report. However, the
 
applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was 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 AMP identified in the GALL Report. 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. The staff verified whether
 
the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The 3-211 staff also determined whether the AMP identified by the applicant was consistent with the AMP identified in the GALL Report 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 a different agi ng management program is credited. The staff audited these line items to verify consistency with the GALL Report. The staff also determined
 
whether the identified AMP would manage the aging effect consistent with the AMP identified by
 
the GALL Report and whether the AMR was valid for the site-specific conditions.
The staff conducted an audit and review of the information provided in the ALRA, as documented in the Audit and Review 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
 
ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The
 
staff's evaluation is discussed below.
3.1B.2.1.1  Crack Initiation and Growth Due to SCC and/or IGSCC
 
In the discussion section of ALRA Table 3.1.1.B, Item 3.1.1.B-22 the applicant stated that the Reactor Head Closure Studs Program is credited for closure head studs and nuts that have an
 
aging effect and aging effect mechanism of loss of material due to general corrosion. As
 
documented in the audit and review report, the staff noted that ALRA Table 3.1.1.B, Item 3.1.1.B-22 applies to the aging effect and aging effect mechanism of cracking and asked
 
the applicant to provide clarification.
In its letter dated December 1, 2005, the applicant revised the ALRA Table 3.1.1.B, Item 3.1.1.B-22 discussion column by deleting the reference to managing loss of material and
 
crediting the aging effect and aging effect mechanism of crack initiation and growth due to SCC.
 
The staff found this revision consistent with the GALL Report and, therefore, acceptable.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
3.1B.2.1.2  Crack Initiation and Growth Due to Cyclic Loading
 
In the discussion section of ALRA Table 3.1.1.B, Item 3.1.1.B-27, the applicant stated that for feedwater nozzles NMP2 manages aging with the BWR Feedwater Nozzle Program, which is consistent with GALL AMP XI.M5, "Feedwater Nozzle."In the ALRA, the applicant stated that GALL AMP XI.M5 is credited also with managing cracking of feedwater nozzle thermal sleeves due to SCC. Verification of the absence of nozzle cracking
 
provides proof that the thermal sleeve intended function is not degraded. For CRDRL nozzles
 
NMP2 manages aging with the BWR CRDRL Nozzle Program, which is consistent with GALL AMP XI.M6, "BWR Control Rod Drive Return Line Nozzle." GALL AMP XI.M6 is credited also with managing cracking of CRD return line nozzle thermal sleeves due to SCC. The applicant
 
stated that verification of the absence of nozzle cracking proves that the thermal sleeve
 
intended function is not degraded. In its letter dated September 15, 2005, the applicant stated
 
that its BWR Feedwater Nozzle and BWR CRDRL Nozzle Programs had been removed as
 
credited programs for the feedwater nozzle and CRDRL nozzle thermal sleeves. As
 
documented in the audit and review report, the staff asked the applicant to address the aging
 
management for the feedwater nozzle thermal sleeves. The applicant responded that it will use 3-212 inspections performed under the BWR Vessel Internals Program with surrogate components more readily accessible for examination. For NMP2, the surrogate components are the
 
feedwater sparger end bracket welds. As documented in the audit and review report, the
 
applicant also provided its basis for choosing the feedwater sparger end bracket welds as
 
follows.The applicant noted that a similar evaluation of the NMP1 feedwater sparger welds and the selection of surrogate welds accessible for inspection also would be acceptable for NMP2.
 
These accessible welds would be used as a leading indicator of potential IGSCC cracking of the
 
thermal sleeve. If cracking is found in these welds a supplemental evaluation of the thermal
 
sleeve integrity would be required.
The applicant stated that review of the NMP2 feedwater thermal sleeve and sparger had been completed and had confirmed that the thermal sleeve material is 316L with several hidden
 
stainless steel welds. The fabrication method review, not complete, will determine the welding
 
procedures. If the hidden welds were stress relieved they would not be considered susceptible
 
to IGSCC and the aging effect of cracking would not be considered applicable to NMP2.
In addition, as documented in the audit and review report, the applicant stated that review of the NMP2 feedwater sparger installation details found field installation of a 20,000 lbf load creating
 
a 0.125 inch cold spring to the sparger. The sparger end brackets were pinned, locking in the
 
cold spring, and then final field-welded with a fillet weld. The applicant stated further that this
 
installation detail is similar to that of NMP1. The result of the cold spring is a fit-up net tensile
 
stress superimposed on the weld residual stress. The combination of the fit-up stress (cold
 
spring) plus the residual stress of the field weld conditions and the fillet weld crevice geometry is
 
more susceptible to IGSCC than the thermal sleeve welds. The corrosion potential of reactor
 
water in the region of the feedwater sparger end bracket welds is equivalent to if not greater
 
than that of the reactor water in contact with the outside diameter weld of the thermal sleeve.
 
The applicant also stated that an EVT-1 examination of the NMP1 and NMP2 feedwater sparger
 
end bracket welds will be added to its BWR Vessel Internals Program as an enhancement. The
 
inspection extent and frequency of the end bracket weld inspection will be the same as the ASME Section XI inspection of the feedwater sparger bracket vessel attachment welds. If the
 
final fabrication review of the NMP2 feedwater thermal sleeve concludes that the hidden welds
 
are not IGSCC-susceptible the NMP2 inspections will be discontinued.
Furthermore, the applicant concluded that overall inspection of the NMP2 feedwater sparger end bracket welds represents conservative inspection of the material condition of the hidden
 
thermal sleeve welds for potential IGSCC cracking. Therefore, consistent with the discussion
 
between the staff and the applicant, as documented in the audit and review report, cracking of
 
the NMP2 feedwater nozzle thermal sleeves will be managed by the applicant's BWR
 
Feedwater Nozzle, BWR Vessel Internals, and Water Chemistry Control Programs. In its letter
 
dated December 1, 2005, the applicant stated that it will add an EVT-1 examination of the
 
NMP2 feedwater sparger brackets as an enhancement to its BWR Vessel Internals Program to
 
address this issue. The staff reviewed the applicant's response and found it acceptable because
 
the applicant's surrogate weld inspection manages aging adequately for the feedwater nozzle
 
thermal sleeves.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
3-213 3.1B.2.1.3  Loss of Fracture Toughness Due to Thermal Aging and Neutron Irradiation Embrittlement In the discussion section of ALRA Table 3.1.1.B, Item 3.1.1.B-33 the applicant stated that loss of fracture toughness due to thermal aging and neutron irradiation embrittlement of jet pumps is
 
managed by BWRVIP-41, "BWR Jet Pump A ssembly Inspection and Flaw EvaluationGuidelines," of GALL AMP XI.M9, "BWR Vesse l Internals Program." Aging management of the orificed fuel supports is conducted according to BWRVIP-47, "BWR Lower Plenum Inspection and Flaw Evaluation Guidelines," of GALL AMP XI.M9.GALL AMP XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel," is credited for managing the aging effect and aging effect mechanism of loss of
 
fracture toughness due to thermal aging and neutron embrittlement. In its letter dated November
 
17, 2005, the applicant revised its BWR Vessel Internals Program to address the management
 
of fracture toughness due to neutron fluence and thermal embrittlement for NMP CASS
 
components. The staff's review and evaluation of the applicant's BWR Vessel Internals Program
 
are documented in SER Section 3.0.3.2.6. The staff found the applicant's BWR Vessel Internals
 
Program acceptable for managing the loss of fracture toughness because the applicant committed to meet the GALL AMP XI.M13 recommendation.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicant's consideration of recent operating
 
experience and proposals for managing associated 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 consistent with the AMRs in the GALL Report. Therefore, the staff concludes
 
that there is reasonable assurance that the applicant has demonstrated that the effects of aging
 
for these components will be adequately managed so that their intended functions will be
 
maintained consistent with the CLB for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).3.1B.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended Summary of Technical Information in the Amended Application. In Section 3.1.2.C of its letter dated August 19, 2005, the applicant provided further evaluation of aging management for
 
NMPNS as recommended by the GALL Report for the reactor vessel, internals, and reactor
 
coolant systems components. The applicant provi ded information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* loss of material due to pitting and crevice corrosion
* loss of fracture toughness due to neutron irradiation embrittlement
* crack initiation and growth due to thermal and mechanical loading or stress corrosion cracking
* crack growth due to cyclic loading 3-214
* changes in dimension due to void swelling
* crack initiation and growth due to stress corrosion cracking or primary water stress corrosion cracking
* crack initiation and growth due to stress corrosion cracking or irradiation-assisted stress corrosion cracking
* loss of preload due to stress relaxation
* loss of section thickness due to erosion
* crack initiation and growth due to PWSCC, ODSCC, or intergranular attack or loss of material due to wastage and pitting corrosion or loss of section thickness due to fretting
 
and wear or denting due to corrosion of carbon steel tube support plate
* loss of section thickness due to flow-accelerated corrosion
* ligament cracking due to corrosion
* loss of material due to flow-accelerated corrosion Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends
 
further evaluation, the staff audited and reviewed the applicant's evaluation to determine
 
whether it adequately addressed the issues that were further evaluated. In addition, the staff
 
reviewed the applicant's further evaluations against the criteria contained in SRP-LR
 
Section 3.1.2.2. Details of the staff's audit are documented in the staff's Audit and Review
 
Report. The staff's evaluation of the aging effects is discussed in the following sections.
3.1B.2.2.1  Cumulative Fatigue Damage
 
In Section 3.1.2.C.1 of its letter dated August 19, 2005, the applicant stated that fatigue is a TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs according to
 
10 CFR 54.21(c)(1). SER Section 4.3 documents the staff's review of the applicant's evaluation
 
of this TLAA.
As documented in the audit and review report, the staff noted that for ALRA Table 3.1.2.A-2 (on page 3.1-51), the fatigue damage of CRD assemblies (including drive mechanism and housing)
 
will be managed through the TLAA but that in ALRA Appendix B, Aging management program
 
and activities (page B2-25), the applicant stated that there are no TLAAs. The staff asked the
 
applicant to explain how the specified NMP1 components are managed. The applicant
 
responded that the only NMP1 reactor vessel internals (RVI) components with calculations or
 
analyses meeting TLAA criteria are the core shroud tie rod assemblies, the clamps, and the
 
CRD assemblies (including drive mechanism and housing). The tie rod assemblies and clamps
 
are repairs for horizontal and vertical core shroud welds on which ASME III-type stress and
 
fatigue analyses were performed during the design process. The pressure boundary portion of
 
the CRD assemblies was evaluated for fatigue. A cumulative usage factor was determined for
 
the CRD penetration including the stub tube, CRD housing, and the stub tube-to-vessel weld
 
and housing-to-stub tube weld. The AMR for the stub tube is addressed in ALRA Table 3.1.2.A.
 
The applicant also responded that for RVI components with no analysis meeting TLAA criteria
 
the "Aging Management Program" column of ALRA Table 3.1.2.A-2 will be modified to replace
 
"TLAA evaluated according to 10 CFR 54.21(c)" with "None." A plant-specific note referencing
 
the relevant BWRVIP Inspection and Evaluation guideline or other basis for not managing 3-215 fatigue will be added to ALRA Table 3.1.2.A-2 for each component with "None" in the AMP column for the aging effect and aging effect mechanism of cumulative fatigue damage or where
 
the TLAA is applicable only to a subset of the component type.
In its letter dated December 1, 2005, the applicant responded by revising ALRA Table 3.1.2.A-2 and Table 3.1.2.B-2 to address this issue. The staff determined that a high cumulative fatigue
 
usage factor indicates a high potential for crack initiation. Although the applicant's response
 
removed the aging effect of cumulative fatigue damage for those components identified in the
 
December 1, 2005, letter, the aging effect of cracking is adequately managed through other
 
AMPs. Therefore, the staff found the response acceptable.
The staff's review of the applicant's response found its action consistent with the GALL Report and therefore acceptable.
3.1B.2.2.2  Loss of Material Due to Pitting and Crevice Corrosion
 
The staff reviewed Section 3.1.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.1.2.2.2.
The applicant stated in Section 3.1.2.C.2 of its letter dated August 19, 2005 that the aging effect and aging effect mechanism of pitting and crevice corrosion are not applicable to the PWR
 
steam generator shell assembly. The staff determined that the aging effect and aging effect
 
mechanism of PWR steam generator shell assembly pitting and crevice corrosion are not
 
applicable to NMP.
Because NMP has no components from this group the staff found this aging effect and aging effect mechanism not applicable to NMP.
In addition the staff reviewed 10 CFR 3.1.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR 10 CFR 3.1.2.2.2.
In Section 3.1.2.C.2 of its letter dated August 19, 2005, the applicant also addressed loss of material due to isolation condenser components due to general pitting and crevice corrosion.
 
The applicant stated in the August 19, 2005, letter that NMP2 has no isolation condensers;
 
therefore this aging effect and aging effect mechanism are not applicable to NMP2.
Because NMP2 has no isolation condensers the staff found this aging effect and aging effect mechanism not applicable to NMP2.
3.1B.2.2.3  Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement
 
The staff reviewed Section 3.1.2.C.3 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.1.2.2.3.
In Section 3.1.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of fracture toughness due to neutron irradiation embrittlement of the reactor vessel.
SRP-LR Section 3.1.2.2.3 states that certain aspects of neutron irradiation embrittlement are TLAAs as defined in 10 CFR 54.3 and must be evaluated according to 10 CFR 54.21(c)(1). SER
 
Section 4.2 documents the staff's review of the applicant's evaluation of this TLAA.
3-216 SRP-LR Section 3.1.2.2.3 states that loss of fracture toughness due to neutron irradiation embrittlement could occur in the reactor vessel.
The Reactor Vessel Surveillance Program monitors neutron irradiation embrittlement of the reactor vessel. The staff review and evaluation of the applicant's Reactor Vessel Surveillance
 
Program are documented in SER 10 CFR 3.0.3.2.16.
In ALRA Table 3.1.2.B-1 the applicant stated that loss of fracture toughness of vessel shells (beltine, lower shell, upper nozzle shell, and upper RPV shell and vessel shell welds (including
 
attachment welds) will be managed by its Reacto r Vessel Surveillance Program. The staff asked the applicant to clarify which areas have neutron fluence exceeding 1E17 n/cm 2 (E>1MeV).
The applicant responded that vessel shells - beltline and vessel shells - lower and the beltline welds have a neutron fluence exceeding 1E17 n/cm
: 2. The applicant's Reactor Vessel Surveillance Program manages aging of thes e components. The component type attachment welds needs no management by the applicant's R eactor Vessel Surveillance Program because even though these welds receive a neutron fluence equal to or greater than E17 n/cm 2 they are not ferritic material. The only carbon/low alloy steel attachment welds are the steam dryer
 
holddown bracket attachment welds in the upper head which are low-fluence welds. The
 
applicant modified ALRA Table 3.1.2.B-1 to show those components managed by the Reactor Vessel Surveillance Program. In its letter dated December 1, 2005, the applicant revised ALRA
 
Table 3.1.2.B-1 to address this issue. The staff reviewed the applicant's letter and found this
 
revision consistent with the GALL Report and, therefore, acceptable.
In ALRA Table 3.1.2.B-1 the applicant stated that loss of fracture toughness of nozzles will be managed by its Reactor Vessel Surveillance Program. The staff asked the applicant to clarify
 
which nozzles will be managed by the Reactor Vessel Surveillance Program.
As documented in the audit and review report, the applicant responded that LPCI/residual heat removal (RHR) nozzles and water level nozzle will be managed by the Reactor Vessel
 
Surveillance Program. Activities of the Reactor Vessel Surveillance Program include an analysis
 
of these nozzles for pressure-temperature (P-T) limits considering the projected fluence for 54
 
effective full-power years (EFPYs) for them. In its letter dated December 1, 2005, the applicant added a plant-specific Note 76 to ALRA Table 3.1.2.B-1 to specify those components managed
 
by the Reactor Vessel Surveillance Program. The staff found this note consistent with the GALL
 
Report and therefore acceptable.
SRP-LR Section 3.1.2.2.3 states that loss of fracture toughness due to neutron irradiation embrittlement and void swelling could occur in Westinghouse and B&W baffle/former bolts.
In Section 3.1.2.C.3 of its letter dated August 19, 2005, the applicant stated that this item pertains to PWR baffle/former bolts only and is not applicable to NMP.
Because NMP has no components in this group the staff found that this aging effect and aging effect mechanism not applicable.
The staff concludes that the applicant's programs have met the criteria of SRP-LR Section 3.1.2.2.3. For those line items addressed in Section 3.1.2.C.3 of the applicant's letter
 
dated August 19, 2005, the staff determined that the applicant has demonstrated consistent with
 
the GALL Report that aging effects will be adequately managed so that intended functions will 3-217 be maintained consistent with the CLB during the period of extended operation as required by 10 CFR 54.21(a)(3).
3.1B.2.2.4  Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress Corrosion Cracking The staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005 against the criteria of SRP-LR Section 3.1.2.2.4.
In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that could occur
 
in small-bore reactor coolant systems and connected system piping less than NPS 4.
SRP-LR Section 3.1.2.2.4.1 states that crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) could occur in small-bore reactor coolant
 
systems and connected system piping less than NPS 4. The program relies on ASMESection XI ISI and on control of water chemistry to mitigate SCC. The GALL Report
 
recommends a plant-specific destructive examinat ion or a NDE that permits inspection of the inside surfaces of the piping to ensure that cracking has not occurred and that component
 
intended function will be maintained during the extended period. The AMPs should be
 
augmented by confirming that service-induced we ld cracking has not occurred in small-bore piping less than NPS 4 including pipe, fittings, and branch connections. A one-time inspection of
 
a sample of locations is an acceptable method to ensure that the aging effect and aging effect
 
mechanism are not occurring and that the component's intended function will be maintained
 
during the period of extended operation.
In Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant also stated that for NMP2aging of the subject small-bore piping is managed by the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program, Water Chemistry Control Program, and One-Time Inspection
 
Program.Additionally the applicant stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for NMP2 reactor vessel instrumentation, reactor recirculation, and CRD systems not part of its ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program NMP credits only its Water
 
Chemistry Control and One-Time Inspection Programs to manage aging.
The applicant further stated in Section 3.1.2.C.4 of its letter dated August 19, 2005, that for thesmall-bore piping included in the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI
 
Program or not the inspections of the One-Time Inspection Program will use either NDE
 
methods with a demonstrated capability to detect cracks on the inside surfaces of the piping or
 
destructive examinations. Both nondestructive and destructive examinations will be performed on a piping sample.
The staff reviewed the applicant's ISI plan and One-Time Inspection Program and found them adequate to managed this cracking issue and consistent with the GALL Report recommendation. The staff's evaluations of the applicant's ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, Water Chemistry Control, and One-Time Inspection Programs are
 
documented in SER Sections 3.0.3.2.1, 3.0.3.2.2, and 3.0.3.1.4, respectively.
3-218 In addition the staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.1.2.2.4.
Also in Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that
 
could occur in the BWR reactor vessel flange leak detection line and BWR jet pump sensing
 
line.SRP-LR Section 3.1.2.2.4 also states that crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) could occur in the BWR reactor vessel flange
 
leak detection line and the BWR jet pump sensing line. The GALL Report recommends that a
 
plant-specific aging management program be evaluated to mitigate or detect crack initiation and
 
growth due to SCC of vessel flange leak detection line.
The applicant stated in its letter dated August 19, 2005, that for NMP1 and NMP2 cracking ofthe vessel flange leak detection lines is managed by the ASME Section Xl (Subsections IWB, IWC, and IWD) ISI Program, One-Time Inspection Program, and Water Chemistry Control
 
Program. The inspections conducted under the applicant's One-Time Inspection Program will
 
use either NDE methods with a demonstrated capability to detect cracks on the inside surfaces
 
of the piping or destructive examinations. Both nondestructive and destructive examinations will be performed on a piping sample. A portion of the NMP2 vessel flange leak detection line is
 
carbon steel not subject to cracking. The applicant stated that loss of material of the carbon
 
steel portion is managed by its Water Chemistr y Control and One-Time Inspection Programs.
The applicant also stated in its letter dated August 19, 2005, that for NMP2 the jet pump sensing lines are not within the scope of license renewal; therefore, the aging effect and aging
 
effect mechanism of cracking for jet pump sensing lines is not applicable at NMP.
The staff reviewed the applicant's piping and instrument drawings (P&ID) and ISI plan to determine whether the applicant's program is adequate and consistent with the GALL Report
 
recommendation.The staff's review and evaluation of the applicant's ASME Section Xl (Subsections IWB, IWC, and IWD) ISI, Water Chemistry Control and One-Time Inspection Programs are documented in
 
SER Sections 3.0.3.2.1, 3.0.3.2.2, and 3.0.3.1.4, respectively.
Furthermore, the staff reviewed Section 3.1.2.C.4 of the applicant's letter dated August19, 2005, against the criteria of SRP-LR Section 3.1.2.2.4.
Also in Section 3.1.2.C.4 of its letter dated August 19, 2005, the applicant addressed crack initiation and growth due to thermal and mechanical loading or SCC (including IGSCC) that
 
could occur in BWR isolation condenser components.
The applicant stated in its August 19, 2005, letter that NMP2 has no isolation condensers; therefore, this aging effect and aging effect mechanism is not applicable to NMP2.
Because NMP2 has no isolation condensers the staff found this aging effect and aging effect mechanism not applicable to NMP2.
3-219 The staff concludes that there is reasonable assurance that the applicant's programs have met the criteria of SRP-LR Section 3.1.2.2.4. For those line items addressed in Section 3.1.2.C.4 of
 
the applicant's letter dated August 19, 2005, the staff determined that the applicant has
 
demonstrated that the effects of aging will be adequately managed consistent with the GALL
 
Report and that intended functions will be maintained consistent with the CLB during the period
 
of extended operation as required by 10 CFR 54.21(a)(3).
3.1B.2.2.5  Crack Growth due to Cyclic Loading
 
The staff reviewed Section 3.1.2.C.5 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.5.
In Section 3.1.2.C.5 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.5 states that crack growth due to cyclic loading could occur in the reactor vessel shell and the reactor coolant system piping and fittings. SRP-LR Table 3.1-1
 
states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.6  Changes in Dimension due to Void Swelling
 
The staff reviewed Section 3.1.2.C.6 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.6.
In Section 3.1.2.C.6 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.6 states that changes in dimension due to void swelling could occur in reactor internal components. SRP-LR Table 3.1-1 states that further evaluation for this aging
 
effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.7  Crack Initiation and Growth due to Stress Corrosion Cracking or Primary Water Stress Corrosion Cracking The staff reviewed Section 3.1.2.C.7 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.7.
In Section 3.1.2.C.7 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.7 states that crack initiation and growth due to SCC and PWSCC could occur: (1) in PWR core support pads (or core guide lugs), instrument tubes (bottom head
 
penetrations), pressurizer spray heads, and nozzles for the steam generator instruments and
 
drains; (2) in PWR CASS reactor coolant system piping and fittings and pressurizer surge line
 
nozzles; and (3) in PWR pressurizer instrumentation penetrations and heater sheaths and 3-220 sleeves made of Ni alloys. SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.8  Crack Initiation and Growth due to Stress Corrosion Cracking or Irradiation-Assisted Stress Corrosion Cracking The staff reviewed Section 3.1.2.C.8 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.8.
In Section 3.1.2.C.8 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.8 states that crack initiation and growth due to SCC or IASCC could occur in baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states that
 
further evaluation for this aging effect is only applicable to PWR plants.
The staff concurs that this aging effect is not applicable to NMP2.
 
3.1B.2.2.9  Loss of Preload due to Stress Relaxation
 
The staff reviewed Section 3.1.2.C.9 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.9.
In Section 3.1.2.C.9 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation could occur in baffle/former bolts in Westinghouse and B&W reactors. SRP-LR Table 3.1-1 states that further
 
evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.10  Loss of Section Thickness due to Erosion
 
The staff reviewed Section 3.1.2.C.10 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.10.
In Section 3.1.2.C.10 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.10 states that loss of section thickness due to erosion could occur in steam generator feedwater impingement plates and supports. SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
3-221 3.1B.2.2.11  Crack Initiation and Growth due to PWSCC, ODSCC, or Intergranular Attack or Loss of Material due to Wastage and Pitting Corrosion or Loss of Section Thickness due to
 
Fretting and Wear or Denting due to Corrosion of Carbon Steel Tube Support Plate The staff reviewed Section 3.1.2.C.11 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.11.
In Section 3.1.2.C.11 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.11 states that crack initiation and growth due to PWSCC, ODSCC, or IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion
 
could occur in alloy 600 components of the steam generator tubes, repair sleeves and plugs.
 
SRP-LR Table 3.1-1 states that further evaluation for this aging effect is only applicable to PWR
 
plants.Based on the above review, the staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.12  Loss of Section Thickness due to Flow-accelerated Corrosion
 
The staff reviewed Section 3.1.2.C.12 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.12.
In Section 3.1.2.C.12 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.12 states that loss of section thickness due to flow-accelerated corrosion could occur in tube support lattice bars made of carbon steel. SRP-LR Table 3.1-1
 
states that further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.13  Ligament Cracking due to Corrosion
 
The staff reviewed Section 3.1.2.C.13 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.1.2.2.13.
In Section 3.1.2.C.13 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in carbon steel components in the steam generator tube support plate. SRP-LR Table 3.1-1 states that
 
further evaluation for this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.14  Loss of Material due to Flow-accelerated Corrosion
 
The staff reviewed Section 3.1.2.C.14 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.1.2.2.14.
3-222 In Section 3.1.2.C.14 of letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
SRP-LR Section 3.1.2.2.14 states that loss of material due to flow-accelerated corrosion could occur in feedwater inlet ring and supports. SRP-LR Table 3.1-1 states that further evaluation for
 
this aging effect is only applicable to PWR plants.
The staff found that this aging effect is not applicable to NMP2.
 
3.1B.2.2.15  Quality Assurance for Aging Management of Nonsafety-Related Components
 
SER Section 3.0.4 includes the staff's evaluation of the applicant's quality assurance program.
 
Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL
 
Report recommends further evaluation, the staff determined that the applicant adequately
 
addressed the issues that were further evaluated. The staff found that the applicant had
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).3.1B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report Summary of Technical Information in the Amended Application. In ALRA Tables 3.1.2.B-1 through 3.1.2.B-5, the staff reviewed additional details of the results of the AMRs for material, environment, AERM, and AMP combinations that are not consistent with the GALL Report, or
 
that are not addressed in the GALL Report.
In ALRA Tables 3.1.2.B-1 through 3.1.2.B-5, 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, and provided inform ation concerning how the aging effect will be managed. 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, materi al, 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.
Staff Evaluation. For component type, material, and environment combinations that are not evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine
 
whether the applicant had demonstrated that the effects of aging will be adequately managed
 
so that the intended functions will be maintained consistent with the CLB during the period of
 
extended operation. The staff's evaluation is discussed in the following sections.
3.1B.2.3.1  Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Pressure Vessel - Summary of Aging Management Evaluation - ALRA Table 3.1.2.B-1 3-223 The NMP2 RPV contains and supports the reactor core, reactor internals, and the reactor coolant/moderator. The RPV forms part of the RCPB and serves as a barrier against leakage of
 
radioactive materials to the drywell. The NMP2 RPV is a vertical, cylindrical pressure vessel
 
with hemispherical bottom and top heads. The cylindrical shell and top and bottom heads of the
 
RPV are fabricated from low-alloy steel, the interior of which is clad with stainless steel weld
 
overlay except for the top head and nozzle and nozzle weld zones. The RPV top head is
 
secured to the RPV by studs and nuts. The RPV flanges are sealed with two concentric metal
 
seal rings designed to permit no detectable leakage through the inner or outer seal at any
 
operating condition. The top head leak detection lines tap off of the vessel head between the
 
seal rings to detect leakage should the inner seal-ring fail.
The RPV is penetrated by various nozzles and the CRD housings and in-core instrumentation thimbles are welded to the bottom head of the RPV. The concrete and steel vessel support
 
pedestal is constructed as part of the building foundation. Steel anchor bolts set in the concrete
 
extend through the bearing plate and secure the flange of the RPV support skirt to the bearing
 
plate and thus to the support pedestal.
Summary of Technical Information in the Application. The applicant's plant-specific AMRs for the RPV components are identified in ALRA Table 3.1.2.B-1. By letter dated December 5, 2005, in ALRA Table 3.1.2.B-1, the applicant identified the following RPV components with AMR
 
results that are not consistent with or not addressed in the GALL Report:
* RPV core differential pressure and liquid control, CRD stub tube, drain lines, in-core instruments, and instrumentation penetrations
* RPV support skirt and attachment welds
* RPV top head closure studs and nuts
* RPV top head leak detection lines
* RPV valves The applicant identified the materials of fabrication for these RPV components as carbon steel and low alloy steel. The applicant indicated that applicable environments for these RPV components include containment air, non-borated water, and treated water (including steam).
The applicant credited the FAC Program with managing loss of material for the RPV core differential pressure and liquid control, CRD stub tube, drain lines, in-core instruments, and instrumentation penetrations. The ASME Section XI (Subsections IWB, IWC, and IWD) ISI
 
Program is credited with the management of loss of material for the RPV support skirt and
 
attachment welds. The applicant credited the Reactor Head Closure Studs Program with
 
managing loss of material of the top head closure studs and nuts. The Water Chemistry Control
 
Program and the One-Time Inspection Program are credited with managing the loss of material
 
for the RPV top head leak detection lines and the RPV valves. In addition the applicant credited
 
TLAA 4.3, "Thermal Fatigue," with managing cumulative fatigue damage of the top head closure
 
studs and nuts and the top head leak detection lines.
 
Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-1 which summarizes the results of AMR evaluations for the NMP2 RPV component groups. The staff's assessment of the RPV components not consistent with or addressed in the GALL Report for NMP2 is provided below.
3-224 The assessments of the NMP2 RPV top head leak detection lines and the RPV valves are in SER Section 3.1B.2.3.4.
RPV Core Differential Pressure and Liquid Control, CRD Stub Tube, Drain Lines, In-coreInstruments, and Instrumentation Penetrations Identification of Aging Effects - In ALRA Table 3.1.2.B-1, the applicant identified loss of material due to FAC as an aging effect applicable to the RPV core differential pressure and liquid
 
control, CRD stub tube, drain lines, in-core instruments, and instrumentation penetrations
 
fabricated from carbon or low alloy steel exposed to a treated water or steam in a
 
high-temperature environment.
FAC is a phenomenon in which repetitive cycles of corrosion and erosion cause wall thinning of carbon steel or low-alloy steel components exposed to high-temperature, high-velocity water or
 
water/steam environments. Normally, FAC occurs only with environmental temperatures above200 &deg;F. The rate of metal loss depends on a complex interplay of such parameters as water
 
chemistry, material composition, and hydrodynamics.
The staff determined that the applicant adequately identified loss of material due to FAC as an AERM for the RPV core differential pressure and liquid control, CRD stub tube, drain lines, in-core instruments, and instrumentation penet rations exposed to these environments. This aging effect is not addressed in GALL Report Volume 2 for these component, material, and
 
environment combinations; therefore, the staff concludes that this AERM is acceptable because
 
it is conservative relative to GALL Report Volume 2 and consistent with the EPRI Report, "Recommendations for an Effective Flow-Accelerated Corrosion Program."Aging Management Programs - In ALRA Table 3.1.2.B-1 the applicant credited the FAC Program with managing loss of material due to FAC for the RPV core differential pressure and
 
liquid control, CRD stub tube, drain lines, in-core instruments, and instrumentation penetrations.
 
Even though GALL Report Volume 2 does not address an AMP for such component, material, and environment combinations, it does recomm end crediting the FAC Program with managing FAC-induced wall thinning of carbon steel piping and fitting components. The staff found the
 
applicant's proposal conservative relative to GALL Report Volume 2 and, therefore, acceptable.
 
The applicant's FAC Program (ALRA AMP B2.1.9) is entirely consistent with GALL AMP XI.M17. The staff's evaluation of the FAC Program is in SER Section 3.0.3.1.3. RPV Support Skirt and Attachment Welds Identification of Aging Effects - In ALRA Table 3.1.2.B-1 and by letter dated December 5, 2005, the applicant identified loss of material due to general corrosion as an applicable aging effect for
 
the RPV support skirt and attachment welds fabricated from carbon or low alloy steel and
 
exposed to an environment of "air with thermal fatigue." The applicant's definition of "air with
 
thermal fatigue" is "this environment is applied to components exposed to air, that are also
 
subject to thermal cycles of sufficient magnitude for thermal fatigue to be a concern." The air
 
environment is the containment air surrounding the RPV and the support skirt.
GALL Report Volume 2 does not identify loss of material due to general corrosion as an aging effect in carbon and low alloy steel when these materials are exposed to an environment of
 
containment air; however, carbon and low alloy steel may rust or corrode in the presence of air
 
with an elevated humidity level. The staff found that the applicant has addressed this issue 3-225 conservatively; therefore, the staff found the applicant's identification of this AERM acceptable for the RPV support skirt and attachment welds. Aging Management Programs - In ALRA Table 3.1.2.B-1 the applicant credited the ASMESection XI (Subsections IWB, IWC, and IWD) ISI Program with managing loss of material due to
 
general corrosion for the RPV support skirt. By letter dated November 22, 2005, the staff requested that the applicant address why the ASME Section XI (Subsections IWB, IWC, and
 
IWD) ISI Program was credited with managing loss of material due to general corrosion in the
 
RPV support skirt. Instead, the staff recommended that this aging effect in the RPV support skirt be managed by the ASME Section XI (Subsection IWF) ISI Program because the RPV support
 
skirt is an ASME Class MC support. By letter dated December 5, 2005, the applicant revised
 
Table 3.1.2.B-1 to indicate that the AERM of loss of material of the RPV support skirt would be managed by the ASME Section XI (Subsection IWF) ISI Program. The staff found the
 
applicant's response acceptable because the RPV support skirt is an ASME Class MC
 
component, and, therefore, is managed appropriately by the ASME Section XI (Subsection IWF)
ISI Program.By letter dated December 5, 2005, the applicant indicated that it credits the ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program with managing the loss of material due to
 
general corrosion in the RPV attachment welds.
The GALL Report Volume 2 does not identify any AMPs for managing loss of material due to general corrosion for these component, material, and environment combinations. The staff
 
found the applicant's proposal conservative relative to the GALL Report Volume 2 and, therefore, acceptable. The applicant's ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program is an AMP consistent with GALL AMP X I.M1 with exceptions. The staff's evaluation ofthe ASME Section XI (Subsections IWB, IWC, and IWD) ISI Program is in SER Section 3.0.3.2.1. The applicant's ASME Section XI (Subsection IWF) ISI Program is an AMP consistent with GALL AMP XI.S3 with exceptions. The staff's evaluation of the ASME Section XI (Subsection IWF) ISI Program is in SER Section 3.0.3.2.19.
RPV Top Head Closure Studs and Nuts Identification of Aging Effects - In ALRA Table 3.1.2.B-1, the applicant identified loss of material due to general, crevice, and pitting corrosion as an aging effect applicable to the RPV top head
 
closure studs and nuts fabricated from carbon or low alloy steel and exposed to an environment
 
of non-borated water systems with operating temperatures > 212 &deg;F. The GALL Report Volume 2 identifies crack initiation and growth, SCC and IGSCC as aging effects for RPV top head enclosure closure studs and nuts fabricated from carbon or low alloy steel exposed to air, leaking reactor coolant water, or steam at 288 &deg;C, but does not identify loss
 
of material due to general, crevice, and pitting corrosion as aging effects in carbon and low alloy
 
steel when exposed to leakage of non-borated reactor coolant or steam. However, carbon and
 
low alloy steel may rust or corrode when exposed to aqueous liquids. The staff found that the
 
applicant has addressed this issue conservatively; therefore, the staff found the applicant's
 
identification of this AERM acceptable.
Also in ALRA Table 3.1.2.B-1, the applicant identified cumulative fatigue damage as an aging effect applicable to the RPV top head closure studs and nuts because of thermal cycling from
 
heatup and cooldown and other transient operating conditions of these components. The staff 3-226 found this identification acceptable because it meets the provisions in of SRP-LR Revision 1 Chapter 3.1 for assessing cumulative fatigue damage in ASME Code Class 1 components. SER
 
Section 4.3 contains the staff's assessment of those plant components requiring thermal fatigue
 
analyses for license renewal.Aging Management Programs - In ALRA Table 3.1.2.B-1, the applicant credited the Reactor Head Closure Studs Program with management of loss of material due to general, pitting, and
 
crevice corrosion for the RPV top head closure studs and nuts. Even though the GALL Report
 
Volume 2 does not address an AMP for these component, material, and environment
 
combinations, the staff found the applicant's proposal conservative relative to GALL Report
 
Volume 2 and, therefore, acceptable. The applicant's Reactor Head Closure Studs Program (ALRA AMP B2.1.3) is an AMP consistent with exception to GALL AMP XI.M3. The staff's
 
evaluation of the Reactor Head Closure Studs Program is in SER Section 3.0.3.2.3.
In ALRA Table 3.1.2.B-1, the applicant proposed managing cumulative fatigue damage of the RPV top head closure studs and nuts with the TLAA. This proposal is consistent with SRP-LR
 
Revision 1 and is, therefore, acceptable. The staff's evaluation of the applicant's TLAA on
 
thermal fatigue of ASME Code Class 1 components is in SER Section 4.3.
RPV Valves The review of the RPV valves is in SER Section 3.1B.2.3.4.
 
Conclusion. The staff has reviewed the applicant's plant-specific AMRs for evaluating the RPV components exposed to the containment air, non-borated water, and treated water (including
 
steam) environments. For these AMRs the staff has determined that the applicant has identified
 
aging effects applicable to these components that are exposed to these environments. The staff
 
also has determined that the applicant has credited either an appropriate inspection-based
 
AMP, an appropriate mitigation-based AMP, a TLAA, or combination of these strategies with
 
managing the aging effects applicable to the RPV components exposed to these environments.
The staff's review concludes that the applicant has demonstrated that the aging effects
 
associated with the NMP2 RPV will be adequately managed so that the intended functions will
 
be maintained consistent with the CLB for the period of extended operation as required by
 
10 CFR 54.21(a)(3).
3.1B.2.3.2  Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Pressure Vessel Internals - Summary of Aging Management Evaluation - ALRA Table 3.1.2.B-2 The NMP2 RPV internals support the core and other internal components, maintain fuel configuration (coolable geometry) during normal operation and accident conditions, and provide
 
reactor coolant flow through the core. The main NMP2 RPV internals components are the
 
reactor core, core shroud, core shroud stabilizers, core shroud support structures, top guide, CRD guide tubes, feedwater sparger, core spray spargers, steam dryer, and the jet pumps.
 
Except for the Zircaloy used in the fuel assemblies reactor internals are stainless steel or other corrosion-resistant alloys.
3-227 Summary of Technical Information in the Application. The applicant's plant-specific AMRs for the RPV internals components are in ALRA Table 3.1.2.B-2. The specific RPV components for
 
NMP2 with AMR results not consistent with or addressed in the GALL Report and within the
 
scope of ALRA Table 3.1.2.B-2 include:
* core shroud head bolts
* core shroud support structures (bolts, brackets, cap screws, clamps, keepers, restraints, and supports)
The applicant identified the materials of fabrication for the core shroud head bolts and the core shroud support structures (including the bolts, brackets, clamps, keepers, restraints, and
 
supports) as nickel-based alloys. The material of fabrication for the cap screws is carbon or low
 
alloy steel. The applicant identified applicable environments for these RPV internals
 
components as treated water (including st eam) environments of temperatures > 482 &deg;F, treated water or steam, high temperature with neutron fluences of < 5 x 10 20 n/cm 2 (E > 1.0 MeV), and treated water or steam high temperature with neutron fluences of >
1 x 10 17 n/cm 2 (E > 1.0 MeV).
The applicant credited the BWR Vessel Internals and the Water Chemistry Control Programs with managing cracking of the core shroud head bolts and core shroud support structures. In
 
addition the applicant credited TLAA 4.3, "Thermal Fatigue," with managing cumulative fatigue
 
damage of the core shroud support structures.
Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-2, which summarizes the results of AMR evaluations for the NMP2 RPV internal components. The staff's assessment of the RPV internals components not consistent with or addressed in the GALL Report for NMP2 is
 
provided here.
RPV Internals - Core Shroud Head Bolts Identification of Aging Effects - In ALRA Table 3.1.2.B-2 the applicant identified SCC or IGSCC as an aging effect applicable to the core shroud head bolts fabricated from nickel-based alloys
 
and exposed to a treated water or steam temperature > 482 &deg;F environment.
GALL Report Volume 2 does not identify SCC or IGSCC as an AERM for the core shroud head bolts. However, as these components are made from materials identical to those of the
 
nickel-alloy RPV internal components that have AMR Commodity Group line items on SCC/IGSCC in GALL Report Volume 2 the staff concludes that there is reasonable assurance
 
that the applicant's determination is consistent with the GALL Report Volume 2 for other RPV
 
internal components made from nickel-based alloy materials and acceptable.
Also in ALRA Table 3.1.2.B-2 the applicant identified cumulative fatigue damage as an aging effect applicable to the core shroud head bolts because of thermal cycling from heatup, cooldown, and other operating transient conditions of these components. The staff found this
 
identification acceptable because it meets the provisions in the SRP-LR Section 3.1 Revision 1
 
Report for assessing cumulative fatigue damage in RPV internal components. Refer to SER
 
Section 4.3 for the staff's assessment of plant components required to have thermal fatigue
 
analyses for license renewal.
3-228Aging Management Programs - In ALRA Table 3.1.2.B-2 the applicant credited the BWR Vessel Internals and the Water Chemistry Control Pr ograms with aging management of SCC/IGSCC of the core shroud head bolts. Even though GALL Report Volume 2 does not address an AMP for
 
such component, material, and environment combinations it does recommend crediting the
 
BWR Vessel Internals and Water Chemistry Programs with managing SCC and IGSCC for
 
stainless steel and nickel-alloy components (i.e., core shroud, core plate, core plate bolts, holddown beams, etc). Therefore, the staff found the applicant's proposal acceptable. The applicant's BWR Vessel Internals Program is an AMP entirely consistent with GALL AMP XI.M9.
 
The staff's evaluation of the BWR Vessel Internals Program is in SER Section 3.0.3.2.6. The
 
applicant's Water Chemistry Control Program is an AMP entirely consistent with GALL AMP XI.M2. The staff's evaluation of the Water C hemistry Program is in SER Section 3.0.3.2.2.
In ALRA Table 3.1.2.B-2 in ALRA Section 4.3 the applicant proposed using the TLAA for managing cumulative fatigue damage of the core shroud head bolts. This proposal is consistent
 
with the NUREG-1800 Revision 1 Report and is, therefore, acceptable. The staff's evaluation of
 
the applicant's TLAA on thermal fatigue of RPV internal components is in SER Section 4.3.
RPV Internals Core Shroud Support Structures (bolts, cap screws, and supports)
Identification of Aging Effects - In ALRA Table 3.1.2.B-2, the applicant identified SCC or IGSCC as an aging effect applicable to the core shroud support structures fabricated from carbon or
 
low alloy steels and nickel-based alloys that are exposed to treated water or steam, high
 
temperature with neutron fluences of < 5 x 10 20 n/cm 2 (E > 1.0 MeV).
The GALL Report Volume 2 does not identify SCC or IGSCC as an AERM for the RPV internals core shroud support structures. Industry experience has not indicated that carbon steel or low
 
alloy steel materials are susceptible to SCC or IGSCC but that stainless steel and nickel-based
 
alloy materials are. The applicant has identified conservatively SCC/IGSCC as an aging effect
 
applicable to the carbon steel/low alloy steel core shroud support structures (i.e., the core
 
shroud support cap screws). Therefore, the staff concludes that there is reasonable assurance
 
that the applicant's determination is conservative relative to the AMR Commodity Group line
 
items in the GALL Report Volume 2 for RPV in ternal components made from stainless steel.
The staff also concludes that the applicant's identification of SCC/IGSCC for the nickel-based core shroud support structures (i.e., the bolts and supports) is consistent with the AMR
 
Commodity Group line items in the GALL Report Volume 2 for RPV internal components made from nickel-based alloy materials and acceptable.
Also in ALRA Table 3.1.2.B-2, the applicant identified cumulative fatigue damage as an aging effect applicable to the core shroud support structures because of thermal cycling from heatup, cooldown, and other operating transient conditions of these components. The staff found this
 
identification acceptable because it meets the provisions in the SRP-LR Chapter 3.1 Revision 1
 
Report for assessing cumulative fatigue damage in RPV internal components. Refer to SER
 
Section 4.3 for the staff's assessment of plant components required to have thermal fatigue
 
analyses for license renewal.Aging Management Programs - In ALRA Table 3.1.2.B-2 the applicant credited the BWR Vessel Internals and Water Chemistry Control Program s with aging management of SCC/IGSCC of the core shroud support structures. Even though the GALL Report Volume 2 does not address an
 
AMP for such component, material, and environment combinations it does recommend crediting 3-229 the BWR Vessel Internals and Water Chemistry Programs with managing SCC and IGSCC for RPV internal components (i.e., core shroud, core plate, core plate bolts, holddown beams, etc).
 
Therefore, the staff found the applicant's proposal acceptable. The applicant's BWR Vessel
 
Internals Program is an AMP entirely consistent with GALL AMP XI.M9. The staff's evaluation of the BWR Vessel Internals Program is in SER Section 3.0.3.2.6. The applicant's Water
 
Chemistry Control Program is an AMP entirely consistent with GALL AMP XI.M2. The staff's evaluation of the Water Chemistry Control Program is in SER Section 3.0.3.2.2.
In ALRA Table 3.1.2.B-2 in ALRA Section 4.3 the applicant proposed using the TLAA for managing cumulative fatigue damage of the RPV internals core shroud support structures. This
 
proposal is consistent with the SRP-LR Revision 1 and, therefore, acceptable. The staff's
 
evaluation of the applicant's TLAA on thermal fatigue of RPV internal components is in SER
 
Section 4.3.
Conclusion. The staff reviewed the applicant's plant-specific AMRs for evaluating the RPV internals components exposed to the treated water (including steam) environments of temperatures >
482&deg;F, treated water or steam high temperature with neutron fluences of
< 5 x 10 20  n/cm 2 (E > 1.0 MeV), and treated water or steam high temperature with neutron fluences of >
1 x 10 17 n/cm 2 (E > 1.0 MeV) environments. For these AMRs the staff determined that the applicant has identified the aging effects applicable to components that are exposed to
 
these environments. The staff has also determined that the applicant credited either an
 
appropriate inspection-based AMP, an appropriate mitigation-based AMP, a TLAA, or
 
combination of these strategies with managing the aging effects applicable to the RPV internal
 
components exposed to these environments. The st aff's review concludes that the applicant has demonstrated that the aging effects of NMP2 RPV internals will be adequately managed so
 
that the intended functions will be maintained consistent with the CLB for the period of extended
 
operation as required by 10 CFR 54.21(a)(3).
3.1B.2.3.3  Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Vessel Instrumentation System - Summary of Agi ng Management Evaluation - ALRA Table 3.1.2.B-3 The NMP2 RPV instrumentation system monito rs and transmits information about key RPV operating parameters during normal and emergency operations. Instrumentation is installed to
 
monitor reactor parameters and indicate them on meters, chart recorders and hydraulic indicator units located in the control room, on remote shutdown panels, and in instrument rooms. The
 
parameters monitored are RPV temperature, water level and pressure, and core flow and core
 
plate differential pressure. This system also prov ides control signals to various systems which in turn initiate the appropriate actions required if the monitored parameter exceeds its desired set
 
point. Systems receiving control signals from the RPV instrumentation system include the reactor protection, primary containment isolation, automatic depressurization, feedwater control, reactor recirculation flow control, redundant reactivity control, and RHR (shutdown cooling
 
mode) systems. The RPV instrum entation system consists of piping, valves, and restricting orifices that provide a fluid path from the RPV to various instrumentation.
Summary of Technical Information in the Application. The applicant's plant-specific AMRs for the RPV instrumentation system components are in Table 3.1.2.B-3 of the ALRA. The specific
 
RPV components for NMP2 with AMR results not consistent with or addressed in the GALL
 
Report and within the scope of ALRA Table 3.1.2.B-3 include:
* RPV instrumentation system closure bolting 3-230
* RPV instrumentation system piping and fittings The applicant identified materials of fabrication for these RPV instrumentation components as martensitic, precipitation-hardenable, and superferritic stainless steels and carbon and low alloy
 
steels. The applicant identified applicable environments for these RPV instrumentation system
 
components as non-borated water systems with operating temperatures > 212 &deg;F and treated water or steam temperature > 482 &deg;F (high temperature) environments.
The applicant credited the Bolting Integrity Program with managing cracking, loss of material, and loss of preload of the RPV instrumentation system closure bolting. The applicant credited
 
the One-Time Inspection and the Water Chemistry Control Programs with managing loss of
 
material for the RPV instrumentation system piping and fittings.
Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-3, which summarizes the results of AMR evaluations for the NMP2 RPV instru mentation system components. The staff's assessment of the RPV instrumentation system components not consistent with or addressed in the GALL Report for NMP2 is provided here. It should be noted that the assessment for the
 
NMP2 RPV instrumentation system piping and fittings is in SER Section 3.1B.2.3.4. RPV Instrumentation System Closure Bolting Identification of Aging Effects - In ALRA Table 3.1.2.B-3 the applicant identified SCC or IGSCC, loss of material due to wear, and loss of preload due to thermal effects, gasket creep, and
 
self-loosening as aging effects applicable to RPV instrumentation system closure bolting
 
fabricated from martensitic, precipitation-hardenable, and superferritic stainless steels and
 
exposed to a non-borated water system with operating temperatures > 212 &deg;F environment (i.e., the reactor coolant or its steam environment).
The GALL Report Volume 2 does not identify these aging effects as applicable AERMs for these components; however, as these components are made from materials similar to those for the stainless steel RCPB closure bolting in high-pressure and high-temperature environments
 
identified in the GALL Report Volume 2; therefore, the staff concludes that there is reasonable
 
assurance that the applicant's determination is consistent with the AERMs identified in GALL
 
Report Volume 2 for RCPB closure bolting and found the applicant's determination acceptable.Aging Management Programs - In ALRA Table 3.1.2.B-3 the applicant credited the Bolting Integrity Program with aging management of SCC or IGSCC, loss of material due to wear, and
 
loss of preload due to thermal effects. Even though the GALL Report Volume 2 does not
 
address an AMP for such component, material, and environment combinations it does
 
recommend crediting the Bolting Integrity Program with managing SCC, loss of material due to
 
wear, loss of preload due to thermal effects, gasket creep, and self-loosening of stainless steel
 
RCPB pump and valve closure bolting in high-pressure and high-temperature systems.
Therefore, the staff finds the applicant's proposal acceptable. The applicant's Bolting Integrity Program is an AMP consistent with GALL AMP X I.M18 with exceptions. The staff's evaluation of the Bolting Integrity Program is in SER Section 3.0.3.2.23.
Conclusion. The staff reviewed the applicant's plant-specific AMRs for evaluating the RPV instrumentation system components exposed to non-borated water with operating temperatures
> 212 &deg;F and treated water or steam temperature > 482 &deg;F (high temperature) environments. For these AMRs the staff determined that the applicant has identified aging effects applicable to 3-231 these components exposed to these environments. The staff also determined that the applicant has credited either an appropriate inspection-based AMP, an appropriate mitigation-based
 
AMP, or combination of these strategies with managing aging effects applicable to the RPV
 
instrumentation system components exposed to these environments. The staff finds that the applicant has demonstrated that the aging effects associated with the NMP2 RPV
 
instrumentation system components will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation as required by
 
10 CFR 54.21(a)(3).
3.1B.2.3.4  Reactor Vessel, Internals, and Reactor Coolant System - NMP2 Reactor Recirculation System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.B-4 Summary of Technical Information in the Application. The description of the reactor recirculation system, recirculation flow control, and the control of the reactor recirculation pumps can be
 
found in ALRA Section 2.3.1.B.4. Reactor recirculation system components subject to AMR
 
include the entire main reactor recirculation flow path which begins at the suction nozzle and
 
ends at the discharge manifold nozzles to the jet pump risers of each recirculation loop for
 
NMP2. SR instrument piping and associated components connected to the recirculation loops
 
are also subject to AMR. The components requiring an AMR for the reactor recirculation system
 
and their intended functions are shown in ALRA Table 2.3.1.B.4-1. The AMR results for these
 
components are shown in ALRA Table 3.1.2.B-4. The following information pertains to the
 
reactor recirculation system provided in the ALRA which the staff has used in its evaluation.
The materials of construction are carbon or low alloy steel (yield strength < 100 Ksi and
> 100 Ksi), CASS, and wrought austenitic stainless steel including nickel-based alloys in piping
 
and fittings.
In ALRA Section 3.1.2.B.4 the applicant listed the following environments to which NMP2 reactor recirculation system components are exposed:
* air
* closure bolting for non-borated water systems with operating temperatures > 212 &deg;F
* hydraulic fluid
* treated water, temperature < 140 &deg;F
* treated water, temperature < 140 &deg;F, low flow
* treated water, temperature > 140 &deg;F, but < 212 &deg;F
* treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow
* treated water or steam, temperature > 482 &deg;F
* treated water or steam, temperature > 482 &deg;F, low flow The applicant identified the following aging effects associated with the NMP1 and NMP2 Reactor Recirculation System piping requiring management:
* cracking
* cumulative fatigue damage
* loss of fracture toughness 3-232
* loss of material
* loss of preload The following AMPs manage these aging effects in the NMP2 reactor recirculation system components:
* ASME Code Section XI (Subsections IWB, IWC, IWD) ISI Program
* Bolting Integrity Program
* BWR Stress Corrosion Cracking Program
* One-Time Inspection Program
* Water Chemistry Control Program Staff Evaluation. The applicant described its AMR for the reactor recirculation system in ALRA Section 3.1. The staff reviewed this section to determine whether the applicant had identified all
 
the applicable aging effects for components in these systems and demonstrated that the aging
 
effects on the components will be adequately managed during the period of extended operation
 
as required by 10 CFR 54.21(a)(3). The staff also reviewed the USAR supplements for the
 
AMPs to ensure that the program descriptions adequately describe the AMPs.
The applicant identified the following aging effects for the reactor recirculation system:
* cracking
* cumulative fatigue damage
* loss of fracture toughness
* loss of material
* loss of preload In ALRA Table 3.1.2.B-4 the applicant identified cracking and cumulative fatigue damage as aging effects applicable to the recirculation system closure bolting, piping and fittings, recirculation pumps, and valves. Cumulative fatigue damage is evaluated in SER Section 4.3, "Metal Fatigue Analysis." The aging effect of loss of fracture toughness is associated with the
 
pressure boundary materials in reactor recirculation pumps and in CASS valves operating at or above 480 &deg;F. The loss of material has been identified as an aging effect in carbon or low alloy steel or austenitic stainless steel with treated water environment operating below 140 &deg;F for
 
such components as piping and fittings, valves, and restriction orifices in the reactor
 
recirculation system. The loss of preload is identified as the applicable aging effect in closure bolting for non-borated water system operating at or above 212 &deg;F. The staff noted that this
 
assessment is consistent with the GALL Report.
The applicant identified cracking as an aging effect applicable to the recirculation system austenitic stainless steel components (piping and fittings, tubing, valve bodies, flow elements, thermowells, restricting orifices) and to the high-strength low-alloy steel primary pressure
 
closure bolting exposed to reactor coolant water. The applicant also identified this aging effect
 
for CASS components exposed to reactor coolant water. The applicant identified crack initiation
 
and growth due to thermal and mechanical loading as an aging effect applicable to small-bore
 
stainless steel piping and fittings and low-alloy steel pressure boundary closure bolting in the
 
reactor recirculation system. The staff noted that this assessment is consistent with the GALL
 
Report. The staff requested confirmation that the applicant had no flaws evaluated according to IWB-3600 "Analytical Evaluation of Flaws" under the ISI program of ASME Code, Section XI as
 
such an evaluation would require a TLAA under the regulation. The applicant's response 3-233 indicated that the NMP2 Reactor Recirculation System has no weld evaluated according to IWB-3600.
The applicant stated under item number 3.1.1.B-07 in ALRA Table 3.1.1.B that for the small-bore reactor coolant system and connect ed systems piping a plant-specific destructive examination or an NDE of the inside surfaces of the piping will be conducted as part of a
 
one-time inspection to verify that service-induced weld cracking is not occurring in the
 
small-bore piping. The applicant's One-Time Inspection AMP is described in ALRA Section B.2.1.20 and the applicant stated that it is consistent with GALL Report Chapter XI.M32, "One-Time Inspection."
In ALRA Table 3.1.2.B-1 the applicant identified cumulative fatigue damage and cracking as AERMs applicable to the vessel drain line. The applicant uses TLAA to manage cumulative
 
fatigue damage and the BWR Penetration Program and Water Chemistry Control Program to
 
manage cracking. Because of the size of the drain line volumetric examination is not required by ASME Code Section XI. In response to the staff's request for information about the adequacy of
 
the AMP applicable to the reactor vessel drain line which is not volumetrically examined the applicant stated that the ASME Code Section XI pressure test is performed every refueling
 
outage. As a function of the pressure test a concurrent VT-2 examination is performed
 
according to acceptance standards stated in Subsection IWB-3522. Any source of leakage
 
detected during this examination must be located and evaluated according to Subsection
 
IWA-5250 prior to return of the system to service. One source of leakage could be from
 
through-wall pitting or crevice corrosion as the applicable loss of material mechanism for
 
stainless steel piping and components. Also performed under the ISI program according to the
 
Subsection IWB-3517 acceptance standards is a VT-1 examination of all reactor vessel drain
 
line bolting, studs, and nuts at every inspection interval. The staff considers the reactor vessel
 
drain line AMPs effective for the period of extended operation.
The staff, however, requested, during the audit, that the applicant submit information about its plant-specific experience related to IGSCC of the reactor coolant pressure boundary piping, mitigative actions taken, and revised inspection schedules following the BWRVIP-75A
 
guidelines. The staff requested that the applicant provide information about its implementation
 
of HWC and NMCA at NMP2 and how implementation has affected monitoring of water
 
chemistry parameters. In response the applicant stated that there have been two indications of
 
potential IGSCC at NMP2. A mechanical stress im provement process was applied to one of the welds to improve the residual stress distribution in the region of the flaw to eliminate the
 
potential for flaw growth. The weld has been classified as a GL 88-01 Category E weld and will
 
be inspected once every six years. The second indication was repaired by weld overlay. The
 
scope and the schedule of inspection for IGSCC are according to GL 88-01 as modified by
 
BWRVIP-75A. The current inspection schedule except for Category A welds subsumed in the
 
alternate Risk-Informed ISI Program is according to the revised inspection frequency allowed by
 
BWRVIP-75A for normal water chemistry. With respect to implementation of HWC and NMCA
 
NMP2 treated the reactor vessel internals with noble metal chemicals in September 2000 and
 
began injecting hydrogen into reactor water in January 2001. Under HWC versus normal water
 
chemistry the electrochemical potential is monitored with a goal of < -0.23V SHE for the
 
effectiveness of HWC. For NMP2 the significant change in water chemistry control when HWC
 
is in operation is the addition of hydrogen-to-oxygen molar ratio monitoring as an indirect means
 
of determining the electrochemical potential.
3-234 The staff's review concludes that the applicant had identified appropriate aging effects for the components in the NMP2 reactor recirculation system.
Conclusion. The staff concludes that the applicant had identified adequately the aging effects and the AMPs credited for managing them for the reactor recirculation system and that the
 
components' intended functions 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 applicable
 
USAR supplement program descriptions and c oncludes that the USAR supplement adequately describes the AMPs credited for managing aging in the reactor coolant system - recirculation
 
system as required by 10 CFR 54.21(d).
3.1B.2.3.5  Reactor Vessel, Internals, and Reac tor Coolant System - NMP2 Control Rod Drive System - Summary of Aging Management Evaluation - ALRA Table 3.1.2.B-5 The NMP2 CRD system is designed to change core reactivity by changing the position of control rods within the reactor core in response to manual control signals and to scram the
 
reactor in response to manual or automatic si gnals. The system also provides water to the nuclear boiler instrumentation system reference leg backfill injection lines and the reactor water
 
cleanup and reactor recirculation pump seals.
Summary of Technical Information in the Application. The applicant's plant-specific AMRs for the CRD system components are in ALRA Table 3.1.2.B-5. The specific NMP2 CRD system
 
components with AMR results not consistent with or addressed in the GALL Report and within
 
the scope of ALRA Table 3.1.2.B-5 include:
* CRD system accumulators
* CRD hydraulic control units
* CRD system piping and fittings
* CRD system valves The applicant identified materials of fabrication for these CRD system components as including carbon and low alloy steels. The applicant identified applicable environments for these CRD
 
system components as treated water or steam, temperature > 212 &deg;F < 482 &deg;F, low flow environments (i.e., the reactor cool ant or its steam environment).
The applicant credited the One-Time Inspection and Water Chemistry Control Programs with managing loss of material for the CRD system accumulators, hydraulic control units, and valves.
 
The applicant also credited the One-Time Inspection Program and the Water Chemistry Control
 
Program with managing cracking of the CRD system piping and fittings.
Staff Evaluation. The staff reviewed ALRA Table 3.1.2.B-5, which summarizes the results of AMR evaluations for the NMP2 CRD system components. The staff's assessment of the CRD system components not consistent with or addre ssed in the GALL Report for NMP2 is provided here. It should be noted that the assessments for the NMP2 CRD system piping and fittings and
 
CRD system valves are in SER Section 3.0.3.CRD System Accumulators and Hydraulic Control Units Identification of Aging Effects - In ALRA Table 3.1.2.B-5 the applicant identified loss of material due to general, pitting, and crevice corrosion as an aging effect applicable to the CRD system 3-235 accumulators and the CRD hydraulic control units fabricated from carbon or low alloy steel and exposed to an environment of treated water or steam, temperature > 212 &deg;F < 482 &deg;F, low flow environments. These components are made from materials and exposed to environments similar to those for the steel and stainless steel isolation condenser components exposed to
 
reactor coolant as identified in the SRP-LR Revision 1.
The applicant identified loss of material due to crevice, general, and pitting corrosion as aging effects in carbon and low alloy steel when these materials are exposed to the reactor coolant or
 
its steam environment. The staff found the applicant's determination acceptable.Aging Management Programs - In ALRA Table 3.1.2.B-5 the applicant credited the One-Time Inspection and Water Chemistry Control Programs with aging management of loss of material
 
due to general, pitting, and crevice corrosion for the CRD system accumulators and the CRD
 
hydraulic control units. The SRP-LR Revision 1 does not address an AMP for these component, material, and environment combinations; however, the SRP-LR Revision 1 does address the
 
AMPs (One-Time Inspection Program and the Water Chemistry Control Program) for this material and environment combination consistent with programs that the applicant identified with
 
managing loss of material due to general, pitting, and crevice corrosion. Therefore, the staff
 
found the applicant's proposal acceptable. The applicant's One-Time Inspection Program is a new AMP consistent with GALL AMP XI.M32. The staff's evaluation of the One-Time Inspection
 
Program is in SER Section 3.0.3.1.4. The applicant's Water Chemistry Control Program is an AMP consistent with GALL AMP XI.M2. The staff's evaluation of the Water Chemistry Program
 
is in Section 3.0.3.2.2.
Conclusion. The staff reviewed the applicant's plant-specific AMRs for evaluating the CRD system components exposed to the treat ed water or steam, temperature > 212 &deg;F < 482 &deg;F, low flow environments. For these AMRs the staff determined that the applicant had identified the
 
aging effects applicable for components that are exposed to these environments. The staff also
 
determined that the applicant had credited either an appropriate inspection-based AMP, an
 
appropriate mitigation-based AMP, or combination of these strategies with managing the aging
 
effects applicable to the CRD system components that are exposed to these environments. The staff's review concludes that the applicant had demonstrated that the aging effects of the NMP2
 
CRD system components will be adequately managed so that the intended functions will be
 
maintained consistent with the CLB for the period of extended operation as required by
 
10 CFR 54.21(a)(3).
3.1B.3  Conclusion The staff concludes that there is reasonable assurance that the applicant provided sufficient information to demonstrate that the effects of aging for the NMP2 reactor vessel, internals, and
 
reactor coolant systems components within the scope of license renewal and subject to an AMR will be adequately managed so that the intended functions 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 applicable USAR supplement program summaries and concludes that they adequately describe the AMPs credited for managing aging of the reactor vessel, internals, and reactor coolant systems, as required by 10 CFR 54.21(d).3.2  Aging Management of Engineered Safety Features 3-2363.2A  NMP1 Aging Management of Engineered Safety Features This section of the SER documents the staff's review of the applicant's AMR results for the engineered safety features (ESF) systems components and component groups associated with the following systems:
* containment spray system
* core spray system
* emergency cooling system3.2A.1  Summary of Technical Information in the Amended Application In ALRA Section 3.2, the applicant provided AMR results for the ESF systems components and component groups. In ALRA Table 3.2.1.A, "NMP1 Summary of Aging Management Programs
 
for the Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801," the
 
applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL Report for the ESF systems components and component groups.
The applicant's AMRs incorporated applicable operating experience in the determination of AERMs. These reviews included evaluation of plant-specific and industry operating experience.
 
The plant-specific evaluation included reviews of condition reports and discussions with
 
appropriate site personnel to identify AERMs. The applicant's review of industry operating
 
experience included a review of the GALL Report and operating experience issues identified
 
since the issuance of the GALL Report.
3.2A.2  Staff Evaluation The staff reviewed ALRA Section 3.2 to determine if the applicant provided sufficient information to demonstrate that the effects of aging for the ESF systems components that are within the
 
scope of license renewal and subject to an AMR will be adequately managed so that the
 
intended functions will be maintained consistent with the CLB for the period of extended
 
operation, as required by 10 CFR 54.21(a)(3).
The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain identified 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 ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.
 
The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's
 
audit evaluation are documented in the Audit and Review Report and are summarized in SER
 
Section 3.2A.2.1.
In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicant's further
 
evaluations were consistent with the acceptance criteria of SRP-LR Section 3.2.2.2. The staff's
 
audit evaluations are documented in the Audit and Review Report and are summarized in SER
 
Section 3.2A.2.2.
In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were not consistent with, or not addressed in, the GALL Report. The audit and technical review
 
included evaluating whether all plausible aging effects were identified and evaluating whether 3-237 the aging effects listed were appropriate for the combination of materials and environments specified. The staff's audit evaluations are documented in the Audit and Review Report and are
 
summarized in SER Section 3.2A.2.3. The staff's evaluation of its technical review is also
 
documented in SER Section 3.2A.2.3.
Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure that they provided an adequate description of the programs credited with managing or
 
monitoring aging for the ESF systems components.
Table 3.2A-1 below provides a summary of t he staff's evaluation of NMP1 components, aging effects/mechanisms, and AMPs listed in ALRA Section 3.2, that are addressed in the GALL
 
Report.Table 3.2A-1  Staff Evaluation for NMP1 Engineered Safety Features Systems Components in the GALL ReportComponent GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation Piping, fittings, and valves in emergency core cooling system (Item Number
 
3.2.1.A-01)
Cumulative fatigue damageTLAA, evaluated inaccordance with 10 CFR 54.21(c)TLAAThis TLAA is evaluated in
 
Section 4.3, Metal Fatigue Analysis Piping, fittings, pumps, and valves in emergency core cooling system (Item Number
 
3.2.1.A-02)
Loss of material due to general corrosion Water chemistry and one-time
 
inspection Water Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2A.2.2.2)
Components in containment spray (PWR only),
standby gas treatment (BWR only), containment
 
isolation, and emergency core cooling systems (Item Number
 
3.2.1.A-03)
Loss of material due to general corrosionPlant-specificOpen-Cycle CoolingWater System
 
Program (B2.1.10),
One-Time Inspection Program (B2.1.20),
Preventive
 
Maintenance
 
Program (B2.1.32)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2A.2.2.2)
Piping, fittings, pumps, and valves in emergency core cooling system (Item Number
 
3.2.1.A-04)
Loss of material due to pitting and
 
crevice corrosion Water chemistry and one-time
 
inspection Water Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2A.2.2.3)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-238 Components in containment spray (PWR only),
standby gas treatment (BWR only), containment
 
isolation, and emergency core cooling systems (Item Number
 
3.2.1.A-05)
Loss of material due to pitting and
 
crevice corrosionPlant-specificOpen-Cycle CoolingWater System
 
Program (B2.1.10),
One-Time Inspection Program (B2.1.20),
Preventive
 
Maintenance
 
Program (B2.1.32)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2A.2.2.3)
Containment isolation valves and
 
associated piping (Item Number
 
3.2.1.A-06)
Loss of material due to MICPlant-specificNoneNot applicable (See Section 3.2A.2.2.4)
Seals in standby gas treatment system (Item Number
 
3.2.1.A-07)
Changes in properties due to
 
elastomer degradationPlant-specificPreventive Maintenance
 
Program (B2.1.32),
Systems Walkdown
 
Program (B2.1.33)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2A.2.2.5)
High pressuresafety injection (charging) pump miniflow orifice (Item Number
 
3.2.1.A-08)
Loss of material due to erosionPlant specificNoneNot applicable,PWR onlyDrywell and suppression
 
chamber spray system nozzles and flow orifices (Item Number
 
3.2.1.A-09)
Plugging of flow orifice and spray nozzles by general
 
corrosion productsPlant specificNoneNot applicable (See Section 3.2A.2.2.7)
External surface of carbon steel
 
components (Item Number
 
3.2.1.A-10)
Loss of material due to general corrosionPlant specificSystems Walkdown Program (B2.1.33)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2A.2.2.2)
Piping and fittings of CASS in emergency core cooling system (Item Number
 
3.2.1.A-11)
Loss of fracture toughness due to
 
thermal aging
 
embrittlementThermal aging embrittlement of
 
CASSNoneNot applicableThere are no CASS piping and fittings with this aging
 
effect/ mechanism
 
in NMP1 ESF system Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-239 Components serviced by open-cycle cooling system (Item Number
 
3.2.1.A-12)
Loss of material due to general, pitting, and crevice
 
corrosion, MIC, and
 
biofouling; buildup
 
of deposit due to
 
biofoulingOpen-cycle coolingwater systemNoneNot applicable Heat exchangershas own open-cycle cooling system Components serviced by closed-cycle cooling system (Item Number
 
3.2.1.A-13)
Loss of material due to general, pitting, and crevice
 
corrosionClosed-cyclecooling water systemNoneNot applicable No components serviced by closed-cycle cooling water systemEmergency corecooling system
 
valves and lines to
 
and from HPCI and
 
RCIC pump turbines (Item Number
 
3.2.1.A-14)Wall thinning due toflow-accelerated
 
corrosionFlow-accelerated corrosionFlow-Accelerated Corrosion Program (B2.1.9)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.2A.2.1)Not applicable for HPCI lines and
 
RCIC pump turbines Pumps, valves, piping, and fittings
 
in containment spray and emergency core cooling systems (Item Number
 
3.2.1.A-15)
Crack initiation andgrowth due to SCCWater chemistryNoneNot applicable,PWR only Pumps, valves, piping, and fittings in emergency core cooling systems (Item Number
 
3.2.1.A-16)
Crack initiation andgrowth due to SCC
 
and IGSCC Water chemistryand BWR stress
 
corrosion cracking Water Chemistry Control Program (B2.1.2), BWR
 
Stress Corrosion
 
Cracking Program (B2.1.6), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.2A.2.1.1)
Carbon steel components (Item Number
 
3.2.1.A-17)
Loss of material due to boric acid
 
corrosionBoric acid corrosionNoneNot applicable,PWR only Closure bolting in high pressure or
 
high temperature systems (Item Number
 
3.2.1.A-18)
Loss of material due to general
 
corrosion; crack initiation and growth due to cyclic loading
 
and/or SCCBolting integrityB olting Integrity Program (B2.1.36)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.2A.2.1) 3-240 The staff's review of the NMP1 component groups followed one of several approaches. One approach, documented in SER Section 3.2A.2.1, discusses the staff's review of the AMR results
 
for components in the ESF systems that the applicant indicated are consistent with the GALL
 
Report and do not require further evaluation. Another approach, documented in SER
 
Section 3.2A.2.2, discusses the staff's review of the AMR results for components in the ESF
 
systems that the applicant indicated are consistent with the GALL Report and for which further
 
evaluation is recommended. A third approach, documented in SER Section 3.2A.2.3, discusses
 
the staff's review of the AMR results for components in the ESF systems that the applicant
 
indicated are not consistent with, or not addressed in, the GALL Report. The staff's review of
 
AMPs that are credited to manage or monitor aging effects of the ESF systems components is documented in SER Section 3.0.3.3.2A.2.1  AMR Results That Are Consistent with the GALL Report Summary of Technical Information in the Amended Application. In ALRA Section 3.2.2.A, the applicant identified the materials, environments, and AERMs. The applicant identified the
 
following programs that manage the aging effect s related to the ESF systems components:
* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Water Chemistry Control Program
* BWR Stress Corrosion Cracking Program
* Open-Cycle Cooling Water System Program
* One-Time Inspection Program
* Selective Leaching of Materials Program
* Preventive Maintenance Program
* Systems Walkdown Program
* Bolting Integrity Program Staff Evaluation. In ALRA Tables 3.2.2.A-1 through 3.2.2.A-3, the applicant provided a summary of AMRs for the ESF systems components, and identified which AMRs it considered to be
 
consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report does not recommend further
 
evaluation, the staff performed an audit and review to determine whether the plant-specific
 
components contained in these GALL Report component groups were bounded by the GALL
 
Report evaluation.
The applicant provided a note for each AMR line item. The notes indicate how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with
 
Notes A through E, which indicate that 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report and the 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the 3-241 GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff also determined whether the AMP identified by the
 
applicant was consistent with the AMP identified in the GALL Report 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 AMP identified by the GALL Report. This note indicates that the applicant
 
was unable to find a listing of some system components in the GALL Report. However, the
 
applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was 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 AMP identified in the GALL Report. 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. The staff verified whether
 
the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The
 
staff also determined whether the AMP identified by the applicant was consistent with the AMP
 
identified in the GALL Report 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 a different AMP is credited. The staff audited these line items
 
to verify consistency with the GALL Report. The staff also determined whether the identified
 
AMP would manage the aging effect consistent with the AMP identified by the GALL Report and
 
whether the AMR was valid for the site-specific conditions.
The staff conducted an audit and review of the information provided in the ALRA, as documented in the Audit and Review 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
 
ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The
 
staff's evaluation is discussed below.
3.2A.2.1.1  Crack Initiation and Growth Due to SCC and IGSCC
 
In the discussion section of ALRA Table 3.2.1.A Item 3.2.1.A-16 the applicant stated that for small-bore valves and piping the One-Time In spection Program is used to manage this aging effect and aging effect mechanism. The GALL Report suggests using the BWR Stress
 
Corrosion Cracking Program and Water Chemistry Control Program for managing SCC and
 
IGSCC in pumps, valves, piping, and fitti ngs in emergency core cooling systems.
As documented in the Audit and Review Report, the staff noted that for ALRA Table 3.2.2.A-3 line item component type piping and fittings, material type wrought austenitic stainless steel, aging effect cracking, and the One-Time Inspection Program it was not clear whether these
 
components also are age-managed by the applicant's Water Chemistry Control and BWR
 
Stress Corrosion Cracking Programs. It was also not clear to which components the applicant's 3-242 One-Time Inspection Program applied within this component type grouping. The staff requested the applicant to clarify this line item.
In its letter dated December 1, 2005, the applicant stated that for the components in the subject line item the BWR Stress Corrosion Cracking Program was not credited because this line item is
 
for small bore piping. Piping and fittings in the emergency condenser system age- managed by the applicant's One-Time Inspection Program, are not included in its BWR Stress Corrosion
 
Cracking Program either because they are sma ll bore piping (< 4 inches nominal diameter), they are in a low temperature environment, or t hey are not made from austenitic stainless steel material. However, the applicant's Water Chemistry Control Program in addition to its One-Time
 
Inspection Program should have been credited for this line item. The subject line item was
 
revised to credit the applicant's Water Chemistry Control Program in addition to its One-Time
 
Inspection Program for managing cracking for this component group. Note 10 was also added to
 
the "Notes" column.
The staff reviewed the applicant's response and determined that after revision of the applicant's AMR line item as described the use of its Wate r Chemistry Control Program to manage cracking is consistent with the GALL Report. Because the line item component is small bore piping and
 
fittings the applicant's BWR Stress Corrosion Cracking Program is not applicable and its
 
One-Time Inspection Program is an adequate alternative.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicant's consideration of recent operating
 
experience and proposals for managing associated aging effects. On the basis of its review, the
 
staff concludes that there is reasonable assurance that the AMR results, which the applicant
 
claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL
 
Report. 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 for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).3.2A.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended Summary of Technical Information in the Amended Application. In Section 3.2.2.C of the letter dated August 19, 2005, the applicant provided further evaluation of aging management as
 
recommended by the GALL Report for the ESF systems components. The applicant provided information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* loss of material due to general corrosion
* local loss of material due to pitting and crevice corrosion
* local loss of material due to MIC
* changes in properties due to elastomer degradation
* local loss of material due to erosion
* buildup of deposits due to corrosion 3-243 Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends
 
further evaluation, the staff audited and reviewed the applicant's evaluation to determine
 
whether it adequately addressed the issues that were further evaluated. In addition, the staff
 
reviewed the applicant's further evaluations against the criteria contained in SRP-LR
 
Section 3.2.2.2. Details of the staff's audit are documented in the staff's Audit and Review
 
Report. The staff's evaluation of the aging effects is discussed in the following sections.
3.2A.2.2.1  Cumulative Fatigue Damage
 
In Section 3.2.2.C.1 of the letter dated August 19, 2005, the applicant stated that fatigue is a TLAA as defined in 10 CFR 54.3. Applicants must evaluate TLAAs according to
 
10 CFR 54.21(c)(1). SER Section 4.3 documents the staff's review of the applicant's evaluation
 
of this TLAA.
3.2A.2.2.2  Loss of Material due to General Corrosion
 
The staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.2.1.
In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant addressed loss of material at locations with stagnant flow conditions due to general corrosion of pumps, valves, piping, and
 
fittings associated with some of the BWR emergency core cooling systems and with lines to the
 
suppression chamber and to the drywell and suppression chamber spray system.
SRP-LR Section 3.2.2.2.2.1 states that the management of loss of material due to general corrosion of pumps, valves, piping, and fittings associated with some of the BWR emergency
 
core cooling systems and with lines to the suppression chamber and to the drywell and
 
suppression chamber spray system should be evaluated further. The AMP relies on monitoring and control of primary water chemistry based on EPRI guidelines to mitigate degradation.
 
However, control of primary water chemistry does not prevent loss of material due to general
 
corrosion at locations of stagnant flow conditions. Therefore, the effectiveness of the applicant's
 
Chemistry Control 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 corrosion to verify the effectiveness of the applicant's Water Chemistry Control
 
Program. A one-time inspection of select components at susceptible locations is an acceptable
 
method to determine whether an aging effect and aging effect mechanism does not occur or
 
progresses very slowly so the component's intended function will be maintained during the
 
period of extended operation.
In its letter dated August 19, 2005, the applicant stated that for NMP1 the containment spray, core spray, emergency cooling, and main steam (for automatic depressurization) systems are
 
applicable. The aging effect and aging effect mechanism are managed by the combination of
 
the Water Chemistry Control Program and One-Time Inspection Program.
The staff reviewed the applicant's Water Chemistry Control and One-Time Inspection Programs and its evaluations are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
3-244 The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
In addition the staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.2.2.
In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant also addressed loss of material due to general corrosion of components in the standby gas treatment, containment
 
isolation, and emergency core cooling systems.
SRP-LR Section 3.2.2.2.2.2 also states that loss of material due to general corrosion could occur in the drywell and suppression chamber spray systems header and spray nozzle
 
components, standby gas treatment system co mponents, containment isolation valves and associated piping, the automatic depressurization system piping and fittings, emergency core
 
cooling system header piping and fittings and spray nozzles, and the external surfaces of
 
carbon steel components. The GALL Report recommends further plant-specific evaluation to
 
ensure adequate aging effect and aging effect mechanism management.
In its letter dated August 19, 2005, the applicant also stated that for NMP1 the applicable systems are the containment spray, core spray, emergency cooling, reactor building ventilation (for standby gas treatment), and main steam (for automatic pressurization) systems. The aging effect and aging effect mechanism for internal surfaces is managed by the One-Time
 
Inspection, Preventive Maintenance, or Open-Cycle Cooling Water System Programs. The aging effect and aging effect mechanism for external surfaces of carbon steel components in
 
the emergency core cooling system is managed by the Systems Walkdown Program.
The staff review and evaluations of the applicant's One-Time Inspection, Preventive Maintenance, Open-Cycle Cooling Water Sy stem, and Systems Walkdown Programs are documented in SER Sections 3.0.3.1.4, 3.0.3.3.1, 3.0.3.2.7, and 3.0.3.3.2, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.2.2.2.2. For those line items that
 
apply to Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.2A.2.2.3  Local Loss of Material Due to Pitting and Crevice Corrosion
 
The staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.3.1.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of material at locations with stagnant flow conditions due to pitting and crevice corrosion of pumps, valves, piping, and fittings associated with some of the BWR emergency core cooling systems and with
 
lines to the suppression chamber and to the drywell and suppression chamber spray system.
3-245 SRP-LR Section 3.2.2.2.3.1 states that the management of local loss of material due to pitting and crevice corrosion of pumps, valves, piping, and fittings associated with some of the BWR
 
emergency core cooling system piping and fittings and with lines to the suppression chamber
 
and to the drywell and suppression chamber spray system should be evaluated further. The
 
AMP relies on monitoring and control of primary water chemistry based on EPRI guidelines to
 
mitigate degradation. However, control of coolant water chemistry does not prevent loss of
 
material due to crevice and pitting corrosion at locations of stagnant flow conditions. Therefore, the effectiveness of the applicant's Water Chemistry Control Program should be verified to
 
ensure that corrosion does not occur. The GALL Report recommends further evaluation of
 
programs to manage the loss of material due to pitting and crevice corrosion to verify the
 
effectiveness of the applicant's Water Chemistry Control Program.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the containment spray, core spray, and emergency cooling systems are applicable for NMP1. The
 
aging effect and aging effect mechanism are managed by a combination of the Water Chemistry
 
Control Program and One-Time Inspection Program.
The staff's review and evaluations of the applicant's Water Chemistry Control and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
In addition the staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.3.2.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant also addressed loss of material due to pitting and crevice corrosion of components in the standby gas treatment, containment isolation, and emergency core cooling systems.
SRP-LR Section 3.2.2.2.3.2 states that local loss of material due to pitting and crevice corrosion could occur in the containment isolation valves and associated piping and automatic
 
depressurization system piping and fittings. The GALL Report recommends further evaluation to
 
ensure adequate aging effect and aging effect mechanism management.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the containment spray, core spray, emergency cooling, and main steam (for automatic
 
depressurization) systems are applicable for NMP1. The aging effect and aging effect
 
mechanism are managed by the One-Time Ins pection Program, the Preventive Maintenance Program, or the Open-Cycle C ooling Water System Program.
The staff's review and evaluations of the applicant's One-Time Inspection, Preventive Maintenance, and Open-Cycle Cooling Wate r System Programs are documented in SER Sections 3.0.3.1.4, 3.0.3.3.1 and 3.0.3.2.7, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.2.2.2.3. For those line items that 3-246 apply to Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, the staff determined that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.2A.2.2.4  Local Loss of Material Due to Microbiologically Influenced Corrosion
 
The staff reviewed Section 3.2.2.C.4 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.4.
The applicant stated in Section 3.2.2.C.4 of its letter dated August 19, 2005, that the aging effect and aging effect mechanism of local loss of material due to microbiologically influenced
 
corrosion (MIC) in containment isolation valves and associated piping is not applicable to NMP.
 
The applicant considers MIC an aging effect and aging effect mechanism for systems with raw
 
water as an environment. NMP1 has no raw water environment for containment isolation valves or the associated piping. Therefore, this issue is not applicable. As documented in the Audit and
 
Review Report, the staff determined through discussions with the applicant's technical
 
personnel that the local loss of material due to MIC in containment isolation valves and
 
associated piping is not applicable to NMP1.
Because NMP1 has no containment isolation valves subject to this aging effect and aging effect mechanism the staff determined that it is not applicable to NMP1.
3.2A.2.2.5  Changes in Properties Due to Elastomer Degradation
 
The staff reviewed Section 3.2.2.C.5 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.5.
In Section 3.2.2.C.5 of its letter dated August 19, 2005, the applicant addressed change in material properties of seals in the standby gas treatment system.
SRP-LR Section 3.2.2.2.5 states that changes in properties due to elastomer degradation could occur in seals associated with the standby gas treatment system ductwork and filters. The GALL Report recommends further evaluation to ensure adequate aging effect and aging effect
 
mechanism management.
In the ALRA, the applicant also stated the NMP1 reactor building ventilation system provides the equivalent function of a standby gas treatment syst em. For the internal surfaces of the system's seals (grouped with blowers) aging effect s/mechanisms are managed by the Preventive Maintenance Program. For external surfaces the aging effects/mechanisms are managed by the Systems Walkdown Program. The staff's review and evaluations of the applicant's Preventive Maintenance and Systems Walkdown Programs are documented in SER Sections 3.0.3.3.1 and 3.0.3.3.2.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.2.2.2.5. For those line items that 3-247 apply to Section 3.2.2.C.5 of the applicant's letter dated August 19, 2005, the staff determined that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.2A.2.2.6  Local Loss of Material Due to Erosion
 
The staff reviewed Section 3.2.2.C.6 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.6.
In Section 3.2.2.C.6 of its letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
Because NMP is a BWR the staff found this aging effect and aging effect mechanism not applicable to NMP.
3.2A.2.2.7  Buildup of Deposits Due to Corrosion
 
The staff reviewed Section 3.2.2.C.7 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.7.
In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant addressed the plugging of components due to general corrosion in the spray nozzles and flow orifices of the drywell and
 
suppression chamber spray system.
SRP-LR Section 3.2.2.2.7 states that the plugging of components due to general corrosion could occur in the spray nozzles and flow orifices of the drywell and suppression chamber spray
 
system. This aging effect and aging effect mechanism applies since the spray nozzles and flow
 
orifices are wetted occasionally even though most of the time this system is on standby. The wetting and drying of these components can aid in the acceleration of this particular corrosion.
 
The GALL Report recommends further evaluation to ensure adequate aging effect and aging
 
effect mechanism management.
In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant stated that the NMP1 containment spray system contains the subject spray nozzles and flow orifices. Plugging of
 
spray nozzles due to general corrosion is not an applicable aging effect and aging effect
 
mechanism as these components are stainless steel and not susceptible to general corrosion.
 
The plugging of flow orifices due to general corrosion is not an applicable aging effect and aging
 
effect mechanism because the lines containing these components are drained completely
 
following each system operation in which they are wetted. The draining ensures that no
 
corrosion products accumulate in the flow orifices. The flow orifices are located in the
 
containment spray heat exchanger drain lines such that plugging would not be impact the
 
intended safety function adversely.
The staff found that general corrosion of stainless steel spray nozzles is not an effect/
mechanism requiring aging management. As documented in the Audit and Review Report, the
 
staff determined through discussions with the applicant's technical personnel that plugging of
 
orifices has no adverse impact upon the intended function of the system.
3-248 3.2A.2.2.8  Quality Assurance for Aging Management of Nonsafety-Related Components SER Section 3.0.4 provides the staff's evaluation of the applicant's quality assurance program.
 
Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL
 
Report recommends further evaluation, the staff determined that the applicant adequately
 
addressed the issues that were further evaluated. The staff found that the applicant had
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).3.2A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report Summary of Technical Information in the Amended Application. In ALRA Tables 3.2.2.A-1 through 3.2.2.A-3, the staff reviewed additional details of the results of the AMRs for material, environment, AERM, and AMP combinations that are not consistent with the GALL Report, or
 
that are not addressed in the GALL Report.
In ALRA Tables 3.2.2.A-1 through 3.2.2.A-3, 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, and provided inform ation concerning how the aging effect will be managed. 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, materi al, 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.
Staff Evaluation. For component type, material, and environment combinations that are not evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine
 
whether the applicant had 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. The staff's evaluation is discussed in the following sections.
3.2A.2.3.1  Engineered Safety Features System s NMP1 Containment Spray System - Summary of Aging Management Evaluation - ALRA Table 3.2.2.A-1 The staff reviewed ALRA Table 3.2.2.A-1, which summarizes the results of AMR evaluations for the containment spray system component groups.
The staff reviewed the following original LRA Table 3.2.2.A-1 line items for the NMP1 Containment Spray System.
* Wrought stainless steel bolting in an air environment where the applicant identified no aging effect.
3-249
* Loss of material of gray cast iron ex ternal surfaces in an air environment is managed by the Systems Walkdown Program. The applicant stat ed that this line item is for external surfaces of carbon steel components not in the GALL Report (Note F, 4).
* Loss of material for carbon or low alloy steel (yield strength < 100 ksi) filters/strainers in a demineralized untreated water low flow environment is managed by the One-Time Inspection and Water Chemistry Control Programs. The applicant stated that this aging
 
effect is not in the GALL Report for this component, material, and environment (Note H).
* Loss of material as an aging effect for gray cast iron pumps in a treated water, temperature < 140 &deg;F, low flow environment is managed by the One-Time Inspection, Water Chemistry Control, and Selective Leaching of Materials Programs. The applicant
 
stated that this aging effect is not in the GALL Report for this component, material, and
 
environment (Note H).
As to the evaluation of no aging effects for wrought stainless steel bolting in an air environment, the staff requested the applicant, in RAI 3.2-1 dated November 17, 2004, to discuss how
 
cracking and loss of pre-load resulting in loss of mechanical closure integrity are managed for
 
these bolts. In addition, the staff requested that the applicant address how the aging effects are
 
managed for inaccessible bolts.
In its response dated December 21, 2004, and as amended (ALRA) by attachment 1 to NMP1L-1960 letter dated July 14, 2005, the applicant stated:
The wrought austenitic stainless steel bolting in an air environment in [the original] LRA Table 3.2.2.A-1 is in the NMP1 Containment Spray System. Since
 
the environment was identified in the aging management review (AMR) as air, cracking and loss of preload were not identified as aging effects for wrought
 
austenitic stainless steel bolting. The maximum typical operating temperature (based on the internal environments assi gned to components in this system) is< 140 &deg;F. Loss of preload would not typically be an aging effect requiring
 
management for bolting in low temperature systems. NUREG-1801 only specifies
 
loss of preload as an aging effect requiring management for components in the
 
reactor vessel and internals and reactor coolant pressure boundary. The only
 
mechanisms for cracking affecting wrought austenitic stainless steel bolting are
 
stress corrosion cracking and cyclic loading (fatigue). Stress corrosion cracking
 
and thermal fatigue are not aging effects requiring management for wrought austenitic stainless steel at temperatures less than 140 &deg;F. Therefore, loss of
 
mechanical closure integrity is not an aging effect requiring management for
 
bolting in the NMP1 Containment Spray System.
With respect to inaccessible bolts, there are no bolts in the NMP1 Containment Spray System that are inaccessible for examination. The only aging effect
 
requiring management for any bolting in the Containment Spray System is loss of material for carbon or low alloy steel bolting, yield strengths > 100 ksi, in an air
 
environment. This aging effect is m anaged by the Systems Walkdown Program (described in [the original] LRA Section B2.1.33), which performs visual
 
examinations of accessible surfaces for loss of material. The inspection criteria of
 
the Systems Walkdown Program require that bolted joints be inspected for
 
corrosion of external surfaces, and will be enhanced to add inspection for
 
evidence of leakage, which does not require the bolted joints to be disassembled.
3-250 This enhancement is described in [the original] LRA Section B2.1.33 (page B-65), under the "Parameters Monitored/Inspected" heading.
The staff found the applicant's response reasonable and acceptable because the applicant justified the absence of aging effects of wrought austenitic bolting in an air environment in the
 
NMP1 containment spray system. The applicant also satisfactory explained managing the loss of material for carbon or low alloy steel bolting in an air environment in the NMP1 containment
 
spray system, and thus the staff's concern in RAI 3.2-1 is resolved.
The staff's review and evaluation of the applicant's Systems Walkdown Program are documented in SER Section 3.0.3.3.2 As to the loss of material of gray cast ir on external surfaces in an air environment managed by the Systems Walkdown Program the applicant stated t hat this line item is for external surfaces of carbon steel components not in the GALL Report (Note F, 4). The staff found the
 
management of the aging effect for external surfaces of this material in an air environment
 
reasonable and acceptable because the Systems Walkdown Program contains adequate
 
provisions. The staff's review and evaluation of the applicant's Systems Walkdown Program are documented in SER Section 3.0.3.3.2.
As to the evaluation of loss of material for carbon and low alloy steel (yield strength < 100 ksi),filters/strainers in a demineralized untreated water (< 140 &deg;F), low flow environment the
 
applicant proposed to manage this aging effect by the One-Time inspection and the Water
 
Chemistry Control Programs. The staff found these AMPs appropriate and acceptable for
 
managing loss of material in this environment.
The applicant also stated in the NMP letter dated December 21, 2004:
This item applies to the four (4) Containment Spray Pump Discharge Strainers (STR-80-09, STR-80-1 0, STR-80-29, and STR-80-30). The internals of these
 
strainers were removed as part of the modification to address NRC Bulletin
 
96-003, "Potential Plugging of Emergency Core Cooling Suction Strainers by
 
Debris in Boiling-Water Reactors." Additionally, the strainer bodies are made of carbon steel. These are ASME Section XI Class 2 components. As such, the
 
bodies of the strainers are subject only to the VT-2 examination under
 
examination category C-H, 'All Pressure Retaining Components.' The VT-2
 
examination is conducted during the system pressure test during each inspection
 
period. VT-2 examinations are conducted to detect evidence of leakage only. The
 
water source is torus water, so the environment for these strainers is
 
demineralized untreated water, low flow. The chemistry action levels and
 
sampling frequencies for the torus water are specified in NMP1 procedure
 
S-CTP-V666, 'Auxiliary Systems Chemistry'.
The staff found these tests and inspections reasonable and acceptable because they conformto ASME Section XI requirements and industry practice.
The staff's review of the One-Time Inspection and Water Chemistry Control Programs is provided in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.
3-251 As to loss of material as an aging effect for gray cast iron pumps in a treated water, temperature< 140 &deg;F, low flow environment the applicant stated that this aging effect is not in the SRP-LR
 
for this component, material, and environment (Note H). The staff concurred with this statement.
 
This aging effect is managed by the One-Time Inspection, Water Chemistry Control, and
 
Selective Leaching of Materials Programs. The st aff's initial evaluation of the management of the aging effects for this component is discussed in RAI 3.4-2.
In RAI 3.4-2, dated November 17, 2004, the staff requested that the applicant discuss the following:
* Bases for visual, VT, or other inspection methods, frequency of inspections, and acceptance criteria
* Bases for sampling of the pumps to detect selective leaching and whether hardness tests will be performed.
In its response by letter dated December 21, 2004, the applicant stated:
The gray cast iron pumps with an internal environment of treated water (temperature <140 &deg;F), are the two condensate transfer pumps. The aging effect
 
requiring management is loss of material. The aging mechanisms to be managed
 
by the One-Time Inspection Program and the Water Chemistry Control Program
 
include crevice corrosion, general corrosion, and pitting corrosion. The One-Time
 
Inspection Program is a new license renewal (LR) AMP commitment for NMP
 
that is to be implemented prior to the period of extended operation. This
 
commitment was made in the original LRA submittal, as supplemented by
 
NMPNS letter NMP1L 1880 dated October 29, 2004. As such, program
 
documents or procedures specific to managing the aging mechanisms (i.e.
 
crevice corrosion, general corrosion and pitting corrosion), specific inspection
 
methods and acceptance criteria for the two condensate transfer pumps do not
 
currently exist. The frequency of any future inspections for the aging mechanisms
 
of crevice corrosion, general corrosion and pitting corrosion will be based on the
 
findings of the One-Time Inspection Program. However, as stated in
 
Appendix B2.1.20, the One-Time Inspection Program will be implemented consistent with NUREG-1801, Section XI.M32.
As presented in ALRA Sections A1.1.33 and B2.1.21, the implementation of the Selective Leaching of Materials Program is addressed in the program description for the One-Time
 
Inspection Program (see ALRA Sections A1.1.28 and B2.1.20). The One-Time Inspection
 
Program is a new LR AMP commitment for NM P to be implemented prior to the period of extended operation so program documents or pr ocedures for managing the aging mechanism of selective leaching for the two condensate trans fer pumps do not exist; however, as stated in ALRA Section B2.1.21, the Selective Leaching Program will be implemented consistent with GALL AMP XI.M33 (NMP1 Commitment 23 and NMP2 Commitment 21).
A determination of whether hardness tests are necessary will be made at the time of the One-Time Inspection Program implementation. This timing is consistent with ALRA
 
Section B2.1.20, which states that inspection techniques may include a one-time visual
 
inspection and hardness measurement. Hardness testing will be considered as a possible
 
inspection technique if visual examination techniques alone cannot determine whether selective 3-252 leaching severe enough to affect the component intended function is occurring. The use of field hardness testing will also be contingent on the accessibility of the affected component surfaces.
Hardness testing on components susceptible to selective leaching may be appropriate if the component configuration and geometry allow. Tubing and other components like valves with
 
complex internal geometry do not provide adequate access to internal surfaces requiring
 
examination for accurate measurements.
This above information is reflected in its ALRA, and the staff found the applicant's response reasonable and acceptable because the applicant's tests and inspection methods are consistent
 
with industry practice and the GALL Report guidelines.
The applicant stated that this aging effect is not in the GALL Report for this component, material, and environment combination (Note H). The staff concurred with this statement.
Based on the above evaluation, the staff found that the applicant had identified the appropriate AMPs for the materials and environment of t he NMP1 containment spray system components.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant had demonstrated that the aging effects associated with the
 
containment spray system components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3.2A.2.3.2  Engineered Safety Features Syst ems NMP1 Core Spray System - Summary of Aging Management Evaluation - ALRA Table 3.2.2.A-2 The staff reviewed ALRA Table 3.2.2.A-2, which summarizes the results of AMR evaluations for the core spray system component groups.
The staff reviewed the following original LRA Table 3.2.2.A-2 items in the NMP1 Core Spray System:
* Loss of material of gray cast iron ex ternal surfaces in an air environment is managed by the System Walkdown Program. The applicant stated that this material is not in the
 
GALL Report for carbon steel components to which this item applies (Note F,4).
* Cracking of wrought austenitic stainless steel filters/strainers in a treated water, temperature >
140 &deg;F, but < 212 &deg;F, low flow environment is managed by the One-Time Inspection and Water Chemistry Control Programs. The applicant stated that this aging
 
effect is not in the GALL Report for this component, material, and environment
 
combination (Note H).
* Cracking of wrought austenitic stainless steel flow orifices in a treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow environment is managed by the ASMESection XI (Subsection IWB, IWC, IWD) ISI, Water Chemistry Control, and One-Time
 
Inspection Programs. The applicant stated that this aging effect is not in the GALL
 
Report for this component, material, and environment combination (Note H).
3-253
* Copper Alloy (zinc > 15 percent) and aluminum bronze heat exchangers in a lubricating oil environment for which the applicant has identified no aging effect. The applicant
 
stated that this material is not in the GALL Report for this component (Note F).
* Loss of material of gray cast iron pumps in a treated water, temperature > 140 &deg;F, but< 212 &deg;F, low flow environment is managed by One-Time Inspection, Selective Leaching of Materials, and Water Chemistry Control Programs. The applicant stated that this
 
aging effect is not in the GALL Report for this component, material, and environment
 
combination (Note H).
The applicant stated that the loss of material of gray cast iron external surfaces in an air environment managed by the Syst ems Walkdown Program applies to external surfaces of carbon steel components not in the GALL Report (Note F, 4). The staff found the management
 
of the aging effect for external surfaces of this material in an air environment reasonable and
 
acceptable because the Systems Walkdown Program is adequate to manage this aging effect.
 
The staff's review and evaluation of the applicant's Systems Walkdown Program are documented in SER Section 3.0.3.3.2. The staff agreed with the applicant's statement that this
 
item applies to carbon steel components not in the GALL Report (Note F, 4).
The applicant stated that the cracking aging effect of wrought austenitic stainless steel filters/strainers in a treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow environment managed by the One-Time Inspection and Water C hemistry Control Programs is not in the GALL Report for this component, material and environment combination (Note H). The staff
 
concurred with this statement. The staff's review of the aging management of this component is
 
in RAI 3.2-7.
In RAI 3.2-7 dated November 17, 2004, the staff requested that the applicant address the specific tests and inspections, frequency of inspections, and acceptance criteria for the strainers
 
and filters to ensure performance of their intended function in the identified environment.
In its response by letter dated December 21, 2004, the applicant stated that:
The components addressed by this AMR line item are the two core spray pump suction strainers located in the torus. Torus water is managed under the Water
 
Chemistry Control Program, which is described in original LRA Section B2.1.2, as supplemented by NMPNS letter NMPIL 1880 dated October 29, 2004. The
 
chemistry action levels and sampling frequencies for the torus water are provided
 
in the response to RAI 3.2-2. These limits are identical to those specified in EPRI
 
TR-103515-R2, 'BWR Water Chemistry Guidelines -2000 Revision.'
The One-Time Inspection Program is described in original LRA Section B2.1.20, as supplemented by NMPNS letter NMP1L 1880 dated October 29, 2004. The
 
One-Time Inspection Program is a new program that will be implemented prior to the period of extended operation. As such, the procedures needed to answer this
 
question have not yet been developed. However, the One-Time Inspection Program will be consistent with NUREG-1801, Section XI.M32 (One-Time
 
Inspection) when implemented. The One-Time Inspection Program Attribute
 
Assessment (PAA) addresses program implem entation at NMPNS relative to the requirements of Appendix A of NUREG-1800. The One-Time Inspection PAA is
 
available on-site at NMPNS for review.
3-254 The staff found the applicant's response reasonable and acceptable because the applicant's AMPs will be consistent with industry practice and GALL Report requirements.
The staff review and evaluations of the One-Time Inspection and Water Chemistry Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively. The staff agreed with the
 
applicant's statement that this aging effect is not in the GALL Report for this component, material, and environment combination (Note H).
The staff concern in RAI 3.2-7 applies also to the component, material, and environment combination of cracking of wrought austenitic stainless steel flow orifices in a treated water, temperature > 140 &deg;F, but < 212 &deg;F, low flow environment managed by the ASME Section XI (Subsections IWB, IWC, IWD) ISI and Water Chemistry Control Programs.
The staff found the applicant's response reasonable and acceptable because the applicant's AMPs will be consistent with industry practice and GALL Report requirements; therefore, the
 
staff's concern described in RAI 3.2-7 is resolved. This information is reflected in the ALRA.
The staff's reviews of the One-Time Inspection and Water Chemistry Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively. The staff agreed with the applicant's
 
statement that this aging effect is not in the GALL Report for this component, material, and
 
environment combination (Note H).
In RAI 3.2-8 dated November 17, 2004, the staff requested that the applicant discuss its inspection and test activities for the copper alloy (zinc > 15 percent) and aluminum bronze heat
 
exchangers in a lubricating oil environment for which the applicant has identified no aging effect
 
to ensure that the lubricating oil remains free of contaminants and water content.
In its response by letter dated December 21, 2004, the applicant stated that, "Lube oil samples from the NMP1 core spray pump motor cooler (i.e., heat exchanger) oil subsystems are
 
obtained on an annual basis according to site procedure N1-CTP-V520, 'Lube Oil Sampling,'
 
and the oil sample results are evaluated and trended. Any indication of an anomalous condition
 
or adverse trend will result in an investigation under the site CAP."
The staff found the response acceptable because the applicant's inspection and test activities ensure that the lubricating oil remains free of contaminants and water content. The staff also
 
agreed with the applicant's statement that this material is not in the GALL Report for this
 
component (Note F).
In RAI 3.2-10, dated November 17, 2004, the staff requested that the applicant provide additional details relating to test and inspection methods for the loss of material of gray cast iron
 
pumps in a treated water temperature > 140 &deg;F, but < 212 &deg;F, low flow environment managed by One-Time Inspection, Selective Leaching of Materials, and Water Chemistry Control Programs.
 
Specifically the staff requested that the applicant provide (a) the basis for selecting a
 
representative sample for the one-time inspection and (b) inspection methods to detect
 
selective leaching. Also the applicant was requested to indicate whether hardness tests would
 
be performed.
In its response by letter dated December 21, 2004, the applicant stated:
3-255 The basis for selecting representative samples for the one-time inspection are stated in original LRA Section B2.1.20, supplemented by NMPNS letter NMP1 L
 
1880 dated October 29, 2004. The process for identifying the population of
 
potentially affected components will be based upon common characteristics of
 
the components, such as material of construction, fabrication process, operating
 
environment, and aging effects. From the selected population, a sample size will
 
be determined to provide a 90 percent confidence that 90 percent of the
 
population does not have the degradation mechanism present. This terminology
 
and methodology are consistent with EPRI TR107514,'Age Related Degradation
 
Inspection Method and Determination.'
The inspection methods used to detect selective leaching will be consistent with original LRA Section B2.1.20, which states that inspection techniques may
 
include a one-time visual inspection and hardness measurement. Hardness
 
testing will be considered as a possible inspection technique if visual
 
examination techniques alone cannot determine that selective leaching is severe
 
enough to affect the component's intended function. The use of field hardness
 
testing will also be contingent on the accessibility of the affected component
 
surfaces to perform the test. Hardness testing on components susceptible to
 
selective leaching may be appropriate if the component configuration and
 
geometry allows. Tubing and other components such as valves with complex
 
internal geometry do not provide adequate physical access to internal surfaces
 
requiring examination to allow accurate measurements to be made.
The One-Time Inspection Program is a new program that will be developed and implemented prior to the period of extended operation [NMP1 Commitment 23
 
and NMP2 Commitment 21]. The One-Time Inspection Program Attribute
 
Assessment (PAA) addresses program implem entation at NMPNS relative to the requirements of Appendix A of NUREG-1800.
The staff found the applicant's response reasonable and acceptable because the inspection methods are according to industry practice and NRC requirements. The staff also agreed with
 
the applicant that this aging effect is not in the GALL Report for this component, material, and
 
environment combination (Note H). This information has been incorporated into the ALRA.
The staff's reviews of the Selective Leaching of Materials, One-Time Inspection, and Water Chemistry Control Programs are provided in the SER Sections 3.0.3.1.5, 3.0.3.1.4, and
 
3.0.3.2.2, respectively.
The staff found that the applicant had identified the appropriate AMPs for the materials and environment associated with the NM P1 core spray system components.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the core
 
spray system components will be adequately managed so that the intended functions will be
 
maintained consistent with the CLB for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).
3-256 3.2A.2.3.3  Engineered Safety Features Sy stems NMP1 Emergency Cooling System -
Summary of Aging Management Evaluation - ALRA Table 3.2.2.A-3 The staff reviewed ALRA Table 3.2.2.A-3, which summarizes the results of AMR evaluations for the emergency cooling system component groups.
The staff reviewed the following ALRA Table 3.2.2.A-3 items in the NMP1 emergency coolingsystem:
* Cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) bolting in non-borated water systems with operating temperatures > 212 &deg;F leaking fluid environment managed by TLAA evaluated according to 10 CFR 54.21(c). (By
 
attachment 2 to NMPIL 2005 dated December 1, 2005, the applicant deleted this item
 
from the table)
* Cracking and loss of material of wrought austenitic stainless steel heat exchangers in a moist air, wetting, temperature > 140 &deg;F, environment managed by the ASME Section XI (Subsections IWB, IWC, IWD) ISI and Preventive Maintenance Programs. The applicant
 
stated that this environment is not in the GALL Report for this material and component (Note G).
* Aluminum and aluminum alloyed with manganese, magnesium, and magnesium plus silicon tanks in a treated water, temperature >
140&deg;F, environment for which the applicant has identified no aging effect.
* Cracking of aluminum alloy (containing copper or zinc as the primary alloying element) valves in a treated water > 140 &deg;F environment managed by ASME Section XI (Subsections IWB, IWC, IWD) ISI, One-Time Inspection, and Water Chemistry Control
 
Programs. The applicant stated that this material is not in the GALL Report for this
 
component (Note F).
The staff found the deletion by attachment 2 to NMPIL 2005 dated December 1, 2005, of the cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) bolting in non-borated water systems with operating temperatures > 212 &deg;F leaking fluid environment managed by TLAA evaluated according to 10 CFR 54.21(c) acceptable because cumulative
 
fatigue damage is not an applicable AERM for this component.
In RAI 3.2-12 dated November 17, 2004, the staff requested that the applicant provide information as to cracking and loss of material of wrought austenitic stainless steel heat
 
exchangers in moist air, temperature > 140 &deg;F environment managed by the ASME Section XI (Subsections IWB, IWC, IWD) ISI and Preventive Maintenance Programs for these heat
 
exchanger components:(a)parameters monitored or inspected(b)methods of detection of aging effects (c)frequency of inspections including monitoring and trending (d)acceptance criteria and their bases 3-257 In its response by letter dated December 21, 2004, the applicant stated that the subject wroughtaustenitic stainless steel heat exchangers in a moist air (temperature > 140 &deg;F ) environment
 
listed in the original LRA Table 3.2.2.A-3 consist of the four NMP1 emergency condensers and
 
that the aging effects requiring management are cracking and loss of material.
By letter dated December 6, 2004, the applicant submitted supplemental information to the original LRA Section 3.1 including revisions to the AMPs for the NMP1 emergency condensers.
 
Specifically the original LRA Table 3.1.1.A item numbers 3.1.1.A-03 and 3.1.1.A-09 were
 
revised to indicate that the emergency condensers were managed by a combination of the Water Chemistry Control, ASME Section XI (Subsections IWB, IWC, and IWD) ISI, and
 
Preventive Maintenance Programs. The emergency condenser vent is monitored continuously in the control room for radioactivity, and a justification for not performing eddy current testing of
 
the condenser tubes was provided. The applicant stated that because the Water Chemistry Control and ASME Section XI Programs are well established in the industry and credited in the
 
GALL Report and because the applicant's programs are consistent with the GALL Report
 
guidelines with justified exceptions the four categories of information requested were provided
 
for the Preventive Maintenance Program only.
Regarding the Preventive Maintenance Program the applicant stated:
  (1)The Preventive Maintenance Program includes temperature monitoring of water in the emergency cooling steam and return lines adjacent to the emergency condensers and in
 
the shell of the emergency condensers. The parameters monitored are water
 
temperature at the inlet and outlet of the condensers and on the shell side of the
 
condensers.    (2)The methods of detection of cracking and loss of material aging effects are through the potential impacts on system temperatures consistent with GALL Report guidelines.  (3)Temperature monitoring of the emergency condensers is conducted continuously through installed instrumentation with local indications and alarms in the control room.
 
Twice a year the temperature data are collected and analyzed to determine if any
 
detrimental effects have occurred.    (4)The temperature monitoring procedure contains separate acceptance criteria for the steam inlet piping, emergency condenser shell water, and condensate return line piping.
 
The acceptance criteria are based upon design analyses to prevent damage to the
 
piping and condensers.
The staff found the applicant's response reasonable and acceptable because the inspectionmethods described are according to ASME Section XI requirements and GALL Report
 
guidelines.
The staff evaluation of aluminum and alumi num alloyed with manganese, magnesium, and magnesium plus silicon tanks in a treated water, temperature > 140 &deg;F environment for which the applicant has identified no aging effect is in RAI 3.2-14.
3-258 In RAI 3.2-14 dated November 17, 2004, the staff requested that the applicant provide the following information about the aging management of the tanks:  (1)ASTM designation or specific alloy content of the material    (2)Bases for the conclusion of no aging effects in this environment (for example, EPRI, ASTM, or similar reference documents with supporting data)
In its response by letter dated December 21, 2004, the applicant stated:
There are two tanks in the NMP1 emergency cooling system that are made ofaluminum alloy with magnesium in a treated water (temperature <140 &deg;F)
 
environment. These tanks (TANK-60-9 and TANK-60-10), provide the
 
demineralized water make-up to the emergency condensers and are in-scope
 
and subject to AMR.    (1)The tanks are made of wrought-aluminum alloy 5052-H34, which is essentially pure aluminum with 2.5 percent magnesium and 0.25 percent chromium.    (2)Aluminum alloyed with magnesium has good corrosion resistance in atreated water (temperature <140 &deg;F ) environment and resists stress
 
corrosion cracking. (Reference, Section 2.1.7 and Section 4 of
 
Appendix A of EPRI TR-1 14882, Non-Class 1 Mechanical
 
Implementation Guideline and Mechanical Tools, Revision 3.)
The staff found the applicant's response reasonable and acceptable because the applicant had provided the bases for the conclusion of no aging effects in the alloyed aluminum tanks;
 
therefore, the staff's concern described in RAI 3.2-14 is resolved.
The applicant stated as to cracking of aluminum alloy (containing copper or zinc as the primary alloying elements) valves in a treated water, temperature > 140 &deg;F, environment managed byASME Section XI, (Subsections IWB, IWC, IWD) ISI, One-Time Inspection, and Water
 
Chemistry Control Programs that this material is not in the GALL Report for this component (Note F). The staff concurred with this statement.
In RAI 3.2-15 dated November 17, 2004, the staff requested that the applicant provide the following information:a)ASTM designation or specific alloy content of the materialb)Bases for the conclusion that cracking is the only aging effect in this environment and EPRI, ASTM, or similar supporting documentary references In its response dated December 21, 2004 the applicant stated:
There are six valves in the NMP1 Emer gency Cooling System that are made of aluminum alloy (containing copper or zinc as the primary alloying elements) in a treated water (temperature <140 &deg;F ) environment. These valves (BV-60-01, BV-60-02, VLV-60-07, VLV-60-08, VLV-6011 and VLV-60-12) are in-scope and
 
subject to AMR.
3-259a)The valves are made of aluminum alloy SB-26 (no grade). b)Aluminum alloyed with copper or zinc as the primary alloying elements isresistant to general corrosion in a treated water (temperature <140 &deg;F )
 
environment, but is susceptible to stress corrosion cracking, as discussed in
 
EPRI TR-1 14882, "Non-Class 1 Mechanical Implementation Guideline and
 
Mechanical Tools," Revision 3.
The staff found the applicant's response reasonable and acceptable because the applicant had provided appropriate bases for the conclusion that stress corrosion cracking is the only AERM
 
in this material-environment combination; therefore, the staff's concern described in RAI 3.2-15
 
is resolved.
The staff found further that the applicant had identified the appropriate AMPs for the materials and environment of the NMP1 emergency cooling system components and, the staff's concern described in RAI 3.2-15 is resolved. The above information is reflected in the ALRA.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the
 
emergency cooling system components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
Conclusion. On the basis of its review, the staff found that the applicant appropriately evaluated AMR results involving material, environment, AERMs, and AMP combinations that are not
 
evaluated in the GALL Report. The staff found that the applicant had demonstrated that the
 
effects of aging will be adequately managed so that the intended functions will be maintained
 
consistent with the CLB for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).
3.2A.3  Conclusion the staff concludes that there is reasonable assurance that the applicant has provided sufficient information to demonstrate that the effects of aging for the NMP1 ESF systems components that are 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 also reviewed the applicable UFSAR supplement program summaries and concludes that they adequately describe the AMPs credited for managing aging of the ESF systems, as
 
required by 10 CFR 54.21(d).3.2B  NMP2 Aging Management of Engineered Safety Features This section of the SER documents the staff's review of the applicant's AMR results for the ESF
 
systems components and component groups associ ated with the following NMP2 systems:
* hydrogen recombiner system
* high pressure core spray system
* low pressure core spray system 3-260
* reactor core isolation cooling system
* residual heat removal system
* standby gas treatment system3.2B.1  Summary of Technical Information in the Amended Application In ALRA Section 3.2, the applicant provided AMR results for the ESF systems components and component groups. In ALRA Table 3.2.1.B, "NMP2 Summary of Aging Management Programs
 
for the Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801," the
 
applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL Report for the ESF systems components and component groups.
The applicant's AMRs incorporated applicable operating experience in the determination of AERMs. These reviews included evaluation of plant-specific and industry operating experience.
 
The plant-specific evaluation included reviews of condition reports and discussions with
 
appropriate site personnel to identify AERMs. The applicant's review of industry operating
 
experience included a review of the GALL Report and operating experience issues identified
 
since the issuance of the GALL Report.
3.2B.2  Staff Evaluation The staff reviewed ALRA Section 3.2 to determine if the applicant provided sufficient information to demonstrate that the effects of aging for the ESF systems components that are within the
 
scope of license renewal and subject to an AMR will be adequately managed so that the
 
intended functions will be maintained consistent with the CLB for the period of extended
 
operation, as required by 10 CFR 54.21(a)(3).
The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain identified 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 ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.
 
The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's
 
audit evaluation are documented in the Audit and Review Report and are summarized in SER
 
Section 3.2B.2.1.
In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicant's further
 
evaluations were consistent with the acceptance criteria in SRP-LR Section 3.2.2.2. The staff's
 
audit evaluations are documented in the Audit and Review Report and are summarized in SER
 
Section 3.2B.2.2.
In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were not consistent with, or not addressed in, the GALL Report. The audit and technical review
 
included evaluating whether all plausible aging effects were identified and evaluating whether
 
the aging effects listed were appropriate for the combination of materials and environments
 
specified. The staff's audit evaluations are documented in the Audit and Review Report and are
 
summarized in SER Section 3.2B.2.3. The staff's evaluation of its technical review is also
 
documented in SER Section 3.2B.2.3.
3-261 Finally, the staff reviewed the AMP summary descriptions in the USAR supplement to ensure that they provided an adequate description of the programs credited with managing or
 
monitoring aging for the ESF systems components.
Table 3.2B-1 below provides a summary of t he staff's evaluation of NMP2 components, aging effects/mechanisms, and AMPs listed in ALRA Section 3.2, that are addressed in the GALL
 
Report.Table 3.2B-1  Staff Evaluation for NMP2 Engineered Safety Features Systems Components in the GALL ReportComponent GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation Piping, fittings, and valves in emergency core cooling system (Item Number
 
3.2.1.B-01)
Cumulative fatigue damageTLAA, evaluated inaccordance with 10 CFR 54.21(c)TLAAThis TLAA is evaluated in
 
Section 4.3, Metal Fatigue Analysis Piping, fittings, pumps, and valves in emergency core cooling system (Item Number
 
3.2.1.B-02)
Loss of material due to general corrosion Water chemistry and one-time
 
inspection Water Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2B.2.2.2)
Components in containment spray (PWR only),
standby gas treatment (BWR only), containment
 
isolation, and emergency core cooling systems (Item Number
 
3.2.1.B-03)
Loss of material due to general corrosionPlant specificWater Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2B.2.2.2)
Piping, fittings, pumps, and valves in emergency core cooling system (Item Number
 
3.2.1.B-04)
Loss of material due to pitting and
 
crevice corrosion Water chemistry and one-time
 
inspection Water Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2B.2.2.3)
Components in containment spray (PWR only),
standby gas treatment (BWR only), containment
 
isolation, and emergency core cooling systems (Item Number
 
3.2.1.B-05)
Loss of material due to pitting and
 
crevice corrosionPlant-specificWater Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2B.2.2.3)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-262 Containment isolation valves and
 
associated piping (Item Number
 
3.2.1.B-06)
Loss of material due to microbiologically
 
influenced corrosionPlant-specificNoneNot applicable (See Section 3.2B.2.2.4)
Seals in standby gas treatment system (Item Number
 
3.2.1.B-07)
Changes in properties due to
 
elastomer degradationPlant-specificNoneNot applicable (See Section 3.2B.2.2.5)
High pressuresafety injection (charging) pump miniflow orifice (Item Number
 
3.2.1.B-08)
Loss of material due to erosionPlant-specificNoneNot applicable,PWR onlyDrywell and suppression
 
chamber spray system nozzles and flow orifices (Item Number
 
3.2.1.B-09)
Plugging of flow orifice and spray
 
nozzles due to
 
general corrosion
 
productsPlant-specificNoneNot applicable (See Section 3.2B.2.2.7)
External surface of carbon steel
 
components (Item Number
 
3.2.1.B-10)
Loss of material due to general corrosionPlant-specificSystems Walkdown Program (B2.1.33)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.2B.2.2.2)
Piping and fittings of CASS in emergency core cooling system (Item Number
 
3.2.1.B-11)
Loss of fracture toughness due to
 
thermal aging
 
embrittlementThermal aging embrittlement of
 
CASSNoneNot applicableThere are no CASS piping and fittings with this aging
 
effect/mechanism in
 
NMP2 Components serviced by open-cycle cooling system (Item Number
 
3.2.1.B-12)
Loss of material due to general, pitting, and crevice
 
corrosion, MIC, and
 
biofouling; buildup
 
of deposit due to
 
biofoulingOpen-cycle coolingwater systemOpen-Cycle CoolingWater System
 
Program (B2.1.10)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.2B.2.1)Components serviced by closed-cycle cooling system (Item Number
 
3.2.1.B-13)
Loss of material due to general, pitting, and crevice
 
corrosionClosed-cyclecooling water systemNoneNot applicableNo ESF System components [except
 
RHR HXs] serviced by closed-cycle cooling water system Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-263Emergency corecooling system
 
valves and lines to
 
and from HPCI and
 
RCIC pump turbines (Item Number
 
3.2.1.B-14)Wall thinning due toflow-accelerated
 
corrosionFlow-accelerated corrosionFlow-Accelerated Corrosion Program (B2.1.9)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.2B.2.1)Not applicable for lines to and from
 
HPCI pump turbine Pumps, valves, piping, and fittings
 
in containment spray and emergency core cooling systems (Item Number
 
3.2.1.B-15)
Crack initiation andgrowth due to SCCWater chemistryNoneNot applicable,PWR only Pumps, valves, piping, and fittings in emergency core cooling systems (Item Number
 
3.2.1.B-16)
Crack initiation andgrowth due to SCC
 
and IGSCC Water chemistryand BWR stress
 
corrosion cracking Water Chemistry Control Program (B2.1.2), BWR
 
Stress Corrosion
 
Cracking Program (B2.1.6), One-Time
 
Inspection Program (B2.1.20)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.2B.2.1)Not applicable for pumps in emergency core cooling systems Carbon steel components (Item Number
 
3.2.1.B-17)
Loss of material due to boric acid
 
corrosionBoric acid corrosionNoneNot applicable,PWR only The staff's review of the NMP2 component groups followed one of several approaches. One approach, documented in SER Section 3.2B.2.1, discusses the staff's review of the AMR results
 
for components in the ESF systems that the applicant indicated are consistent with the GALL
 
Report and do not require further evaluation. Another approach, documented in SER
 
Section 3.2B.2.2, discusses the staff's review of the AMR results for components in the ESF
 
systems that the applicant indicated are consistent with the GALL Report and for which further
 
evaluation is recommended. A third approach, documented in SER Section 3.2B.2.3, discusses
 
the staff's review of the AMR results for components in the ESF systems that the applicant
 
indicated are not consistent with, or not addressed in, the GALL Report. The staff's review of
 
AMPs that are credited to manage or monitor aging effects of the ESF systems components is documented in SER Section 3.0.3.
3-2643.2B.2.1  AMR Results That Are Consistent with the GALL Report Summary of Technical Information in the Amended Application. In ALRA Section 3.2.2.B, the applicant identified the materials, environments, and AERMs. The applicant identified the
 
following programs that manage the aging effect s related to the ESF systems components:
* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Water Chemistry Control Program
* Flow-Accelerated Corrosion Program
* Open-Cycle Cooling Water System Program
* One-Time Inspection Program
* Preventive Maintenance Program
* Systems Walkdown Program
* Bolting Integrity Program Staff Evaluation. In ALRA Tables 3.2.2.B-1 through 3.2.2.B-6, the applicant provided a summary of AMRs for the ESF systems components, and identified which AMRs it considered to be
 
consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report does not recommend further
 
evaluation, the staff performed an audit and review to determine whether the plant-specific
 
components contained in these GALL Report component groups were bounded by the GALL
 
Report evaluation.
The applicant provided a note for each AMR line item. The notes indicate how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with
 
Notes A through E, which indicate that 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report and the 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been
 
reviewed and accepted by the staff. The staff also determined whether the AMP identified by the
 
applicant was consistent with the AMP identified in the GALL Report 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 AMP identified by the GALL Report. This note indicates that the applicant
 
was unable to find a listing of some system components in the GALL Report. However, the
 
applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was under review. The staff audited
 
these line items to verify consistency with the GALL Report. The staff also determined whether 3-265 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 AMP identified in the GALL Report. 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. The staff verified whether
 
the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The
 
staff also determined whether the AMP identified by the applicant was consistent with the AMP
 
identified in the GALL Report 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 a different AMP is credited. The staff audited these line items
 
to verify consistency with the GALL Report. The staff also determined whether the identified
 
AMP would manage the aging effect consistent with the AMP identified by the GALL Report and
 
whether the AMR was valid for the site-specific conditions.
The staff conducted an audit and review of the information provided in the ALRA, as documented in the Audit and Review 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
 
ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The
 
staff's evaluation is discussed below.
3.2B.2.1.1  Cumulative Fatigue Damage
 
In the discussion section of ALRA Table 3.2.1.B Item 3.2.1.B-01 the applicant stated that piping, fittings, and valves in the emergency core cooli ng systems may be subject to cumulative fatigue damage and are subject to TLAA. In ALRA Table 3.4.2.B-4 the staff noted that a flexible hose
 
had been included.
As documented in the Audit and Review Report, the applicant explained that the hose is a flexible bellows welded to end fittings of rigid pipe. A braided stainless steel sheath protects the
 
outer diameter of the bellows. The component is designed to absorb movement, and no TLAA
 
has been performed.
Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicant's consideration of recent operating
 
experience and proposals for managing associated aging effects. On the basis of its review, the
 
staff concludes that there is reasonable assurance that the AMR results, which the applicant
 
claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL
 
Report. Therefore, the staff concludes that there is reasonable assurance that the applicant had
 
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 for the period of
 
extended operation, as required by 10 CFR 54.21(a)(3).
3-2663.2B.2.2  AMR Results That Are Consistent with the GALL Report, for Which Further Evaluation is Recommended Summary of Technical Information in the Amended Application. In Section 3.2.2.C of its letter dated August 19, 2005, the applicant provided further evaluation of aging management as
 
recommended by the GALL Report for the ESF systems components. The applicant provided information concerning how it will manage the following aging effects:
* cumulative fatigue damage
* loss of material due to general corrosion
* local loss of material due to pitting and crevice corrosion
* local loss of material due to microbiologically influenced corrosion
* changes in properties due to elastomer degradation
* local loss of material due to erosion
* buildup of deposits due to corrosion Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends
 
further evaluation, the staff audited and reviewed the applicant's evaluation to determine
 
whether it adequately addressed the issues that were further evaluated. In addition, the staff
 
reviewed the applicant's further evaluations against the criteria contained in SRP-LR
 
Section 3.2.2.2. Details of the staff's audit are documented in the staff's Audit and Review
 
Report. The staff's evaluation of the aging effects is discussed in the following sections.
3.2B.2.2.1  Cumulative Fatigue Damage
 
In Section 3.2.2.C.1 of its letter dated August 19, 2005, the applicant stated 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 staff's review of the applicant's evaluation
 
of this TLAA.
3.2B.2.2.2  Loss of Material Due to General Corrosion
 
The staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.2.2.2.2.1.
In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant addressed loss of material at locations with stagnant flow conditions due to general corrosion of pumps, valves, piping, and
 
fittings of some of the BWR emergency core cooling systems and lines to the suppression
 
chamber and to the drywell and suppression chamber spray system.
SRP-LR Section 3.2.2.2.2.1 states that the management of loss of material due to general corrosion of pumps, valves, piping, and fittings of some of the BWR emergency core cooling
 
systems and of lines to the suppression cham ber and to the drywell and suppression chamber spray system should be evaluated further. The AM P relies on monitoring and control of primary water chemistry based on EPRI guidelines to mitigate degradation; however, control of primary
 
water chemistry does not prevent loss of material due to general corrosion in stagnant flow
 
conditions. Therefore, the effectiveness of the applicant's Water Chemistry Control Program
 
should be verified to ensure that corrosion does not occur.
3-267 The GALL Report recommends further evaluation of programs to manage loss of material due to general corrosion to verify the effectiveness of the applicant's Water Chemistry Control
 
Program. A one-time inspection of select components at susceptible locations is an acceptable
 
method to determine whether an aging effect and aging effect mechanism is either not occurring
 
or progressing very slowly so that the component's intended function will be maintained during
 
the period of extended operation.
In the letter dated August 19, 2005, the applicant stated that the applicable NMP2 systems are the high pressure core spray, low pressure core spray, reactor core isolation cooling and
 
residual heat removal systems. The aging effect and aging effect mechanism are managed by a
 
combination of the Water Chemistry Control Program and One-Time Inspection Program.
The staff's review and evaluation of the applicant's Water Chemistry Control and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
In addition the staff reviewed Section 3.2.2.C.2 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.2.2.
In Section 3.2.2.C.2 of its letter dated August 19, 2005, the applicant also addressed loss of material due to general corrosion of components in the standby gas treatment, containment
 
isolation, and emergency core cooling systems.
SRP-LR Section 3.2.2.2.2.2 states that loss of material due to general corrosion could occur in the drywell and suppression chamber spray systems header and spray nozzle components, standby gas treatment system components, contai nment isolation valves and associated piping, the automatic depressurization system pipi ng and fittings, emergency core cooling system header piping and fittings and spray nozzles, and the external surfaces of carbon steel
 
components. The GALL Report recommends further plant-specific evaluation to ensure
 
adequate management of the aging effect and aging effect mechanism.
In the letter dated August 19, 2005, the applicant also stated that the applicable NMP2 systems are the hydrogen recombiner, reactor core isolation cooling, standby gas treatment, and main
 
steam (for automatic depressurization) systems. The aging effect and aging effect mechanism
 
for internal surfaces is managed by the One-Time Inspection Program. The aging effect and
 
aging effect mechanism for external surfaces of carbon steel components in ECCS systems is managed by the Systems Walkdown Program.
The staff review and evaluations of the applicant's One-Time Inspection and Systems Walkdown Programs are documented in SER Sections 3.0.3.1.4 and 3.0.3.3.2, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
The staff concludes that the applicant's programs have met the criteria of SRP-LR Section 3.2.2.2.2. For those line items addressed in Section 3.2.2.C.2 of the applicant's letter
 
dated August 19, 2005, the staff determined that the information in the application is consistent
 
with the GALL Report and the applicant had demonstrated that the effects of aging will be 3-268 adequately managed so that intended functions will be maintained consistent with the CLB during the period of extended operation as required by 10 CFR 54.21(a)(3).
3.2B.2.2.3  Local Loss of Material Due to Pitting and Crevice Corrosion
 
The staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.3.1.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant addressed loss of material in stagnant flow conditions due to pitting and crevice corrosion of pumps, valves, piping, and
 
fittings of some of the BWR emergency core cooling systems and of lines to the suppression
 
chamber and to the drywell and suppression chamber spray system.
SRP-LR Section 3.2.2.2.3.1 states that the management of local loss of material due to pitting and crevice corrosion of pumps, valves, piping, and fittings of some of the BWR emergency
 
core cooling system piping and fittings and of lines to the suppression chamber and to the
 
drywell and suppression chamber spray system should be evaluated further. The AMP relies on monitoring and control of primary water chemistry based on EPRI guidelines to mitigate
 
degradation; however, control of coolant water chemistry does not prevent loss of material due
 
to crevice and pitting corrosion in stagnant flow conditions. Therefore, the effectiveness of the
 
applicant's Water Chemistry Control Program should be verified to ensure that corrosion does
 
not occur. The GALL Report recommends further evaluation of programs to manage the loss of material due to pitting and crevice corrosion to verify the effectiveness of the applicant's Water
 
Chemistry Control Program.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the applicable NM2 systems are the high pressure core spray, low pressure core spray, reactor core isolation
 
cooling, and residual heat removal systems. The aging effect and aging effect mechanism are
 
managed by a combination of the Water C hemistry Control Program and the One-Time Inspection Program.
The staff's review and evaluation of the applicant's Water Chemistry Control and One-Time Inspection Programs are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
In addition the staff reviewed Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.3.2.
In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant also addressed loss of material due to pitting and crevice corrosion of components in the standby gas treatment, containment isolation, and emergency core cooling systems.
SRP-LR Section 3.2.2.2.3.2 states that local loss of material due to pitting and crevice corrosion could occur in the containment isolation valves and associated piping and automatic
 
depressurization system piping and fittings. The GALL Report recommends further evaluation to
 
ensure adequate management of the aging effect and aging effect mechanism.
3-269 In Section 3.2.2.C.3 of its letter dated August 19, 2005, the applicant stated that the applicable NM2 system is the hydrogen recombiner syst em. The aging effect and aging effect mechanism are managed by the One-Time Inspection Program.
The staff reviewed the applicant's One-Time Inspection Program and its evaluation is documented in SER Section 3.0.3.1.4.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant's programs have met the criteria of SRP-LR Section 3.2.2.2.3. For those line
 
items addressed in Section 3.2.2.C.3 of the applicant's letter dated August 19, 2005, the staff
 
determined that the information in the application is consistent with the GALL Report and the
 
applicant had demonstrated that the effects of aging will be adequately managed so that the
 
intended functions will be maintained consistent with the CLB during the period of extended
 
operation as required by 10 CFR 54.21(a)(3).
3.2B.2.2.4  Local Loss of Material Due to Microbiologically Influenced Corrosion
 
The staff reviewed Section 3.2.2.C.4 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.4.
The applicant stated in Section 3.2.2.C.4 of its letter dated August 19, 2005, that for the local loss of material due to microbiologically induced corrosion (MIC) in containment isolation valves
 
and associated piping this aging effect and aging effect mechanism are not applicable to NMP.
 
NMP considers MIC an aging effect and aging effect mechanism for systems with raw water
 
environments. NMP2 has no raw water environm ent for containment isolation valves or associated piping; therefore, this issue is not applicable for NMP2. As documented in the Audit
 
and Review Report, the staff determined through discussions with the applicant's technical
 
personnel that the local loss of material due to MIC in containment isolation valves and
 
associated piping is not applicable to NMP2.
Because NMP2 has no containment isolation valves subject to this aging effect and aging effect mechanism the staff determined that it is not applicable to NMP2.
3.2B.2.2.5  Changes in Properties Due to Elastomer Degradation
 
The staff reviewed Section 3.2.2.C.5 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.5.
In Section 3.2.2.C.5 of its letter dated August 19, 2005, the applicant stated that for the seals in the standby gas treatment system this aging effect and aging effect mechanism are not
 
applicable to NMP2. The NMP2 standby gas tr eatment system contains no seals. As documented in the Audit and Review Report, the staff determined through discussions with the
 
applicant's technical personnel that the standby gas treatment system contains no seals; therefore, this aging effect and aging effect mechanism are not applicable to NMP2.
Because NMP2 has no components subject to this aging effect and aging effect mechanism the staff determined that it is not applicable to NMP2.
3-270 3.2B.2.2.6  Local Loss of Material Due to Erosion The staff reviewed Section 3.2.2.C.6 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.2.2.2.6.
In Section 3.2.2.C.6 of its letter dated August 19, 2005, the applicant stated that this aging effect applies to PWRs only.
Because NMP is a BWR the staff found that this aging effect and aging effect mechanism are not applicable to NMP2.
3.2B.2.2.7  Buildup of Deposits Due to Corrosion
 
The staff reviewed Section 3.2.2.C.7 of the applicant's letter dated August 19, 2005, against the criteria of Section 3.2.2.2.7.
In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant addressed the plugging of components due to general corrosion in the spray nozzles and flow orifices of the drywell and
 
suppression chamber spray system.
SRP-LR Section 3.2.2.2.7 states that the plugging of components due to general corrosion could occur in the spray nozzles and flow orifices of the drywell and suppression chamber spray
 
system. This aging effect and aging effect mechanism and effect will apply because spray
 
nozzles and flow orifices are wetted occasionally even though most of the time this system is on
 
standby. The wetting and drying of these components can accelerate this particular corrosion.
 
The GALL Report recommends further evaluation to ensure adequate management of the aging
 
effect and aging effect mechanism.
In Section 3.2.2.C.7 of its letter dated August 19, 2005, the applicant stated that for NMP2 the containment spray cooling mode of the residual heat removal system contains the subject spray
 
nozzles and flow orifices. The plugging of spray nozzles due to general corrosion is not an
 
applicable aging effect and aging effect mechanism as these components are stainless steel not
 
susceptible to general corrosion. The plugging of flow orifices due to general corrosion is not an
 
applicable aging effect and aging effect mechanism because the lines containing these
 
components are flushed during quarterly testing which prevents the buildup of deposits.
NMP2 spray nozzles are made of stainless steel and the orifices are periodically flushed; therefore; the staff found this aging effect not applicable to NMP2.
3.2B.2.2.8  Quality Assurance for Aging Management of Nonsafety-Related Components
 
SER Section 3.0.4 includes the staff's evaluation of the applicant's quality assurance program.
 
Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL
 
Report recommends further evaluation, the staff determined that the applicant adequately
 
addressed the issues that were further evaluated. The staff found that the applicant had
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3-2713.2B.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report Summary of Technical Information in the Amended Application. In ALRA Tables 3.2.2.B-1 through 3.2.2.B-6, the staff reviewed additional details of the results of the AMRs for material, environment, AERM, and AMP combinations that are not consistent with the GALL Report, or
 
that are not addressed in the GALL Report.
In ALRA Tables 3.2.2.B-1 through 3.2.2.B-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, and provided inform ation concerning how the aging effect will be managed. 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, materi al, 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.
Staff Evaluation. For component type, material, and environment combinations that are not evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine
 
whether the applicant had 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). The staff's evaluation is discussed in
 
the following sections.
3.2B.2.3.1  Engineered Safety Features Sy stems NMP2 Hydrogen Recombiner System -
Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-1 The staff reviewed ALRA Table 3.2.2.B-1, which summarizes the results of AMR evaluations for the hydrogen recombiner system component groups.
The staff reviewed the following ALRA Table 3.2.2.B-1 item for the NMP2 hydrogen recombinersystem.
* Martensitic precipitation hardenable and superferritic stainless steel bolting in an air environment for which the applicant has identified no aging effect.
The staff found the applicant's assessment of no aging effect for this material, environment, and component combination acceptable as supported by industry data and operating experience.
(Also refer to staff's evaluation in RAI 3.2-16 discussed in SER Section 3.2B.2.3.6, Standby Gas
 
Treatment Systems, where the aging managem ent in a similar component, material, environment combination is evaluated).
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the
 
hydrogen recombiner system components w ill be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3-272 3.2B.2.3.2  Engineered Safety Features System s NMP2 High Pressure Core Spray System -
Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-2 The staff reviewed ALRA Table 3.2.2.B-2, which summarizes the results of AMR evaluations for the high pressure core spray system component groups.
The staff reviewed the following ALRA Table 3.2.2.B-2 items in the NMP2 high pressure corespray system.
* Cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) closure bolting for non-borated water system with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c). The
 
applicant stated that this environment is not in the GALL Report for this
 
material-component combination (Note G). (By attachment 2 of NMPIL 2005 dated
 
December 1, 2005, the applicant deleted this item from the table)
* Cracking and loss of material of martensitic precipitation hardenable and superferritic stainless steel closure bolting for non-borated water systems with temperatures > 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program. The applicant
 
stated that this environment is not in the GALL Report for this material-component
 
combination (Note G).
* Cumulative fatigue damage in martensitic, precipitation hardenable and superferritic stainless steel bolting for non-borated systems with temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c). (By
 
NMPIL 2005 attachment 2 dated December 1, 2005, the applicant deleted this item from
 
the table)
* Cumulative fatigue damage of nickel-based alloy piping and fittings in a treated water or steam environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).
The applicant stated that this material is not in the GALL Report for this component (Note F).
* Cracking of nicked based piping and fittings in a treated water or steam, temperatures >482 &deg;F low flow environment managed by the One-Time Inspection and Water Chemistry Control Programs The applicant stated that this material is not in the GALL Report for
 
this component (Note F).
* Cracking of wrought austenitic stainless steel restriction orifices in a treated water orsteam, temperature >482 &deg;F, low flow envir onment managed by the One-Time Inspection and Water Chemistry Control Programs. The applicant stated that this aging effect is not
 
in the GALL Report for this component, material, and environment combination (Note H).
The applicant deleted cumulative fatigue damage of carbon or low alloy steel (yield strength
> 100 ksi) closure bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c)
 
from the table by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found this
 
deletion acceptable because cumulative fatigue damage is not an applicable AERM for this
 
component.
The staff found the management of the aging effects of cracking and loss of material of martensitic precipitation hardenable and superferritic stainless steel closure bolting for 3-273 non-borated water systems with temperatures > 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program acceptable as discussed in the evaluation of the program in SER
 
Section 3.0.3.2.23. The applicant stated that this environment is not in the GALL Report for this
 
material-component combination (Note G). The staff concurred with this statement.
The applicant deleted cumulative fatigue damage in martensitic, precipitation hardenable and superferritic stainless steel bolting for non-borated systems with temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) from the table by NMPIL 2005 attachment 2 dated December 1, 2005.
The staff found the aging management of cumulative fatigue damage of nickel-based alloy piping and fittings in a treated water or steam environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) reasonable and acceptable. The applicant stated that this
 
material is not in the GALL Report for this component (Note F). The staff concurred with this
 
statement.
The staff found the aging management of cracking of nickel-based piping and fittings in atreated water or steam, temperature > 482 &deg;F, lo w flow environment by One-Time Inspection and Water Chemistry Control Programs appropria te and acceptable in this environment. The staff evaluations of the One-Time Inspection and Water Chemistry Control Programs are in SER
 
Sections 3.0.3.1.4 and 3.0.3.2.2 respectively. The applicant stated that this material is not in the
 
GALL Report for this component (Note F). The staff concurred with this statement.
The staff's evaluation of the management of cracking of wrought austenitic stainless steelrestriction orifices in a treated water or steam, temperature > 482 &deg;F, low flow environment by
 
One-Time Inspection and Water Chemistry Control Programs is in RAI 3.2-7 (SER
 
Section 3.2A.2.3.2). The staff found these AMPs appropriate and acceptable for this
 
environment. The staff's evaluations of One-Ti me Inspection and Water Chemistry Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively. The applicant stated that this aging effect is not in the GALL Report for this component, material, and environment
 
combination (Note H). The staff concurred with this statement.
The staff's evaluations found that the applicant had identified the appropriate AMPs for the materials and environment associated with the components in the NMP2 high pressure core spray system.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the high
 
pressure core spray system components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3.2B.2.3.3  Engineered Safety Features System s NMP2 Low Pressure Core Spray System -
Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-3 The staff reviewed ALRA Table 3.2.2.B-3, which summarizes the results of AMR evaluations for the low pressure core spray system component groups.
The staff reviewed the following ALRA Table 3.2.2.B-3 items in the NMP2 low pressure corespray system 3-274
* Cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).The
 
applicant stated that this environment is not in the GALL Report for this
 
material-component combination (Note G). (By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant deleted this item from the table)
* Cracking and loss of material in martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with operating temperatures
 
> 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program. The applicant stated that this environment is not in the GALL Report for this
 
material-component combination (Note G).
* Cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with operating temperatures
 
> 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).The applicant stated that this environment is not in the GALL Report for
 
this material-component combination (Note G). (By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant deleted this item from the table)
* Cracking in wrought austenitic stainless steel restriction orifices in a treated water, temperature > 140 &deg;F, but < 212 &deg;F, environment managed by the One-Time inspection and Chemistry Control Programs. The applicant stated that this aging effect is not in the
 
GALL Report for this component, material, and environment combination (Note H).
* Cracking of wrought austenitic stainless steel restriction orifices in a treated water or steam, temperature > 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs. The applicant stated that this aging effect is not in the
 
GALL Report for this component, material, and environment combination (Note H).
The applicant by NMPIL 2005 attachment 2 dated December 1, 2005, deleted from the table cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA.
The staff found management of cracking and loss of material in martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with
 
operating temperatures > 212 &deg;F, leaking fluid environment by the Bolting Integrity Program acceptable as discussed in the evaluation of the Bolting Integrity Program in SER
 
Section 3.0.3.2.23. The applicant stated that this environment is not in the GALL Report for this
 
material-component combination (Note G). The staff concurred with this statement.
The applicant by NMPIL 2005 attachment 2 dated December 1, 2005, deleted from the table cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless
 
steel bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).
The applicant stated that this environment is not in the GALL Report for this material-component combination (Note G). The staff concurred with this statement.
The applicant stated that cracking in wrought austenitic stainless steel restriction orifices in a treated water, temperature > 140 &deg;F, but < 212 &deg;F, environment managed by the One-Time 3-275 inspection and Chemistry Control Programs is not in the GALL Report for this component, material, and environment combination (Note H). The staff concurred with this statement. The
 
staff found these AMPs appropriate and acceptable for managing the aging effect in this
 
environment. The staff evaluations of the One-Time Inspection and Water Chemistry Control Programs are provided in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.
The applicant stated that cracking of wrought austenitic stainless steel restriction orifices in a treated water or steam, temperature > 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs is not in the GALL Report for this component, material, and environment combination (Note H). The staff concurred with this statement. The
 
staff evaluation of the management of the aging effects is in RAI 3.2-7 (SER
 
Section 3.2A.2.3.2). The staff found these management programs appropriate and acceptable
 
for the aging effect in this environment. The staff evaluations of the One-Time Inspection and
 
Water Chemistry Control Programs are in SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively.
The staff's evaluations found that the applicant had identified the appropriate AMPs for the materials and environment associated with the above components in the NMP2 low pressure core spray system On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the low
 
pressure core spray system components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3.2B.2.3.4  Engineered Safety Features Systems NMP2 Reactor Core Isolation Cooling System
- Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-4 The staff evaluated the following items in the NMP2 reactor core isolation cooling system
* Cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).The
 
applicant stated that this environment is not in the GALL Report for this
 
material-component combination (Note G). (By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant deleted this item from the table.
* Cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with operating temperatures
 
> 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c). The applicant stated that this environment is not in the GALL Report
 
for this material-component combination (Note G). (By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant deleted this item from the table)
* Cracking and loss of material of martensitic precipitation hardenable and superferritic stainless steel closure bolting for non-borated water systems with temperatures > 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program. The applicant
 
stated that this environment is not in the GALL Report for this material-component
 
combination. (Note G).
3-276
* Cracking of wrought austenitic stainless steel condensing chambers in a treated water or steam, temperature > 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs. The applicant stated that this aging effect is not in the
 
GALL Report for this component, material, and environment combination (Note H).
* Cumulative fatigue damage of wrought austenitic stainless steel piping and fittings in a treated water or steam, temperature > 482 &deg;F, environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c). The applicant stated that this material is not in the
 
GALL Report for this component (Note F). (By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant added note 10 stating that this item applies to small
 
bore piping not included in the ISI Testing Program).
* Cracking and loss of strength of polymeric external surfaces in an air environment managed by the Preventive Maintenance Program. The applicant stated that this aging
 
effect is not in the GALL Report for this component, material, and environment
 
combination (Note H).
* Cracking in wrought austenitic stainless steel restriction orifices in a treated water, temperature > 212 &deg;F, but < 482 &deg;F, environment managed by the One-Time inspection and Chemistry Control Programs. The applicant stated that this aging effect is not in the
 
GALL Report for this component, material, and environment combination (Note H).
* Cracking of wrought austenitic stainless steel restriction orifices in a treated water or steam, temperature > 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs. The applicant stated that this aging effect is not in the
 
GALL Report for this component, material, and environment combination (Note H).
The applicant deleted cumulative fatigue damage of carbon or low alloy steel (yield strength
> 100 ksi) bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found the deletion acceptable because
 
cumulative fatigue damage is not an applicable AERM for this component.
The applicant deleted cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with operating temperatures
 
> 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found the
 
deletion acceptable because cumulative fatigue damage is not an applicable AERM for this
 
component.
The applicant stated that cracking and loss of material of martensitic precipitation hardenable and superferritic stainless steel closure bolting for non-borated water systems with temperatures
 
> 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program, is not in the GALL Report for this material-component combination (Note G). The staff concurred with this
 
statement. The staff found the management of the aging effects acceptable as stated in the
 
evaluation of the Bolting Integrity Program in SER Section 3.0.3.2.23.
The applicant stated that cracking of wrought austenitic stainless steel condensing chambers in a treated water or steam, temperature > 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs is not in the GALL Report for this component, material, and environment combination (Note H). The staff concurred with this statement. The
 
staff evaluation of the management of the aging effects is in RAI 3.2-7 (SER 3-277 Section 3.2A.2.3.2). The staff found these AMPs appropriate and acceptable for the aging effect in this environment. The staff evaluations of the One-Time Inspection and Water Chemistry Control Programs is in SER Sections 3.0.3.1.4 and 3.0.3.2.2 respectively.
The applicant stated that cumulative fatigue damage of wrought austenitic steel piping and fittings in a treated water or steam, temperature > 482 &deg;F, environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) is not in the GALL Report for this component (Note F). The staff concurred with this statement. By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant added note 10 stating that this item applies to small bore
 
piping not included in the ISI Program. This component also is not evaluated in ALRA
 
Section 4.3. The staff found the aging management of cumulative fatigue damage of small bore
 
piping by TLAA in accordance with 10 CFR 54.21(c) reasonable and acceptable.
The applicant stated that cracking and loss of strength of polymeric external surfaces in an air environment managed by the Preventive Maintenanc e Program is not in the GALL Report for this component, material, and environment combination (Note H). The staff concurred with this
 
statement. The staff requested additional information about the Preventive Maintenance
 
Program tests and inspections to manage the aging effects for this component. In its response
 
dated November 15, 2005, the applicant stated:
The polymer components in the NMP2 RCIC System are expansion joints between RCIC System Piping and the Condensate Storage Tank. They are
 
fabricated of butyl rubber with polyester fabric and metal reinforcement.
 
The PM Program methods of inspection associated with these expansion
 
joints are visual, dimensional, and durometer readings as follows:
* Inspection of the expansion joints is performed every two years.
* Replacement of the components is scheduled for every 20 years.
The PM Program acceptance criteria for the inspections are the following:    Visual Inspection
* No excessive and deep cracking or cuts of outer cover exposing reinforcing wire, body rings or fabric.
* No blistering or local areas of deformation or ply separation.
* No leakage or weeping through bellows or at flange connections.
* No soft or gummy areas.
* No mechanical damage due to maintenance or operating activity.
* If expansion joint has a liner, liner is not damaged.
* Structural members and attachment hardware are not damaged and maintain structural integrity.
Dimensional Inspection
* Face to face dimensions are within design tolerances.
* Durometer readings between 50 - 80 (Shur scale).
3-278 The inspections and acceptance criteria for the expansion joints are based on approved vendor manuals.
The staff found the applicant's response reasonable and acceptable because the Preventive Maintenance Program tests and inspections are consistent with industry practice and vendor
 
recommendations. The staff found the management of the aging effects in polymeric
 
components by the Preventive Maintenance Program acceptable.
The applicant stated that cracking in wrought austenitic stainless steel restriction orifices in a treated water, temperature > 212 &deg;F, but < 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs is not in the GALL Report for this component, material, and environment combination (Note H).The staff concurred with this statement. The
 
staff review of the management of the aging effects is in RAI 3.2-7 (In SER Section 3.2A.2.3.2).
 
The staff found these AMPs appropriate and acceptable for the aging effect in this environment.
 
The staff evaluations of the One-Time Inspection and Water Chemistry Control Programs are in
 
SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.
The applicant stated that cracking of wrought austenitic stainless steel restriction orifices in a treated water or steam, temperature > 482 &deg;F, environment managed by the One-Time Inspection and Chemistry Control Programs is not in the GALL Report for this component, material, and environment combination (Note H). The staff concurred with this statement. The
 
staff review of the management of the aging effects is in RAI 3.2-7 (In SER Section 3.2A.2.3.2).
 
The staff found these AMPs appropriate and acceptable for managing the aging effect in this
 
environment. The staff evaluations of the One-Time Inspection and Water Chemistry Control Programs are provided in SER Sections 3.0.3.1.4 and 3.0.3.2.2, respectively.
The staff's evaluations found that the applicant had identified the appropriate AMPs for the materials and environment associated with the NMP2 reactor core isolation cooling system
 
components.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the
 
reactor core isolation cooling system components will be adequately managed so that the
 
intended functions will be maintained consistent with the CLB for the period of extended
 
operation, as required by 10 CFR 54.21(a)(3).
3.2B.2.3.5  Engineered Safety Features Syst ems NMP2 Residual Heat Removal System -
Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-5 The staff reviewed the following ALRA items for the NMP2 residual heat removal system:
* Cumulative fatigue damage of carbon or low alloy steel (yield strength >
100 ksi) bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c).The applicant stated that
 
this environment is not in the GALL Report for this material-component combination (Note
 
G). (By NMPIL 2005 attachment 2 dated December 1, 2005, the applicant deleted this item
 
from the table) 3-279
* Cracking and loss of material of martensitic precipitation hardenable and superferritic stainless steel closure bolting for non-borated water systems with temperatures > 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program. The applicant stated
 
that this environment is not in the GALL Report for this material-component combination (Note G)
* Cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with
 
10 CFR 54.21(c).The applicant stated that this environment is not in the GALL Report for
 
this material-component combination (Note G). (By NMPIL 2005 attachment 2 dated
 
December 1, 2005, the applicant deleted this item from the table)
The applicant deleted cumulative fatigue damage of carbon or low alloy steel (yield strength
> 100 ksi) bolting for non-borated water systems with operating temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found the deletion acceptable because
 
cumulative fatigue damage for this component is not an applicable AERM.
The applicant stated that for cracking and loss of material of martensitic precipitation hardenable and superferritic stainless steel closure bolting for non-borated water systems with
 
temperatures > 212 &deg;F, leaking fluid environment managed by the Bolting Integrity Program this environment is not in the GALL Report for this material-component combination (Note G). The
 
staff concurred with this statement. The staff found the management of the aging effects
 
acceptable as discussed in the evaluation of the Bolting Integrity Program in SER
 
Section 3.0.3.2.23.
The applicant deleted cumulative fatigue damage of martensitic precipitation hardenable and superferritic stainless steel bolting for non-borated water systems with operating
 
temperatures > 212 &deg;F, leaking fluid environment managed by TLAA evaluated in accordance with 10 CFR 54.21(c) by NMPIL 2005 attachment 2 dated December 1, 2005. The staff found
 
the deletion acceptable because cumulative fatigue damage for this component is not an
 
applicable AERM.
The staff's evaluations found that the applicant had identified the appropriate AMPs for the materials and environment associated with the above components in the NMP2 residual heat removal system.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the
 
residual heat removal system components will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).
3.2B.2.3.6  Engineered Safety Features Syst ems NMP2 Standby Gas Treatment System -
Summary of Aging Management Evaluation - ALRA Table 3.2.2.B-6 The staff reviewed the following ALRA items for the NMP2 standby gas treatment system 3-280
* Martensitic precipitation hardenable and super ferritic stainless steel bolting in an air environment for which the applicant has assigned no aging effect.
* Loss of material for wrought austenitic stainless steel heaters in an air with moisture orwetting temperature < 140 &deg;F environment m anaged by the One-Time Inspection Program.
The applicant stated that this aging effect is not in the GALL Report for this component, material, and environment combination (Note H).
* Loss of material for wrought austenitic stainless steel piping and fittings in an air withmoisture or wetting temperature < 140 &deg;F environment managed by the One-Time
 
Inspection Program. The applicant stated that this aging effect is not in the GALL Report for
 
this component, material, and environment combination (Note H).
* Loss of material for aluminum and al uminum alloyed with manganese, magnesium plussilicon valves in an air with moisture or wetting temperature < 140 &deg;F environment managed
 
by One-Time Inspection Program. The applicant stated that this aging effect is not in the
 
GALL Report for this component, material, and environment combination (Note H).
* Loss of material for wrought austenitic stainless steel valves in an air with moisture orwetting temperature < 140 &deg;F environment m anaged by One-Time Inspection Program. The applicant stated that this aging effect is not in the GALL Report for this component, material, and environment combination (Note H).
The staff requested that the applicant justify assigning no aging effect to the martensitic precipitation hardenable and superferritic stainless steel bolting. As addressed in RAI 3.2.16 the
 
applicant stated:
The material specification for the bolting corresponding to the ALRA line item for martensitic precipitation hardened and superferritic stainless steel bolting in air (temperature < 140 &deg;F) environments is ASTM A193 Grade B6, which has a minimum specified tempering temperature of 1100 &deg;F. Material with this heat treatment would
 
have a yield strength of approximately 100 ksi. The material specification for the
 
bolting corresponding to the ALRA line items for carbon or low allow steel (yield strength > 100 ksi) bolting in a moist air (temperature < 140 &deg;F) environment is ASTM A193 Grade B7, which has a minimum tempering temperature of 1100 &deg;F. Yield
 
strengths for Type 4140 steel bar, which is a steel grade that meets A193 chemical requirements, are below 150 ksi when tempered at 1100 &deg;F. Therefore, for both
 
material types, the material yield strengths will not exceed 150 ksi.GALL Report Section XI.M18, Bolting Integrity, under the "parameters monitored/inspected" program element states that cracking must be monitored only for bolts with yield strengths
 
exceeding 150 ksi. Therefore, that cracking is not identified as an aging effect for the subject
 
bolts is not inconsistent with the GALL Report.
Loss of preload typically would not be an aging effect requiring management for bolting in low temperature systems. The GALL Report specifies only loss of preload as an aging effect
 
requiring management for components in the reactor vessel and internals and reactor coolant
 
pressure boundary. For closure bolting in ESF systems the GALL Report addresses only carbon
 
and low alloy steel bolting in high-pressure or high temperature systems. The bolting with the
 
material-environment combinations of carbon or low alloy steel (yield strength > 100 ksi) and
 
martensitic precipitation hardened and superferritic stainless steel bolting in air are not in high
 
temperature or high pressure systems. Furthermore, the GALL Report does not identify loss of 3-281 preload even for ESF bolts in high temperature, high pressure systems. Therefore, the determination that loss of preload does not apply to the subject bolts is consistent with the
 
GALL Report.
The staff found the applicant's assessment reasonable, acceptable, and consistent with the GALL Report.
In a-RAI 3.2.2.B-1 dated November 22, 2005, the staff requested that the applicant provide assurance that a one-time inspection alone is adequate to manage the aging effect of loss of
 
material for wrought austenitic stainless steel heaters in an air with moisture or wetting temperature < 140 &deg;F environment managed by t he One-Time Inspection Program. In addition the staff requested the applicant to discuss the specifics of the tests and inspections for these
 
components.
In its response, letter dated December 5, 2005, the applicant stated:
As in the response to RAI 3.4.2.B-2, for the identified components fabricated of either stainless steel (SS) or alloyed aluminum (high aluminum, low alloy content) in a low
 
temperature, moist air environment, it is considered unlikely that the loss of material
 
aging effect will occur. SS in this mild air environment (containment environment) where any moisture would have extremely low concentrations of halides would not
 
exhibit aging effects. Aluminum forms a prot ective passive layer in mild environments that protects the base metal from further corrosion. The One-Time Inspection Program
 
activities will utilize visual, volumetric, and other inspection techniques consistent with industry practices to provide a means of verifying that aging management is not
 
occurring or is progressing at such a slow rate that the intended function of the
 
components would not be adversely affected.
The staff found the applicant's response reasonable and acceptable because the applicant explained that the aging effect is unlikely to occur in this environment for this component. The
 
staff therefore considered the One-Time Inspection Program adequate for managing the aging
 
effect in this environment. The staff's evaluation of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff also concurred with the applicant's assessment that this aging effect
 
is not in the GALL Report for this component, material, and environment combination (Note H).
The staff found reasonable and acceptable as stated in a-RAI 3.2.2.B-1 management of loss of material for wrought austenitic stainless steel piping and fittings in an air with moisture or wetting temperature < 140 &deg;F environment by t he One-Time Inspection Program. The staff's evaluation of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff also
 
concurred with the applicant's assessment that this aging effect is not in the GALL Report for
 
this component, material, and environment combination (Note H).
The staff found reasonable and acceptable as stated in a-RAI 3.2.2.B-1 management of loss of material for wrought austenitic stainless steel valves in an air with moisture or wetting temperature < 140 &deg;F environment by the One-Ti me Inspection Program. The staff's evaluation of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff also concurred with
 
the applicant's assessment that this aging effect is not in the GALL Report for this component, material, and environment combination (Note H).
3-282 The staff's evaluation of loss of material fo r aluminum and aluminum alloyed with manganese,magnesium plus silicon valves in an air with moisture or wetting temperature < 140 &deg;F, environment managed by One-Time Inspection Progr am is in a-RAI 3.2.2.B-1. The staff's evaluation of the One-Time Inspection Program is in SER Section 3.0.3.1.4. The staff found it
 
reasonable and acceptable. The staff also concurred with the applicant's assessment that this
 
aging effect is not in the GALL Report for this component, material, and environment
 
combination (Note H).
The staff's evaluations found that the applicant had identified the appropriate AMPs for the materials and environment of the NMP2 standby gas treatment system components.
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant demonstrated that the aging effects associated with the standby
 
gas treatment system components will be adequat ely managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).
Conclusion. On the basis of its review, the staff found that the applicant appropriately evaluated AMR results involving material, environment, AERMs, and AMP combinations that are not
 
evaluated in the GALL Report. The staff found that the applicant had demonstrated that the
 
effects of aging will be adequately managed so that the intended functions will be maintained
 
consistent with the CLB for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).
3.2B.3  Conclusion the staff concludes that there is reasonable assurance that the applicant had provided sufficient information to demonstrate that the effects of aging for the NMP2 ESF systems components that are 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 also reviewed the applicable USAR supplement program summaries and concludes that they adequately describe the AMPs credited for managing aging of the ESF systems, as
 
required by 10 CFR 54.21(d).3.3  Aging Management of Auxiliary Systems3.3A  NMP1 Aging Management of Auxiliary Systems This section of the SER documents the staff's review of the applicant's AMR results for the
 
auxiliary systems components and component groups associated with the following NMP1systems:
* circulating water system
* city water system
* compressed air systems
* containment systems
* control room HVAC system 3-283
* diesel generator building ventilation system
* emergency diesel generator system
* fire detection and protection system
* hydrogen water chemistry system
* liquid poison system
* miscellaneous non contaminated vents and drains system
* neutron monitoring system
* radioactive waste disposal building HVAC system
* radioactive waste system
* reactor building closed loop cooling water system
* reactor building HVAC system
* reactor water cleanup system
* sampling system
* service water system
* shutdown cooling system
* spent fuel pool filtering and cooling system
* turbine building closed loop cooling water system
* turbine building HVAC system
* electric steam boiler system
* makeup and demineralizer system3.3A.1  Summary of Technical Information in the Amended Application In ALRA Section 3.3, the applicant provided AMR results for the aux iliary systems components and component groups. In ALRA Table 3.3.1.A, "NMP1 Summary of Aging Management
 
Programs for the Auxiliary Systems Evaluat ed in Chapter VII of NUREG-1801," the applicant provided a summary comparison of its AMRs wi th the AMRs evaluated in the GALL Report for the auxiliary systems co mponents and component groups.
The applicant's AMRs incorporated applicable operating experience in the determination of AERMs. These reviews included evaluation of plant-specific and industry operating experience.
 
The plant-specific evaluation included reviews of condition reports and discussions with
 
appropriate site personnel to identify AERMs. The applicant's review of industry operating
 
experience included a review of the GALL Report and operating experience issues identified
 
since the issuance of the GALL Report.
3.3A.2  Staff Evaluation The staff reviewed ALRA Section 3.3 to determine if the applicant provided sufficient information to demonstrate that the effects of aging for the auxiliary systems components that are within the scope of license renewal and subject to an AMR will be adequately managed so that the
 
intended functions will be maintained consistent with the CLB for the period of extended
 
operation, as required by 10 CFR 54.21(a)(3).
The staff performed an onsite audit of AMRs to confirm the applicant's claim that certain identified 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 ALRA was applicable and that the applicant had identified the appropriate GALL AMRs.
 
The staff's evaluations of the AMPs are documented in SER Section 3.0.3. Details of the staff's 3-284 audit evaluation are documented in the Audit and Review Report and are summarized in SER Section 3.3A.2.1.
In the onsite audit, the staff also selected AMRs that were consistent with the GALL Report and for which further evaluation is recommended. The staff confirmed that the applicant's further
 
evaluations were consistent with the acceptance criteria in SRP-LR Section 3.3.2.2. The staff's
 
audit evaluations are documented in the Audit and Review Report and are summarized in SER
 
Section 3.3A.2.2.
In the onsite audit, the staff also conducted a technical review of the remaining AMRs that were not consistent with, or not addressed in, the GALL Report. The audit and technical review
 
included evaluating whether all plausible aging effects were identified and evaluating whether
 
the aging effects listed were appropriate for the combination of materials and environments
 
specified. The staff's audit evaluations are documented in the Audit and Review Report and are
 
summarized in SER Section 3.3A.2.3. The staff's evaluation of its technical review is also
 
documented in SER Section 3.3A.2.3.
Finally, the staff reviewed the AMP summary descriptions in the UFSAR supplement to ensure that they provided an adequate description of the programs credited with managing or
 
monitoring aging for the aux iliary systems components.
Table 3.3A-1 below provides a summary of t he staff's evaluation of NMP1 components, aging effects and mechanisms, and AMPs listed in ALRA Section 3.3, that are addressed in the GALL
 
Report.Table 3.3A-1  Staff Evaluation for NMP1 Auxiliary Systems Components in the GALL ReportComponent GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation Components in spent fuel pool
 
cooling and cleanup (Item Number
 
3.3.1.A-01)
Loss of material due to general, pitting, and crevice
 
corrosion Water chemistry and one-time
 
inspection Water Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.3A.2.2.1)
Linings in spent fuel pool cooling and cleanup system;
 
seals and collars in ventilation systems (Item Number
 
3.3.1.A-02)
Hardening, cracking and loss of strength
 
due to elastomer
 
degradation; loss of material due to wearPlant specificPreventive Maintenance
 
Program (B2.1.32) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.3A.2.2.2)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-285 Components in load handling, chemical
 
and volume control system (PWR), and reactor water
 
cleanup and shutdown cooling systems (older
 
BWR)
(Item Number
 
3.3.1.A-03)
Cumulative fatigue damageTLAA, evaluated inaccordance with 10 CFR 54.21(c)TLAANo TLAA for components in load handling systems-does not meet TLAA
 
criteria (See Section
 
3.3A.2.1.1)
Heat exchangers inreactor water cleanup system (BWR); high
 
pressure pumps in
 
chemical and
 
volume control system (PWR)
(Item Number
 
3.3.1.A-04)
Crack initiation andgrowth due to SCC
 
or crackingPlant specificWater Chemistry Control Program (B2.1.2), Preventive
 
Maintenance
 
Program (B2.1.32) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.3A.2.2.4)
Components inventilation systems, diesel fuel oil system, and emergency diesel generator systems;
 
external surfaces of
 
carbon steel
 
components (Item Number
 
3.3.1.A-05)
Loss of material due to general, pitting, and crevice
 
corrosion, and MICPlant specificClosed-CycleCooling Water System Program (B2.1.11), Fire Water System
 
Program (B2.1.17),
One-Time Inspection Program (B2.1.20),
10 CFR 50 Appendix J
 
Program (B2.1.26),
Preventive
 
Maintenance
 
Program (B2.1.32),
Systems Walkdown
 
Program (B2.1.33)Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.3A.2.2.5)
Components in reactor coolant
 
pump oil collect system of fire
 
protection (Item Number
 
3.3.1.A-06)
Loss of material due to galvanic, general, pitting, and crevice
 
corrosionOne-time inspectionNoneNot applicable (See Section 3.3A.2.2.6)
Diesel fuel oil tanks in diesel fuel oil system and emergency diesel generator system (Item Number
 
3.3.1.A-07)
Loss of material due to general, pitting, and crevice
 
corrosion, MIC, and
 
biofoulingFuel oil chemistry and one-time
 
inspectionFuel Oil Chemistry Program (B2.1.18),
One-Time Inspection Program (B2.1.20) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.3A.2.2.7)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-286 Piping, pump casing, and valve body and bonnets in shutdown cooling system (older BWR)
(Item Number
 
3.3.1.A-08)
Loss of material due to pitting and
 
crevice corrosion Water chemistry and one-time
 
inspection Water Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20) Consistent withGALL, which
 
recommends further
 
evaluation.
One-Time Inspection Program
 
is used for further
 
evaluation (See
 
Section 3.3A.2.2.1)
Heat exchangers in chemical and
 
volume control system (Item Number
 
3.3.1.A-09)
Crack initiation andgrowth due to SCC and cyclic loading Water chemistry and a plant-specific
 
verification programNoneNot applicable (See Section 3.3A.2.2.9)
Neutron absorbing sheets in spent fuel
 
storage racks (Item Number
 
3.3.1.A-10)
Reduction of neutron absorbing capacity and loss of
 
material due to
 
general corrosion (Boral, boron steel)Plant specificWater Chemistry Control Program (B2.1.2), One-Time
 
Inspection Program (B2.1.20)(See Section 3.3A.2.2.10)New fuel rack assembly (Item Number
 
3.3.1.A-11)
Loss of material due to general, pitting, and crevice
 
corrosion Structures monitoringNoneNot applicable.The new fuel rackassembly is not in
 
scope.Neutron absorbing sheets in spent fuel
 
storage racks (Item Number
 
3.3.1.A-12)
Reduction of neutron absorbing capacity due to
 
Boraflex degradation Boraflex monitoring Boraflex Monitoring Program (B2.1.12)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Spent fuel storage racks and valves in
 
spent fuel pool
 
cooling and cleanup (Item Number
 
3.3.1.A-13)
Crack initiation andgrowth due to stress
 
corrosion crackingWater chemistryWater Chemistry Control Program (B2.1.2) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Closure bolting and external surfaces of
 
carbon steel and low-alloy steel
 
components (Item Number
 
3.3.1.A-14)
Loss of material due to boric acid
 
corrosionBoric acid corrosionSystems Walkdown Program (B2.1.33),
Bolting Integrity
 
Program (B2.1.36) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1.7)
Components in or serviced by closed-cycle cooling water system (Item Number
 
3.3.1.A-15)
Loss of material due to general, pitting, and crevice
 
corrosion, and MICClosed-cyclecooling water systemClosed-CycleCooling Water System Program (B2.1.11)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-287 Cranes includingbridge and trolleys and rail system in
 
load handling system (Item Number
 
3.3.1.A-16)
Loss of material due to general corrosion and wear Overhead heavy load and light load handling systems Inspection of Overhead Heavy
 
Load and Light
 
Load Handling Systems Program (B2.1.13)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components in or serviced by open-cycle cooling water systems (Item Number
 
3.3.1.A-17)
Loss of material due to general, pitting, crevice, and
 
galvanic corrosion, MIC, and biofouling;
 
buildup of deposit
 
due to biofoulingOpen-cycle coolingwater systemOpen-Cycle CoolingWater Program (B2.1.10);
One-Time Inspection Program (B2.1.20);
 
Preventive
 
Maintenance
 
Program (B2.1.32) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Buried piping and fittings (Item Number
 
3.3.1.A-18)
Loss of material due to general, pitting, and crevice
 
corrosion, and MIC Buried piping and tanks surveillance or Buried piping and tanks inspection Buried Piping andTanks Inspection
 
Program (B2.1.22) Consistent withGALL, which
 
recommends further
 
evaluation (See
 
Section 3.3A.2.2.11)
Components in compressed air system (Item Number
 
3.3.1.A-19)
Loss of material due to general and
 
pitting corrosion Compressed air monitoring Compressed Air Monitoring Program (B2.1.14), Bolting Integrity Program (B2.1.36)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components (doors and barrier
 
penetration seals)
 
and concrete
 
structures in fire
 
protection (Item Number
 
3.3.1.A-20)
Loss of material dueto wear; hardening
 
and shrinkage due to weatheringFire protectionFire Protection Program (B2.1.16)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components inwater-based fire
 
protection (Item Number
 
3.3.1.A- 21)
Loss of material due to general, pitting, crevice, and
 
galvanic corrosion, MIC, and biofoulingFire water systemFire Water System Program (B2.1.17)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components indiesel fire system (Item Number
 
3.3.1.A-22)
Loss of material due to galvanic, general, pitting, and crevice
 
corrosionFire protection and fuel oil chemistryNoneNot applicable. Fueloil supply lines do
 
not have this aging
 
effect.
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-288Tanks in diesel fueloil system (Item Number
 
3.3.1.A-23)
Loss of material due to general, pitting, and crevice
 
corrosion Aboveground carbon steel tanksNoneNot applicable.
Diesel fuel oil tanks
 
are not supported
 
on earthen or
 
concrete foundations Closure bolting (Item Number
 
3.3.1.A-24)
Loss of material due to general
 
corrosion; crack initiation and growth due to cyclic loading
 
and SCCBolting integrityB olting Integrity Program (B2.1.36)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components incontact with sodium
 
pentaborate solution in standby liquid control system (BWR)
(Item Number
 
3.3.1.A-25)
Crack initiation andgrowth due to SCCWater chemistryWater Chemistry Control Program (B2.1.2) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components inreactor water cleanup system (Item Number
 
3.3.1.A-26)
Crack initiation andgrowth due to SCC
 
and IGSCCReactor watercleanup system
 
inspection Water Chemistry Control Program (B2.1.2), BWR
 
Reactor Water Cleanup System
 
Program (B2.1.15),
One-Time Inspection Program (B2.1.20) Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components inshutdown cooling system (older BWR)
(Item Number
 
3.3.1.A-27)
Crack initiation andgrowth due to SCC BWR stress corrosion cracking and water chemistry BWR Stress Corrosion Cracking
 
Program (B2.1.6),
Water Chemistry
 
Program (B2.1.2)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components inshutdown cooling system (older BWR)
(Item Number
 
3.3.1.A-28)
Loss of material due to pitting and
 
crevice corrosion, and MICClosed-cyclecooling water systemClosed-CycleCooling Water
 
Program (B2.1.11)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)Components (aluminum bronze, brass, cast iron, cast steel) in open-cycle and closed-cycle cooling water systems, and
 
ultimate heat sink (Item Number
 
3.3.1.A-29)
Loss of material due to selective leaching Selective leaching of materialsClosed-CycleCooling Water
 
Program (B2.1.11);
Open-Cycle Cooling Water Program (B2.1.10); Selective
 
Leaching of
 
Materials Program (B2.1.21)Consistent withGALL, which
 
recommends no
 
further evaluation (See Section
 
3.3A.2.1)
Component GroupAging Effect/MechanismAMP in GALLReportAMP in ALRAStaff Evaluation 3-289Fire barriers, walls, ceilings, and floors
 
in fire protection (Item Number
 
3.3.1.A-30)
Concrete cracking and spalling due to freeze-thaw, aggressive chemical
 
attack, and reaction with aggregates;
 
loss of material due
 
to corrosion of
 
embedded steelFire protection and structures
 
monitoringNoneNot applicable.The plant-specific environment for
 
concrete structures
 
in fire protection
 
does not generate
 
the listed aging
 
effects.The staff's review of the NMP1 component groups followed one of several approaches. One approach, documented in SER Section 3.3A.2.1, discusses the staff's review of the AMR results
 
for components in the auxiliary systems that the applicant indicated are consistent with the GALL Report and do not require further evaluation. Another approach, documented in SER
 
Section 3.3A.2.2, discusses the staff's review of the AMR results for components in the auxiliary
 
systems that the applicant indicated are consistent with the GALL Report and for which further
 
evaluation is recommended. A third approach, documented in SER Section 3.3A.2.3, discusses
 
the staff's review of the AMR results for co mponents in the auxiliary systems that the applicant indicated are not consistent with, or not addressed in, the GALL Report. The staff's review of
 
AMPs that are credited to manage or monitor aging effects of the auxiliary systems components is documented in SER Section 3.0.3.3.3A.2.1  AMR Results That Are Consistent with the GALL Report Summary of Technical Information in the Amended Application. In ALRA Section 3.3.2.A, the applicant identified the materials, environments, and AERMs. The applicant identified the
 
following programs that manage the aging effects related to the auxiliary systems components:
* ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program
* Water Chemistry Control Program
* Flow-Accelerated Corrosion Program
* Open-Cycle Cooling Water System Program
* Closed-Cycle Cooling Water System Program
* Compressed Air Monitoring Program
* BWR Reactor Water Cleanup System Program
* Fire Protection Program
* Fire Water System Program
* Fuel Oil Chemistry Program
* One-Time Inspection Program
* Selective Leaching of Materials Program
* Buried Piping and Tanks Inspection Program
* 10 CFR 50 Appendix J Program
* Preventive Maintenance Program
* Systems Walkdown Program
* Bolting Integrity Program 3-290 Staff Evaluation. In ALRA Tables 3.3.2.A-1 through 3.3.2.A-25, the applicant provided a summary of AMRs for the auxiliary system s components, and identified which AMRs it considered to be consistent with the GALL Report.
For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report does not recommend further
 
evaluation, the staff performed an audit and review to determine whether the plant-specific
 
components contained in these GALL Report component groups were bounded by the GALL
 
Report evaluation.
The applicant provided a note for each AMR line item. The notes indicate how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with
 
Notes A through E, which indicate that 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report and the 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 AMP
 
identified in the GALL Report. The staff audited these line items to verify consistency with the
 
GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been
 
reviewed and accepted by the staff. The staff also determined whether the AMP identified by the
 
applicant was consistent with the AMP identified in the GALL Report 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 AMP identified by the GALL Report. This note indicates that the applicant
 
was unable to find a listing of some system components in the GALL Report. However, the
 
applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was 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 AMP identified in the GALL Report. 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. The staff verified whether
 
the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The
 
staff also determined whether the AMP identified by the applicant was consistent with the AMP
 
identified in the GALL Report 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 a different agi ng management program is credited. The staff audited these line items to verify consistency with the GALL Report. The staff also determined 3-291 whether the identified AMP would manage the aging effect consistent with the AMP identified by the GALL Report and whether the AMR was valid for the site-specific conditions.
The staff conducted an audit and review of the information provided in the ALRA, as documented in the Audit and Review 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
 
ALRA was applicable and that the applicant identified the appropriate GALL Report AMRs. The
 
staff's evaluation is discussed below.
3.3A.2.1.1  Cumulative Fatigue Damage
 
In ALRA Table 3.3.1.A Item 3.3.1.A-03 the applicant stated that cumulative fatigue damage is managed using a TLAA.
As documented in the Audit and Review Report, the staff asked the applicant to clarify the statement on Table 3.3.1.A (page 3.3-86) of the ALRA that NMP has no TLAA for components
 
in load handling systems. The staff requested the applicant to justify technically why this aging
 
effect and aging effect mechanism was not applied to NMP. In its letter dated December 1, 2005, the applicant stated that this issue has been screened against the six criteria for a TLAA.
 
Furthermore in this letter the applicant stated that the operating cycles for the cranes did not
 
meet the criteria for a TLAA because (1) there were no actual calculations or analyses in the
 
CLB projecting the number of operating cycles and (2) for cranes designed to CMAA-70 an
 
estimate of the number of possible operating cycles in 60 years, a substantial fraction (40-95
 
percent) of the crane maximum rated load, was a very small percentage of the allowable
 
number of cycles (for the NMP2 reactor building polar crane 1500 cycles versus a minimum
 
allowable number of cycles of 100,000). Therefore, generating a formal calculation of operating
 
cycles for 60 years would not result in any m eaningful limitations on the use of the crane (i.e., the calculation would not meet criteria #4 for a TLAA from 10 CFR 54.3 which is, "Were
 
determined to be relevant by the licensee in making a safety determination.")
The staff reviewed the applicant's response and found that it adequately justified having no TLAA for components in load handling systems.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism, as recommended by the GALL Report.
3.3A.2.1.2  Crack Initiation and Growth Due to SCC or Cracking
 
In the discussion section of ALRA Table 3.3.1.A, Item 3.3.1.A-04, the applicant stated that for stainless steel heat exchangers aging management is by the Water Chemistry Control Program and Preventive Maintenance Program; however , as documented in the Audit and Review Report, the staff noted that the applicant has applied ALRA Table 3.3.1, Item 3.3.1.A-04 to
 
manage cracking in wrought austenitic stainless steel in a treated water or steam environment
 
with temperatures > 140 &deg;F < 212 &deg;F using its Water Chemistry Control Program and One-Time Inspection Program. The staff asked the applicant to identify the AMPs to be applied. In a letter
 
dated December 1, 2005, the applicant stated that ALRA Table 3.3.1.A, Item 3.3.1.A-04 would
 
be revised to state that further evaluation is documented in Appendices B2.1.2 (Water
 
Chemistry Control Program) and B2.1.20 (One-Time Inspection Program).
3-292 The staff reviewed the applicant's response and found it consistent with the GALL Report and therefore acceptable.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism, as recommended by the GALL Report.
3.3A.2.1.3  Loss of Material Due to General, Pitting, and Crevice Corrosion, and MIC
 
As documented in the Audit and Review Report, the staff noted that the applicant had cited ALRA Table 3.3.1.A, Item 3.3.1.A-15 a number of times and had assigned Notes A, B, C, or D even though no exception to GALL AMP XI.M21, "Closed-Cycle Cooling Water System," had been taken in NMP AMP B2.1.11, "Closed-Cycl e Cooling Water System Program." The staff requested the applicant to clarify the basis for the assignment of Notes B and D. In a letter
 
dated December 1, 2005, the applicant stated that the notes are all A unless a GALL Report
 
Item does not address a specific component type, in which case the Note is C. Also the
 
applicant stated that the notes for pumps, tanks, and valves line items referencing ALRA
 
Table 3.3.1.A-15 (three on pages 3.3-137, 3.3-138, and 3.3-139) had been revised from Note B
 
to Note A. The applicant removed the GALL Report item and Table 1 item, and replaced Note E
 
with Note H for gray cast iron pumps in ALRA Tables 3.2.2.A-1 (page 3.2-38) and 3.3.2.A-21 (page 3.3-197). Finally, the applicant stated in this letter that there is also reference to this Table 1 Item for GCI HXs in ALRA Table 3.3.2.A-7 and that Note D should have been Note C because the component is a heat exchanger (HX) instead of a pump. The staff reviewed the
 
applicant's response and found it acceptable because the applicant had assigned the
 
appropriate notes to the AMR line items.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
3.3A.2.1.4  Loss of Material Due to General Corrosion and Wear
 
As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.5.2.A-4 (page 3.5-74) for component type refueling platform and aging effect and aging effect
 
mechanism loss of material the Table1 line item shown is 3.3.1.B-16. The staff asked the
 
applicant to explain why a NMP2 line item is shown with an NMP1 component type.
In its letter dated December 1, 2005, the applicant stated that the reference is an error. For ALRA Table 3.5.2.A-4 with line item component type refueling platform and aging effect and
 
aging effect mechanism loss of material the Table 1 reference was changed from Item
 
3.3.1.B-16 to Item 3.3.1.A-16.
The staff reviewed the applicant's response and found the correction of the reference to ALRA Table 3.3.1.A, Item 3.3.1.A-16 acceptable.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
3.3A.2.1.5  Loss of Material Due to Wear; Hardening and Shrinkage Due to Weathering
 
In ALRA Table 3.5.2.A-1 the applicant referenced ALRA Table 3.3.1.A, Item 3.3.1.A-20.
3-293 As documented in the Audit and Review Report, the staff noted that for component type doors and aging effect and aging effect mechanism loss of material the Note shown is C, indicating
 
that the NMP AMP is consistent with the GA LL Report AMP; however, the AMP shown is NMP AMP B2.1.16, "Fire Protection Program," for which the applicant takes some exceptions to the GALL AMP XI.M26, "Fire Protection." The staff asked the applicant to explain why a Note C was
 
shown instead of a Note D. This request also applied to ALRA Table 3.5.2.A-6 (page 3.5-76),
ALRA Table 3.5.2.A-7 and ALRA Table 3.5.2.A-11 for component type doors and aging effect/
 
mechanism loss of material managed by the applicant's Fire Protection Program.
In its letter dated December 1, 2005, the applicant stated that the note entry should be Note D instead of C. Note C was changed to Note D for ALRA Tables 3.5.2.A-11, 3.5.2.A-6, and
 
3.5.2.A-7 with AMR line item component doors and aging effect and aging effect mechanism
 
loss of material managed by the applicant's Fire Protection Program.
The staff reviewed the applicant's response and found it acceptable because the correction of Note C to Note D assigned the proper note to these AMR line items.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism, as recommended by the GALL Report.
3.3A.2.1.6  Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic Loading and SCC As documented in the Audit and Review Report, the staff noted that in ALRA Table 3.3.2.A-10 (page 3.3-147) for component type bolting and aging effect and aging effect mechanism of loss
 
of material or cracking, the Note shown is B, which indicates that, for the NMP AMP shown, the
 
applicant has taken an exception to the GALL Report AMP; however, the AMP shown is NMP AMP B2.1.36, "Bolting Integrity Program," for which the applicant claimed consistency with GALL AMP XI.M18, "Bolting Integrity." The staff asked the applicant to explain why a Note B
 
was shown instead of a Note A. In its letter dated December 1, 2005, the applicant stated that
 
Note B is appropriate because its letter dated September 15, 2005, had declared an exception
 
for the applicant's Bolting Integrity Program. The staff reviewed the applicant's response and
 
found the applicant correct and the appropriate note assigned to the AMR line items.
The staff's review found that the applicant appropriately addressed the aging effect and aging effect mechanism as recommended by the GALL Report.
3.3A.2.1.7  Loss of Material Due to Boric Acid Corrosion
 
In reviewing ALRA Table 3.3.1.A, Item 3.3.1-14, the staff noted that the applicant had credited the Bolting Integrity Program and Systems Wa lkdown Program. These AMPs are different from the AMP recommended by the GALL Report, GALL AMP XI.M10, "Boric Acid Corrosion."
The staff review and evaluations of the applicant's Bolting Integrity and Systems Walkdown Programs are documented in Sections 3.0.3.2.23 and 3.0.3.3.2 of this SER, respectively. The
 
staff found that the applicant's System Walkdown Program detects leakage and manages
 
material degradation through visual inspection and that the applicant's Bolting Integrity Program
 
monitors the potential leakage of sodium pentaborate solution on the liquid poison system
 
component bolting. The staff concludes that these AMPs will ensure detection of leakage before 3-294 a loss of intended function and manage adequately the loss of material due to boric acid corrosion.
The staff's review found that the applicant appropriately addressed the loss of material due to boric acid corrosion for closure bolting and external surfaces of carbon steel components.
Conclusion. The staff evaluated the applicant's claim of consistency with the GALL Report. The staff also reviewed information pertaining to the applicant's consideration of recent operating
 
experience and proposals for managing associated aging effects. On the basis of its review, the
 
staff concludes that there is reasonable assurance that the AMR results, which the applicant
 
claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL
 
Report. Therefore, the staff concludes that the applicant had 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 for the period of extended operation, as required by
 
10 CFR 54.21(a)(3).3.3A.2.2  AMR Results That are Consistent with the GALL Report, for Which Further Evaluation is Recommended Summary of Technical Information in the Amended Application. In Section 3.3.2.C of its supplemental letter to the ALRA, dated August 19, 2005, the applicant provided further
 
evaluation of aging management as recomm ended by the GALL Report for the auxiliary systems components. The applicant provided info rmation concerning how it will manage the following aging effects:
* loss of material due to general, pitting, and crevice corrosion
* hardening and cracking or loss of strength due to elastomer degradation or loss of material due to wear
* cumulative fatigue damage
* crack initiation and growth due to cracking or stress corrosion cracking
* loss of material due to general, microbiologically influenced, pitting, and crevice corrosion
* loss of material due to general, galvanic, pitting, and crevice corrosion
* loss of material due to general, pitting, crevice, and MIC and biofouling
* crack initiation and growth due to stress corrosion cracking and cyclic loading
* reduction of neutron-absorbing capacity and loss of material due to general corrosion
* loss of material due to general, pitting, crevice, and MIC Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends
 
further evaluation, the staff audited and reviewed the applicant's evaluation to determine
 
whether it adequately addressed the issues that were further evaluated. In addition, the staff
 
reviewed the applicant's further evaluations against the criteria contained in SRP-LR
 
Section 3.3.2.2. Details of the staff's audit are documented in the staff's Audit and Review
 
Report. The staff's evaluation of the aging effects is discussed in the following sections.
3.3A.2.2.1  Loss of Material Due to General, Pitting, and Crevice Corrosion 3-295 The staff reviewed Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.3.2.2.1.1.
In Section 3.3.2.C.1 of a letter dated August 19, 2005, the applicant addressed loss of material due to general, pitting, and crevice corrosion for components in the spent fuel pool cooling and
 
cleanup system. For NMP1 components in the s pent fuel pool cooling systems are managed by the combination of the Water Chemistry Control Program and One-Time Inspection Program.
SRP-LR Section 3.3.2.2.1.1 states that loss of material due to general, pitting, and crevice corrosion could occur in the channel head and access cover, tubes, and tubesheets of the heat
 
exchanger in the spent fuel pool cooling and cleanup system. The Water Chemistry Program
 
relies on monitoring and control of reactor water chemistry based on the EPRI guidelines of
 
BWRVIP-29, (TR-103515), "BWR Water Chemistry Guidelines - Normal and Hydrogen Water
 
Chemistry," to manage the effects of loss of material from general, pitting, or crevice corrosion;
 
however, high concentrations of impurities at cr evices and locations of stagnant flow conditions could cause general, pitting, or crevice corrosion. Therefore, the effectiveness of the Water
 
Chemistry Control Program should be verified to ensure no corrosion. The GALL Report
 
recommends further evaluation of programs to manage loss of material from general, pitting, and crevice corrosion to verify the effectivene ss of the applicant's Water Chemistry Control Program. A one-time inspection of select components at susceptible locations is an acceptable
 
method to ensure no corrosion and that the component's intended function will be maintained
 
during the period of extended operation.
The staff's review and evaluation of the applicant's Water Chemistry Control Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
In addition the staff reviewed Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005, against the criteria of SRP-LR Section 3.3.2.2.1.2.
In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant addressed loss of material due to pitting and crevice corrosion of components in the spent fuel cooling and cleanup system
 
and the shutdown cooling system of older BWRs.
SRP-LR Section 3.3.2.2.1.2 states that loss of material due to pitting and crevice corrosion could occur in the piping, filter housing, valve bodies, and shell and nozzles of the ion
 
exchanger in the spent fuel pool cooling and cleanup system and in the piping and pump casing
 
in the shutdown cooling system (older BWR). The Water Chemistry Control Program relies on monitoring and control of reactor water chemistry based on EPRI guidelines of BWRVIP-29 (TR-103515), "BWR Water Chemistry Guidelines - Normal and Hydrogen Water Chemistry," to
 
manage the effects of loss of material from pitting or crevice corrosion; however, high concentrations of impurities at crevices and locations of stagnant flow conditions could cause
 
pitting or crevice corrosion. Therefore, the effect iveness of the chemistry control program should be verified to ensure no corrosion. The GALL Report recommends further evaluation of
 
programs to manage loss of material from pitting and crevice corrosion to verify the effectiveness of The Water Chemistry Control Program. A one-time inspection of select 3-296 components at susceptible locations is an acceptable method to ensure no corrosion and that the component's intended function will be maintained during the period of extended operation.
In Section 3.3.2.C.1 of its letter dated August 19, 2005, the applicant also stated that for NMP1 the reactor water cleanup and shutdown cooling systems are applicable. The aging effect/
 
mechanism is managed by the combination of the Water Chemistry Control Program and One-Time Inspection Program.
The staff review and evaluation of the applicant's Water Chemistry Control Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.3.2.2.1. For those line items that
 
apply to Section 3.3.2.C.1 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
demonstrated that the effects of aging will be adequately managed so that intended functions
 
will be maintained consistent with the CLB during the period of extended operation as required
 
by 10 CFR 54.21(a)(3).
3.3A.2.2.2  Hardening and Cracking or Loss of Strength Due to Elastomer Degradation or Loss of Material due to Wear The staff reviewed Section 3.3.2.C.2 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.3.2.2.2.
In Section 3.3.2.C.2 of its letter dated August 19, 2005, the applicant addressed aging effects and aging effect mechanisms that could occur for the elastomer lining of some components
 
exposed to the treated water environment of the spent fuel pool cooling system and elastomer seals and collars in the ductwork of cert ain ventilation systems exposed to a range of atmospheric conditions.
SRP-LR Section 3.3.2.2.2 states that hardening and cracking due to elastomer degradation could occur in elastomer linings of the filter, valve, and ion exchangers in spent fuel pool cooling
 
and cleanup systems. Hardening and loss of strength due to elastomer degradation could occur
 
in the collars and seals of the duct and in the elastomer seals of the filters in the control room
 
area, auxiliary and radwaste area, and primary containment heating ventilation systems and in the collars and seals of the duct in the diesel generator building ventilation system. Loss of
 
material due to wear could occur in the collars and seals of the duct in the ventilation systems.
 
The GALL Report recommends further evaluation to ensure that these aging effects and aging
 
effects mechanisms are adequately managed.
In Section 3.3.2.C.2 of its letter dated August 19, 2005, the applicant also stated that elastomers are not used in the lining of spent fuel pool system components within the scope of license
 
renewal at NMP.
3-297 In addition the applicant stated in its letter dated August 19, 2005, that for NMP1 ventilation systems the aging effects and aging effects mechanisms for seals and collars are managed by
 
the Preventive Maintenance Program. The st aff reviewed the applicant's Preventive Maintenance Program and its evaluation is documented in SER Section 3.0.3.3.1.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria of the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.3.2.2.2. For those line items that
 
apply to Section 3.3.2.C.2 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.3A.2.2.3  Cumulative Fatigue Damage
 
In Section 3.3.2.C.3 of its letter dated August 19, 2005, the applicant stated 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 staff's review of the applicant's evaluation
 
of this TLAA.
3.3A.2.2.4  Crack Initiation and Growth Due to Cracking or Stress Corrosion Cracking
 
The staff reviewed Section 3.3.2.C.4 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.3.2.2.4.
In Section 3.3.2.C.4 of its letter dated August 19, 2005, the applicant addressed cracking due to SCC for the stainless steel reactor water cleanup system regenerative and non-regenerative
 
heat exchangers.
SRP-LR Section 3.3.2.2.4 states that crack initiation and growth due to SCC could occur in the regenerative and non-regenerative heat exchanger components in the reactor water cleanup
 
system. The GALL Report recommends further evaluation to ensure that these aging effects
 
and aging effects mechanisms are adequately managed.
In its August 19, 2005, letter the applicant also stated that for NMP1 this aging effect and aging effects mechanism for the reactor wate r cleanup system regenerative and non-regenerative heat exchangers is managed by a combination of the Water Chemistry Control Program and One-Time Inspection Program.
The staff's review and evaluation of the applicant's Water Chemistry Control Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.2 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in the SRP-LR.
3-298 Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.3.2.2.4. For those line items that
 
apply to Section 3.3.2.C.4 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.3A.2.2.5  Loss of Material Due to General, Microbiologically Influenced, Pitting, and Crevice Corrosion The staff reviewed Section 3.3.2.C.5 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.3.2.2.5.
In Section 3.3.2.C.5 of its letter dated August 19, 2005, the applicant addressed loss of material from corrosion that could occur on internal and external surfaces of components exposed to a
 
range of atmospheric conditions. Specifically included in the subsection are the ventilation
 
systems, the diesel generator systems' fuel oil, starting air, and combustion air intake and exhaust subsystems, and auxiliary sy stems' external carbon steel surfaces within the scope of license renewal.
SRP-LR Section 3.3.2.2.5 states that loss of material due to general, pitting, and crevice corrosion could occur in the piping and filter housing and supports in the control room area, the
 
auxiliary and radwaste area, the primary contai nment heating and ventilation systems, in the piping of the diesel generator building ventilation system, in the above-ground piping and
 
fittings, valves, and pumps in the diesel fuel oil system, and in the diesel engine starting air, combustion air intake, and combustion air ex haust subsystems in the emergency diesel generator system. Loss of material due to general, pitting, crevice, and MIC could occur in the
 
duct fittings, access doors and closure bolts, equipment frames, and housing of the duct; due to
 
pitting and crevice corrosion could occur in the heating/cooling coils of the air handler; and due
 
to general corrosion could occur on the external surfaces of all carbon steel structures and components, including bolting exposed to operating temperatures < 212 &deg;F in the ventilation
 
systems. The GALL Report recommends further ev aluation to ensure that these aging effects and aging effects mechanisms are adequately managed. Acceptance criteria are stated in
 
Branch Technical Position RLSB-1.
In Section 3.3.2.C.5 of its letter dated August 19, 2005, the applicant also stated that for NMP1 this aging effect and aging effect mechanism for the applicable systems and components is
 
managed by the Closed-Cycle Cooling Water, Fi re Water System, One-Time Inspection , 10 CFR 50 Appendix J, Preventive Maint enance, and Systems Walkdown Programs.
The staff's review and evaluation of the applicant's Closed-Cycle Cooling Water System, Fire Water System, One-Time Inspection, 10 CFR 50 Appendix J, Preventive Maintenance and
 
Systems Walkdown Programs are documented in SER Sections 3.0.3.2.8, 3.0.3.2.14, 3.0.3.1.4, 3.0.3.1.7, 3.0.3.3.1 and 3.0.3.3.2, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in the SRP-LR.
3-299 Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.3.2.2.5. For those line items that
 
apply to Section 3.3.2.C.5 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.3A.2.2.6  Loss of Material Due to General, Galvanic, Pitting, and Crevice Corrosion
 
The staff reviewed Section 3.3.2.C.6 of the applicant's letter dated August 19, 2005 against the criteria in SRP-LR Section 3.3.2.2.6.
In Section 3.3.2.C.6 of its letter dated August 19, 2005, the applicant addressed loss of material due to general, galvanic, pitting, and crevice corrosion in the reactor recirculation pumps' oil
 
collection system in fire protection.
The applicant stated in Section 3.3.2.C.6 of its letter dated August 19, 2005, that this item is not applicable because NMP has no oil collection systems for its reactor recirculation pumps. As
 
documented in the Audit and Review Report, the staff determined through discussions with the
 
applicant's technical personnel that loss of material due to general, galvanic, pitting, and crevice
 
corrosion in the reactor recirculation pumps' oil collection system in fire protection is not
 
applicable because NMP has no oil collection systems for its reactor recirculation pumps.
Because NMP has no components from this group the staff found this aging effect and aging effect mechanism not applicable to NMP.
3.3A.2.2.7  Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion and Biofouling The staff reviewed Section 3.3.2.C.7 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.3.2.2.7.
In Section 3.3.2.C.7 of its letter dated August 19, 2005, the applicant addressed loss of material due to general, pitting, crevice, and MIC and biofouling for the internal surfaces of components
 
in the diesel fuel oil system.
SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, crevice, and MIC and biofouling could occur in the internal surfaces of tanks in the diesel fuel oil system and due
 
to general, pitting, crevice, and MIC in the tanks of the diesel fuel oil system in the emergency
 
diesel generator system. The existing AMP re lies on the Fuel Oil Chemistry Program for monitoring and control of fuel oil contamination according to the guidelines of ASTM Standards
 
D4057, D1796, D2709 and D2276 to manage loss of material due to corrosion or biofouling that
 
may occur where contaminants accumulate. The effectiveness of the chemistry control program
 
should be verified to ensure no corrosion. The GALL Report recommends further evaluation of
 
programs to manage corrosion/biofouling to verify program effectiveness. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure no
 
corrosion and maintenance of the component's intended function during the period of extended
 
operation.
3-300 The applicant also stated in the ALRA that for NMP1 this aging effect and aging effect mechanism are managed by the combination of the Fuel Oil Chemistry Program and One-Time Inspection Program.
The staff's review and evaluation of the applic ant's Fuel Oil Chemistry Program and One-Time Inspection Program are documented in SER Sections 3.0.3.2.15 and 3.0.3.1.4, respectively.
The staff reviewed the applicant's further evaluation and concludes that it meets the criteria in the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.3.2.2.7. For those line items that
 
apply to Section 3.3.2.C.7 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
3.3A.2.2.8  Quality Assurance for Agi ng Management of Non-Safety-Related Components SER Section 3.0.4 provides the staff's evaluation of the applicant's quality assurance program.
 
3.3A.2.2.9  Crack Initiation and Growth Due to Stress Corrosion Cracking and Cyclic Loading
 
The staff reviewed Section 3.3.2.C.9 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.3.2.2.9.
In Section 3.3.2.C.9 of its letter dated August 19, 2005, the applicant stated that crack initiation and growth due to SCC and cyclic loading apply to PWRs only and that this aging effect/
 
mechanism is not applicable to NMP. The staff determined through discussions with the
 
applicant's technical personnel that because this aging effect and aging effect mechanism
 
applies to PWRs only it is not applicable to NMP.
Because NMP has no components from this group the staff determined that this aging effect and aging effect mechanism are not applicable to NMP.
3.3A.2.2.10  Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General Corrosion The staff reviewed Section 3.3.2.C.10 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.3.2.2.10.
SRP-LR Section 3.3.2.2.10 states that reduction of neutron-absorbing capacity and loss of material due to general corrosion could occur in the neutron-absorbing sheets of the spent fuel
 
storage rack in the spent fuel storage. The GALL Report recommends further evaluation to
 
ensure that these aging effects are adequately managed.
In Section 3.3.2.C.10 of its letter dated August 19, 2005, the applicant stated that reduction of neutron-absorbing capacity and loss of material due to general corrosion in the
 
neutron-absorbing (Boral or boron steel) sheets of the spent fuel storage racks are not 3-301 applicable as it had identified no aging effects and aging effects mechanisms for these components.
In its letter dated November 17, 2005, the applicant revised ALRA to address discussion held during the license renewal audit. In this letter, the applicant credits the Water Chemistry Control
 
and One-Time Inspection Programs for aging management. The Water Chemistry Control and One Time Inspection Programs manage general corrosion. The Boraflex Monitoring Program
 
manages the effects of reduction of neutron-absorbing capability.
The staff reviewed the applicant's Water Chemistry Control, One-Time Inspection, and Boraflex Monitoring Programs. The staff found this acceptable since its change meets the GALL Report's
 
recommendation. On this basis, the staff found this acceptable.
3.3A.2.2.11  Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion The staff reviewed Section 3.3.2.C.11 of the applicant's letter dated August 19, 2005, against the criteria in SRP-LR Section 3.3.2.2.11.
In Section 3.3.2.C.11 of its letter dated August 19, 2005, the applicant addressed loss of material due to general, pitting, crevice, and MIC for buried piping and fittings.
SRP-LR Section 3.3.2.2.11 states that loss of material due to general, pitting, and crevice corrosion and MIC could occur in the underground piping and fittings in the open-cycle cooling
 
water system (service water system) and in t he diesel fuel oil system. The Buried Piping and Tanks Inspection Program relies on industry practice, frequency of pipe excavation, and
 
operating experience to manage the effects of loss of material from general, pitting, crevice, and
 
MIC. The effectiveness of the applicant's Buried Piping and Tanks Inspection Program should
 
be verified to evaluate an applicant's inspection frequency and operating experience with buried
 
components and ensure no loss of material.
In Section 3.3.2.C.11 of its letter dated August 19, 2005, the applicant also stated that this aging effect and aging effect mechanism are managed by the Buried Piping and Tanks Inspection
 
Program for NMP1 diesel generator systems.
The staff's review and evaluation of the applicant's Buried Piping and Tanks Inspection Program are documented in SER Section 3.0.3.1.6.
As documented in the Audit and Review Report, the staff asked the applicant to clarify its position on opportunistic inspections prior to the period of extended operation. In its letter dated
 
December 1, 2005, the applicant stated that the ALRA had been revised to include the following
 
in its Buried Piping and Tanks Inspection Program:
Program activities will include visual inspec tions of external coatings and wrappings to detect damage and degradation. Prior to entering the period of extended operation, NMP will verify that there has been at least one opportunistic or focused inspection
 
within the past ten years. Upon entering the period of extended operation, NMP will
 
perform a focused inspection within ten years, unless an opportunistic inspection
 
occurred within this ten year period. All credited inspections will be performed in areas 3-302 with the highest likelihood of corrosion problems, and in areas with a history of corrosion problems.
After a review of the applicant's clarification of its visual inspection position and its further evaluation the staff concludes that the program meets the criteria of the SRP-LR.
Based on the programs identified above, the staff concludes that there is reasonable assurance that the applicant has met the criteria of SRP-LR Section 3.3.2.2.11. For those line items that
 
apply to Section 3.3.2.C.11 of the applicant's letter dated August 19, 2005, the staff determined
 
that the information in the application is consistent with the GALL Report and the applicant had
 
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).
Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL
 
Report recommends further evaluation, the staff determined that the applicant adequately
 
addressed the issues that were further evaluated. The staff found that the applicant had
 
demonstrated that the effects of aging will be adequately managed so that the intended
 
functions will be maintained consistent with the CLB for the period of extended operation, as
 
required by 10 CFR 54.21(a)(3).3.3A.2.3  AMR Results That Are Not Consistent with or Not Addressed in the GALL Report Summary of Technical Information in the Application. In the original LRA Tables 3.3.2.A-1 through 3.3.2.A-25, the staff reviewed additional details of the results of the NMP1 AMRs for
 
material, environment, aging effect requiring management, and AMP combinations that are not
 
consistent with the GALL Report, or not addressed in the GALL Report.
In the original LRA Tables 3.3.2.A-1 through 3.3.2.A-25, the applicant indicated, via Notes F through J, that the combination of component type, material, environment, and aging effect
 
requiring management does not correspond to a line item in the GALL Report, and provided
 
information concerning how the aging effect will be managed. Specifically, Note F indicated that
 
the material for the AMR line item component is not evaluated in the GALL Report. Note G
 
indicated that the environment for the AMR line item component and material is not evaluated in the GALL Report. Note H indicated that the aging effect for the AMR line item component, material, and environment combination is not evaluated in the GALL Report. Note I indicated
 
that the aging effect identified in the GALL Report for the line item component, material, and
 
environment combination is not applicable. Note J indicated that neither the component nor the
 
material and environment combination for the line item is evaluated in the GALL Report.
Staff Evaluation. For component type, material, and environment combinations that are not evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine
 
whether it had demonstrated that the effects of aging will be adequately managed so that the
 
intended functions will be maintained consistent with the CLB during the period of extended
 
operation. The staff's evaluation is discussed in the following sections.
3.3A.2.3.0  General RAIs on AMR Issues 3-303 By letter dated November 2, 2005, the staff requested that the applicant provide additional information on issues described in the general RAI (a-RAI 3.3.2-1) for the ALRA applicable to
 
more than one system in both NMP1 and NMP2. By letter dated November 30, 2005, the
 
applicant responded. The following describes a-RAI 3.3.2-1, the applicant's response, and the
 
staff's evaluation of the applicant's response.
Adequacy of the Use of One-Time Inspection (a-RAI 3.3.2-1). One-time inspection is appropriate where either an aging effect is not expected to occur but there is insufficient data to
 
rule it out completely or the aging effect is expected to occur very slowly and not affect the
 
component intended function. The applicant proposed to use the One-Time Inspection Program
 
to manage aging effects for various materials exposed to various environments for a majority of
 
the components in two systems: (a) ALRA Table 3.3.2.A-14, NMP1 radioactive waste system and (b) ALRA Table 3.3.2.B-14, NMP2 floor and equipment drains system.
In a-RAI 3.3.2-1 dated November 2, 2005, the staff requested that the applicant:
(1)Explain from system characteristics why the One-Time Inspection Program rather than periodic inspections is proposed as the sole AMP for these two systems to manage
 
aging effects of material-environment combinations (2) Justify the use of the One-Time Inspection Program for the following cases:(a)In Table 3.3.2.A-14 AERM of cracking for wrought austenitic stainless steel (WASS) Heat Exchangers exposed to air, moisture, or wetting, temperature
 
> 140 &deg;F and for WASS valves exposed to treated water temperature
> 140 &deg;F < 212 &deg;F.(b)In Table 3.3.2.A-14 AERM of loss of material (LOM) for carbon or low alloy steel (yield strength < 100 ksi) or WASS valves, piping, and fittings exposed to
 
demineralized untreated water (DUW).(c)In Table 3.3.2.A-14 AERM of LOM for carbon or low alloy steel (yield strength
< 100 ksi) valves exposed to either DUW, low flow, or treated water, temperature
 
> 140 &deg;F < 212 &deg;F. (d)In Table 3.3.2.B-14 AERM of cracking for WASS drainers exposed to treated water, temperature > 140 &deg;F < 212 &deg;F. (e)In Table 3.3.2.B-14 AERM of LOM for aluminum pump or carbon or low alloy steel (yield strength < 100 ksi) strainers exposed to raw water.
In its letter dated November 30, 2005, the applicant responded:
(1) The NMP1 radwaste and NMP2 floor and equipment drains systems include the following subsystems:
* equipment drains in various building
* floor drains in various buildings
* the piping, pumps, tanks, and valves in these subsystems 3-304 The components in these systems are fabric ated predominantly of carbon steel and the environment is generally water; however, exposur e to water is not continuous. When tanks or sumps reach pre-set levels the pumps automat ically start to empty them and expose the downstream components to water.
The applicant stated that for this non-continuous exposure the One Time Inspection Program was chosen to manage aging because the identified aging effects were judged to occur at such
 
a slow rate that the component intended functions would not be impacted during the period of
 
extended operation. After further evaluation, including review of the guidance from the most
 
recent industry aging management documentation, the applicant concluded that the
 
Preventative Maintenance Program manages the agi ng of the carbon steel and gray cast iron components in these systems more effectivel y than the One Time Inspection Program. The Preventive Maintenance Program was, therefore, substituted for the One Time Inspection
 
Program to manage the aging of the carbon steel and gray cast iron components in these
 
systems with the exception of the carbon steel piping and fittings and valves subjected to an
 
internal fuel oil environment. As these components are exposed to fuel oil drainage loss of
 
material from water contamination is possible. This possibility is considered unlikely because
 
there would be an oil film on the inside of thes e components; however, the One Time Inspection Program will ascertain whether loss of material occurs. Through its CAP, the applicant will
 
document and correct the anomaly. The cast and wrought austenitic stainless steel, nickel-based alloy, and copper alloy (zinc <
15 percent) components will continue to be managed by the One Time Inspection Program.
The applicant further stated that an extent of condition review had been performed for the other NMP1 and NMP2 mechanical systems to determine if similar changes were needed in the
 
application of the One Time Inspection Program for aging management. As a result of this
 
review, there were two other changes identified: (1) for the NMP1 miscellaneous
 
non-contaminated vents and drains system the AMP for managing the internals of the system components (carbon steel piping and fittings in a demineralized untreated water or raw water
 
environment) was changed to the Preventive Maintenance Program and (2) for the NMP2 standby liquid control system the line item on Table 3.3.2.B-30 (page 3.3-288) of the ALRA for WASS valves in the air, moisture or wetting, temperature < 140 &deg;F environment was deleted (line with Note H). The valves identified as in that environment are actually wetted and covered
 
by the other wetted WASS valve environments already included in the ALRA.
For the specific instances questioned the applicant provided the following response:
(2)(a) The heat exchangers that are addressed by the line item in the ALRA are associated with the Radwaste System Concentrator 12. This Concentrator, and hence
 
its associated components, are infrequently (less than once per operating cycle) used
 
since other preferable methods for liquid waste processing are normally utilized (see USAR Section XII.2.2. 1). As shown on Drawing LR- 18045-C, Sheet 5, the heat
 
exchangers associated with Concentrator 12 are the Concentrator Heat Exchanger, the Concentrator Distillate Sub-Cooler, the Concentrator Vent Condenser, and the
 
Concentrator Vapor Condenser. The One- Time Inspection Program is considered to
 
be the appropriate aging management program for these components since they are normally exposed to air and the rate of aging is judged to be so slow that their
 
intended functions would not be impacted during the period of extended operation.
3-305 The valves in this system that are WASS in Treated Water > 140 &deg;F, but < 212 &deg;F are all 3/4" valves (mostly ball valves) in either instrument lines or drain lines. As such, the
 
applicable AERM of cracking was considered to be unlikely since there is normally no
 
flow through these lines and it is very improbable that the water temperature is
 
sustained at the high end of the indicated range. For this reason, the One Time
 
Inspection Program was considered to be adequate for aging management of these
 
valves, so it was credited.
(2)(b-d) As discussed in the response to the first part of this RAI, the aging management of the carbon steel and gray cast iron components within the NMPI
 
Radioactive Waste System is changed from the One Time Inspection Program to the
 
PM Program. For the stainless steel component s within the system, it is considered to be unlikely that they will experience the AERMs that have been identified for them. For
 
this reason, the One Time Inspection Program is retained as the AMP.
(2)(e) These pumps are the sump pumps in the Control Building floor drain sump (see Drawing LR-66C-0). These pumps are non-safety-related pumps that are in scope for
 
10 CFR 54.4(a)(2) because they are located in the Control Building and there is
 
safety-related equipment in the vicinity. Ev en though the Environment for these pumps has been identified as Raw Water, the water that enters the sump is treated or demineralized
 
water that has leaked onto the floor and drained to the sump. Since there is no chemistry
 
control of this water, it has been identified as Raw Water. The One Time Inspection
 
Program has been credited for aging management since it is considered unlikely that the
 
AERM of LOM would ever occur to the extent such that the loss of the intended function of
 
the pumps would be lost.
For the carbon steel strainers, as discussed in the response to the first part of this RAI, the AMP is to be changed to the PM Program.
The staff reviewed the applicant's response and found it reasonable and acceptable because the applicant has revised the aging management strategy for carbon steel components in the
 
radioactive waste system, the auxiliary NMP2 floor and equipment drains system, and the other systems to ensure detection of aging effects prior to loss of intended function.
The staff's system-specific evaluations are discussed below.
 
3.3A.2.3.1  Auxiliary Systems NMP1 Circ ulating Water System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-1 The staff reviewed ALRA Table 3.3.2.A-1, which summarizes the results of AMR evaluations for the circulating water system component-m aterial-environment AERM combinations not addressed in the GALL Report. These combinations use Note F through J in ALRA
 
Table 3.3.2.A-1 as revised in the applicant's letter NMP1L 1996 dated November 17, 2005. The
 
staff verified that the applicant had identified all AERMs and credited appropriate AMPs for
 
managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs to
 
ensure that the program descriptions adequately describe them.
Aging Effects. ALRA Table 2.3.3.A.2-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include external surfaces, valves, and traveling screens and rakes.
3-306 For these component types the applicant identified the following materials, environments, and AERMs:
* gray cast iron exposed to air subject to loss of material
* gray cast iron exposed to raw water subject to loss of material
* fiberglass exposed to raw water subject to cracking and loss of strength The staff reviewed the information in ALRA Section 2.3.3.A.2, Table 2.3.3.A.2-1, Section 3.3.2.A.1, and Table 3.3.2.A-1.
The staff's review of the information provided in the ALRA found the aging effects of the circulating water system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not
 
identify any omitted aging effects. Therefore, the staff found that the applicant had identified the
 
appropriate aging effects for the materials and environments associated with the above
 
components in the circulating water system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the above components the staff evaluated the AMPs to determine whether they are appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement contains an adequate description of the program.
ALRA Table 3.3.2.A-1 identifies the following AMPs for managing the aging effects for the circulating water system components not addressed by the GALL Report:
* System Walkdown Program
* Open-Cycle Cooling Water System Program
* Selective Leaching of Materials Program The staff's detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.7, and 3.0.3.1.5.
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated with the
 
circulating water system components will be adequately managed so that the intended functions
 
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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.2  Auxiliary Systems NMP1 City Water System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-2 The staff reviewed ALRA Table 3.3.2.A-2, which summarizes the results of AMR evaluations for the city water system component-material-env ironment AERM combinations not addressed in the GALL Report. These combinations use note F through J in ALRA Table 3.3.2.A-2 as revised
 
by the applicant's letters NMP1L 1996 dated November 17, 2005, and NMP1L 2007 dated
 
December 5, 2005. The staff reviewed these supplemental letters and verified that the applicant
 
had identified all AERMs and credited appropriate AMPs for managing them. The staff also 3-307 reviewed the applicable UFSAR supplements for the AMPs to ensure that the program descriptions adequately describe them.
Aging Effects. ALRA Table 2.3.3.A.3-1 lists individual system components within the scope of license renewal subject to an AMR. The component types that do not rely on the GALL Report
 
for an AMR include external surfaces, valves, and traveling screens and rakes.
For these component types the applicant identified the following materials, environments, and AERMs:
* gray cast iron exposed to air subject to loss of materia.
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated water subject to loss of material
* copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss of material
* gray cast iron exposed to demineralized untreated water subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.3, Table 2.3.3.A.3-1, Section 3.3.2.A.2, and Table 3.3.2.A-2. During its review the staff determined that additional
 
information was needed.
The RAIs are organized in two groups, general and system-specific. The general RAI applicable to this system is a-RAI 3.3.2-1.
In a-RAI 3.3.2-1 dated November 2, 2005, the staff requested that the applicant provide additional information and by letter dated November 30, 2005, the applicant responded. The
 
RAI, the applicant's response, and the staff's evaluation of the response are described in SER
 
Section 3.3A.2.3.0. There are no relevant system-specific RAIs associated with this system.
The staff's review of the information provided in the ALRA and the additional information in the applicant's response to the RAI the staff found the aging effects of the city water system
 
component types not addressed by the GALL Report consistent with industry experience for
 
these combinations of materials and environments. The staff did not identify any omitted aging
 
effects. Therefore, the staff found that the applicant had identified the appropriate aging effects
 
for the materials and environments of the city water system components.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement adequately describes the program.
ALRA Table 3.3.2.A-2 identifies the following AMPs for managing aging effects for the city water system components not addressed by the GALL Report:
* System Walkdown Program
* One-Time Inspection Program
* Selective Leaching of Materials Program 3-308 In the applicant's response to general RAI a-RAI 3.3.2-1, as described in SER Section 3.3A.2.3.0, the applicant revised its management strategy for the aging effects of some
 
components in this system by replacing the O ne-Time Inspection Program with the Preventive Maintenance Program. The staff's detailed review of the Preventive Maintenance Program is in
 
SER Section 3.0.3.3.1.
The staff's detailed review of System Walkdown Program and Selective Leaching of Materials Program is in SER Sections 3.0.3.3.2 and 3.0.3.1.5.
Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the city water system components will be adequately managed so that the intended
 
functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d) 3.3A.2.3.3  Auxiliary Systems NMP1 Co mpressed Air Systems - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-3 The staff reviewed ALRA Table 3.3.2.A-3, which summarizes the results of AMR evaluations for the compressed air systems component-mat erial-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-3 as revised by the applicant's letter NMP1L 1996 dated November 17, 2005. The
 
staff reviewed this supplemental letter and verified that the applicant had identified all AERMs
 
and had credited appropriate AMPs with managing them. The staff also reviewed the applicable
 
UFSAR supplements for the AMPs to ensure that the program descriptions describe them
 
adequately.
Aging Effects. ALRA Table 2.3.3.A.4-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include drain traps, external surfaces, filters/strainers, heat exchangers, piping and fittings, separators, and valves.
For these component types the applicant identified the following materials, environments, and AERMs:
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water, low flow, subject to loss of material
* gray cast iron exposed to air subject to loss of material
* gray cast iron exposed to demineralized untreated water, or demineralized untreated water, low flow, subject to loss of material
* polymers exposed to air subject to cracking, hardening and shrinkage, and loss of strength
* red brass cold worked exposed to air subject to cracking 3-309
* wrought austenitic stainless steel exposed to demineralized untreated water, low flow, subject to loss of material
* copper alloys (zinc > 15 percent) and aluminum bronze exposed to air subject to loss of heat transfer
* copper alloys (zinc > 15 percent) and aluminum bronze exposed to demineralized untreated water or demineralized untreated water, low flow, subject to loss of heat transfer
 
and loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water or demineralized untreated water, low flow, subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.4, Table 2.3.3.A.4-1, Section 3.3.2.A.3, and Table 3.3.2.A-3.
The staff's review of the information provided in the ALRA found the aging effects of the compressed air systems component types not addr essed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not
 
identify any omitted aging effects. Therefore, the staff found that the applicant had identified the
 
appropriate aging effects for the materials and environments of the components in the compressed air systems.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the program adequately.
ALRA Table 3.3.2.A-3 identifies the following AMPs for managing the aging effects for the compressed air systems components not addressed by the GALL Report:
* System Walkdown Program
* Compressed Air Monitoring Program
* Selective Leaching of Materials Program The staff's detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.11, and 3.0.3.1.5.
Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the compressed air systems components will be adequately managed so that the intended
 
functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d) 3.3A.2.3.4  Auxiliary Systems NMP1 Cont ainment Systems - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-4 3-310 The staff reviewed ALRA Table 3.3.2.A-4, which summarizes the results of AMR evaluations for the containment systems component-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA Table 3.3.2.A-4. The
 
staff verified that the applicant had identified all AERMs and had credited appropriate AMPs with
 
managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs to
 
ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.5-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include heat exchanger, piping and fittings, valves, and vaporizers.
For these component types the applicant identified the following materials, environments, and AERMs.
* copper alloys (zinc <
15 percent) exposed to air subject to loss of heat transfer
* copper alloys (zinc <
15 percent) exposed to air, moisture or wetting, temperature > 140 &deg;F, subject to loss of heat transfer
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water subject to loss of material
* wrought austenitic stainless steel exposed to air, moisture or wetting, temperature > 140 &deg;F, subject to cracking
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water, low flow, subject to loss of material
* wrought austenitic stainless steel exposed to demineralized untreated water, low flow, subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.5, Table 2.3.3.A.5-1, Section 3.3.2.A.4 and Table 3.3.2.A-4.
The staff's review of the information provided in the ALRA found the aging effects of the containment systems component types not addr essed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not
 
identify any omitted aging effects. Therefore, the staff found that the applicant had identified the
 
appropriate aging effects for the materials and environments of the components in the
 
containment systems.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-4 identifies the following AMPs for managing the aging effects for the containment systems components not addressed by the GALL Report:
* One-Time Inspection Program
* Preventive Maintenance Program
* Closed-Cycle Cooling Water System Program 3-311 The staff's detailed review of these AMPs is in SER Sections 3.0.3.1.4, 3.0.3.3.1, and 3.0.3.2.8.
 
==
Conclusion:==
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the containment systems components will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.5  Auxiliary Systems NMP1 Contro l Room HVAC System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-5 The staff reviewed ALRA Table 3.3.2.A-5, which summarizes the results of AMR evaluations for the control room HVAC system component-m aterial-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-5. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.6-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include expansion tank, external surfaces, filters/strainers, flow elements, heat exchanger, piping and fittings, pumps, seals and gaskets, and valves and dampers.
For these component types the applicant identified the following materials, environments, and AERMs:
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water, low flow, subject to loss of material
* gray cast iron exposed to air subject to loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water subject to loss of material
* copper alloys (zinc <
15 percent) exposed to air subject to loss of heat transfer
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water subject to loss of heat transfer
* wrought austenitic stainless steel exposed to demineralized untreated water subject to loss of heat transfer and loss of material
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water subject to loss of material
* polymers exposed to air subject to loss of sealing
* gray cast iron exposed to demineralized untreated water subject to loss of material 3-312 The staff reviewed the information in ALRA Section 2.3.3.A.6, Table 2.3.3.A.6-1, Section 3.3.2.A.5, and Table 3.3.2.A-5.
In a-RAI 3.3.2.A-5-1 dated November 2, 2005, the staff requested that the applicant clarify the Note "K" for heat exchangers and valves and dampers in Table 3.3.2.A-5 and explain why the
 
LOM was not identified as an AERM for wrought austenitic stainless (WASS) steel heat
 
exchangers exposed to demineralized untreated water (DUW) similar to the WASS heat
 
exchangers in Table 3.3.2.A-14.
In its response by letter dated November 30, 2005, the applicant stated that as part of the recovery effort which led to the submittal of the ALRA it chose to convert the lettered
 
plant-specific notes to the standard industry-lettered notes. As discussed with the staff, the
 
applicant agreed that Note H should be substituted for Note K. For those two cited locations in
 
Table 3.3.2.A-5 each Note K is, therefore, changed to Note H.
The applicant further stated that there is a similar Notes anomaly in ALRA Table 3.3.2.B-6 (page 3.3-217). For the component type piping and fittings the indicated Notes column entry of 'J'
 
should be 'None' consistent with the other Notes column entries in this table and is changed
 
accordingly.
As to the second question in the RAI the applicant agreed that the AERM of LOM should be applied to the WASS heat exchangers in DUW environments. Therefore, the applicant made the
 
following changes: (a) Consistent with Table 3.3.2.A-14, the HT and PB function for the WASS heat exchangers in Table 3.3.2.A-5 should have a line item for the AERM of LOM which is
 
added. For this line item, the AMP is the Closed Cycle Cooling Water System Program with the Note of H. Additionally, the Note 9 for the LOHT AERM line item is removed.(b) In Table 3.3.2.A-15, for the WASS heat exchangers with HT and PB intended functions in a DUW environment, a line item for the AERM of LOM is added. For this
 
line item, the AMP is the Closed Cycle Coo ling Water System Program with the Note of H. The Note 9 for the LOHT intended function line item is removed (additionally, for
 
the LOHT line item, the One Time Inspection Program was removed in NMP letter
 
NMP1L 1996, dated November 17, 2005).(c) In Table 3.3.2.A-17, for the WASS heat exchangers in a DUW environment, the AERM is changed from None to LOM, the AMP is changed from None to the Closed
 
Cycle Cooling Water System Program, and the Note is changed from None to H.(d) In Table 3.3.2.A-21, for WASS heat exchangers in a DUW environment, a line item for the AERM of LOM is added with the AMP of the Closed Cycle Cooling Water
 
System Program, and Note H. Additionally, t he Note 9 in the LOHT AERM line item is removed.(e) In Table 3.3.2.B-27, for the WASS heat exchangers with the HT and PB intended functions in a DUW environment, a line item for the AERM of LOM is added with the
 
AMP of the Closed Cycle Cooling Water Sy stem Program, and Note H. Additionally, the Note 9 in the LOHT AERM line item is removed.
3-313 The staff's review of the information provided in the ALRA and the additional information included in the applicant's response to the RAI found the aging effects of the control room
 
HVAC system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not identify any
 
omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate
 
aging effects for the materials and environments of the components in the control room HVAC system.Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-5 identifies the following AMPs for managing the aging effects for the control room HVAC system component s not addressed by the GALL Report:
* Closed-Cycle Cooling Water System Program
* System Walkdown Program
* Preventive Maintenance Program
* One-Time Inspection Program
* Selective Leaching of Materials Program The staff's detailed review of these AMPs is in SER Sections 3.0.3.2.8, 3.0.3.3.2, 3.0.3.3.1, 3.0.3.1.4, and 3.0.3.1.5.
Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the control room HVAC system components will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d) 3.3A.2.3.6  Auxiliary Systems NMP1 Diesel Generator Building Ventilation System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-6 The staff reviewed ALRA Table 3.3.2.A-6, which summarizes the results of AMR evaluations for the diesel generator building ventilation system component groups.
This auxiliary system is listed here for inform ation and completeness. The AMR results for the NMP1 diesel generator building ventilation syst em are consistent with the GALL Report. The staff's evaluation of these results is presented in SER Section 3.3A.2.2.5 3.3A.2.3.7  Auxiliary Systems NMP1 Emergency Diesel Generator System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-7 The staff reviewed ALRA Table 3.3.2.A-7, which summarizes the results of AMR evaluations for the emergency diesel generator system com ponent-material-environment AERM combinations 3-314 not addressed in the GALL Report. These combinations use Notes F through J in ALRA Table 3.3.2.A-7. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.8-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include external surfaces, filters/strainers, heat exchangers, and pumps.
For these component types the applicant identified the following materials, environments, and AERMs:
* gray cast iron exposed to air subject to loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to treated water, temperature< 140 &deg;F, subject to loss of heat transfer
* gray cast iron exposed to treated water, temperature < 140 &deg;F, subject to loss of heat transfer
* wrought austenitic stainless steel exposed to raw water subject to loss of heat transfer
* gray cast iron exposed to raw water subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.8, Table 2.3.3.A.8-1, Section 3.3.2.A.7, and Table 3.3.2.A-7.
The staff's review of the information provided in the ALRA found the aging effects of the emergency diesel generator system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The
 
staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had
 
identified the appropriate aging effects for the materials and environments of the components in
 
the emergency diesel generator system.
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-7 identifies the following AMPs for managing the aging effects for the emergency diesel generator system com ponents not addressed by the GALL Report:
* System Walkdown Program
* One-Time Inspection Program
* Closed-Cycle Cooling Water System Program
* Open-Cycle Cooling Water System Program
* Selective Leaching of Materials Program The staff's detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.1.4, 3.0.3.2.8, 3.0.3.2.7, and 3.0.3.1.5.
3-315 Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the emergency diesel generator syst em components will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.8  Auxiliary Systems NMP1 Fire Dete ction and Protection System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-8 The staff reviewed the ALRA Table 3.3.2.A-8, which summarizes the results of AMR evaluations for the fire detection and protection system component groups.
The staff initially reviewed ALRA Table 3.3.2.A-8 (only those line items that are not consistent with the GALL Report or component aging effects for material/environment was not listed in the
 
GALL Report), which summarizes the results of AMR evaluations for the NMP1 fire detection
 
and protection system component groups.
In ALRA Section 3.3.2.A.8 and Table 3.3.2.A-8, the applicant identified the materials, environments, and AERMs. The materials identified include carbon steel or low alloy steel, concrete, copper alloy (zinc <
15%), copper alloy (zinc > 15%) and aluminum bronze, gray cast iron, and wrought austenitic stainless steel.
The applicant identified the environments to which these materials could be exposed as air, dried air or gas, exhaust, fuel oil without water contamination, lubricating oil, raw water low flow, soil above the water table, and soil below the water table as the environments associated with
 
the fire detection and protection system. The applicant identified AERMs from cracking and loss
 
of material associated with the fire detection and protection system.
The applicant proposed to manage the fire protection system aging effects by using the Fire Protection Program, Fire Water System Progr am, Preventive Maintenance Program, Systems Walkdown Program, Bolting Integrity Program, One-Time Inspection Program, and Selective Leaching of Materials Program. The staff's evaluations of these programs are documented in
 
SER Sections 3.0.3.2.13, 3.0.3.2.14, 3.0.3.3.1, 3.0.3.3.2, 3.0.3.3.23, 3.0.3.1.4, and 3.0.3.1.5
 
respectively.
The staff reviewed ALRA Section 3.3.2.A.8 and Table 3.3.2.A-8, to determine whether the applicant demonstrated that it will adequately manage the effects of aging for the fire protection
 
system during the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff
 
conducted its review, described below, in accordance with SRP-LR Section 3.3 and the GALL
 
Report.In RAI 2.3.3.A.9-8 dated November 17, 2004, the staff stated that the GALL Report describes recommendations for aging management of the fire protection water system based on the
 
combination of component type, material, and environment. ALRA Table 3.3.2.A-8 for the
 
auxiliary systems for the NMP1 fire detection and protection system summarizes the AMP for each of the combinations mentioned above. When the combinations do not exactly match the 3-316 requirements of the GALL Report, the ALRA table includes a note indicating that the prescribed AMP has been modified for use or that the applicant will use another aging management
 
program. For the combination of fire hydrants, gray cast iron, raw water, low flow, a table note indicates that the Selective Leaching Program is being used in addition to the Fire Water System
 
Program to manage loss of material.
To complete its review, the staff required further information regarding the use of the Selective Leaching Program to manage loss of material. Therefore, in the RAI 2.3.3.A.9-8, the staff
 
requested that the applicant supply the portions of the Selective Leaching Program that are
 
applicable to the combination of fire hydrants, gray cast iron, raw water, low flow. The staff also
 
requested that the applicant include program documents and procedures credited for managing
 
the loss of material for this combination.
In its response by letter dated December 17, 2004, the applicant stated that as presented in ALRA Sections A1.1.33 and B2.1.21, the implementation of the selective leaching of materials
 
program is discussed in the program descripti on for the One-Time Inspection Program (see ALRA Section B2.1.20). The One-Time Inspection Program is a new license renewal aging
 
management program commitment for NMPNS (NMP1 Commitment 23 and NMP2 Commitment
: 21) that is to be implemented prior to the period of extended operation. This commitment was
 
made in the original LRA submittal, as supplemented by the NMP letter NMP1L 1880 dated October 29, 2004. As such, NMP does not currently have any program documents or procedures specific to managing selective leaching for fire hydrants Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-8 acceptable because it adequately describes how the Selective Leaching Program would be used to
 
manage loss of material components in question. Therefore, the staff's concern described in
 
RAI 2.3.3.A.9-8 is resolved.
In RAI 2.3.3.A.9-9 dated November 17, 2004, the staff stated that the GALL Report describes requirements for aging management of the fire protection water system based on the
 
combination of component type, material, and environment.
The original LRA Table 3.3.2.A-8 for the auxilia ry systems for the NMP1 fire detection and protection system summarizes the AMP for each of the combinations mentioned above. When
 
the combinations do not exactly match the requirements of the GALL Report, the original LRA
 
table includes a note indicating that the prescribed AMP has been modified for use or that
 
another AMP is being used.
For the combination of flow elements, wrought austenitic stainless steel, raw water, low flow, a table note indicates that the Fire Water System Program has been modified to manage cracking
 
in addition to loss of material.
Additionally, another note of the original LRA table indicates that flow elements are not specifically identified in GALL Report Chapter VII for the fire protection system.
Therefore, to complete its review, the staff required further information regarding the use of the Fire Water System Program to manage cracking and loss of material. In the RAI, the staff
 
requested that the applicant supply the Fire Water System Program documents and procedures 3-317 that are applicable to the combination of flow elements, wrought austenitic stainless steel, raw water, low flow that are credited with managing cracking and loss of material.
In its response by letter dated December 17, 2004, the applicant stated that the AERM of material cracking resulting from SCC for wrought austenitic stainless steel components (including the flow elements) in low flow, raw water will be reassigned to the One-Time
 
Inspection Program for aging management. As presented in the original LRA Sections A1.1.28
 
and B2.1.20, the One-Time Inspection Program is a new AMP, documented as commitments (NMP1 Commitment 23 and NMP2 Commitment 21) to be implemented prior to the period of
 
extended operation. These commitments were made in the original LRA submittal, as
 
supplemented by the NMP correspondence NMP1L 1880 dated October 29, 2004. As such, NMP does not currently have any program doc uments or procedures specific to manage cracking of flow elements.
The above flow elements are also susceptible to loss of material from galvanic, general, pitting, and MIC mechanisms. The applicant credits fire system flow test and a site chemistry procedure
 
with managing the aging along with a new inspection activity yet to be generated. These
 
credited activities are discussed below:
* The new site activity is identified as an enhancement in "parameters monitored/inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement adds procedural guidance
 
for performing visual inspections to monitor internal corrosion and detect biofouling. This
 
enhancement will include inspections for loss of material in the flow elements above and
 
will be implemented prior to the period of extended operation. As such, there are no
 
existing program documents or procedur es implementing these inspections.
* Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is credited with managing loss of material as a result of microbiological activity. The
 
procedure provides guidance for sampling and analysis of raw water systems for the
 
presence of bacteria. Acceptance criteria are defined and the site corrective action
 
process is utilized when the criteria are not met. Additionally, as presented in the original
 
LRA Sections A1.1.18 and B2.1.17, the fire water system program will be enhanced prior to
 
the period of extended operation to add specific requirements for periodic sampling of
 
water-based fire protection systems.
* Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with managing corrosion, biofouling, and MIC of the fire protection water distribution system. The testing
 
actiivity provides full flow testing of the system in accordance with the NFPA Fire Protection
 
Handbook. Acceptance criteria are defined and the site corrective action process is utilized
 
when the criteria are not met. The procedure verifies the system is capable of retaining
 
pressure and is not obstructed or degraded by corrosion or fouling.
The applicant revised AMR original LRA Table 3.3.2.A-8 to replace Fire Water System Program with One-Time Inspection Program for the management of material cracking for wrought
 
austenitic stainless steel components (flow elements and orifices) in a raw water, low flow
 
environment.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-9 acceptable because it adequately describes how the aging effects requiring management of material
 
cracking resulting from SCC for wrought austenitic stainless steel components, galvanic, 3-318 general, pitting, MIC, and selective leaching would be managed for the components in question.
The applicant also revised the AMR original LRA table for the component types in question to
 
show the One-Time Inspection Program for the management of cracking. Therefore, the staff's
 
concern described in RAI 2.3.3.A.9-9 is resolved.
In RAI 2.3.3.A.9-10 dated November 17, 2004, the staff stated that the GALL Report describes recommendations for aging management of the fire protection water system based on the
 
combination of component type, material, and environment.
The original LRA Table 3.3.2.A-8 for the auxilia ry systems for the NMP1 fire detection and protection system summarizes the aging managem ent program for each of the combinations mentioned above. When the combinations do not exactly match the requirements of the GALL
 
Report, the original LRA table includes a note indicating that the prescribed AMP has been
 
modified for use or that another AMP is being used.
For the combination of heat exchangers, carbon or low alloy steel (yield strength < 100 Ksi), raw water, and low flow, a table note indicates that the Fire Water System Program has been
 
modified to manage loss of material in heat exchangers which are not specifically identified in
 
GALL Report Chapter VII for the fire protection system.
To complete its review, the staff required further information regarding the use of the Fire Water System Program to manage loss of material for heat exchangers. The staff asked the applicant to supply the Fire Water System Program documents and procedures that are applicable to the
 
combination of heat exchangers, carbon or low alloy steel (yield strength < 100 Ksi), raw water, and low flow that are credited with managing loss of material in heat exchangers.
In its response by letter dated December 17, 2004, the applicant stated that the heat exchangers in question are susceptible to loss of material from galvanic, general, pitting, and
 
MIC mechanisms. A new inspection acti vity (see NMP1 Commitment 20 and NMP2 Commitment 18), for which a procedure must be generated, a site chemistry procedure, and a
 
fire system flow test are credited with managing aging. These activities are discussed below:
* The new site activity is identified as an enhancement in "parameters monitored/ inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement adds procedural guidance
 
for performing visual inspections to monitor internal corrosion and to detect biofouling. This
 
new activity will include inspections for loss of material in the heat exchangers in question
 
and will be implemented prior to the period of extended operation. As such, there are no
 
existing procedures implementing these inspections at this time. The Fire Water System
 
Program attribute assessment addresses program implementation at NMP relative to the requirements of SRP-LR Appendix A.
* Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is credited with managing loss of material as a result of microbiological activity. The
 
procedure provides guidance for sampling and analysis of raw water systems for the
 
presence of bacteria. Additionally, as presented in original LRA Sections A1.1.18 and
 
B2.1.17, the Fire Water System Program will be enhanced prior to the period of extended
 
operation to add specific requirements for periodic sampling of water-based fire protection systems.
3-319
* Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with the possible discovery of corrosion, biofouling, and MIC of the fire protection water distribution
 
system. The procedure provides for full flow test ing of the system in accordance with the NFPA Fire Protection Handbook. Acceptance criteria are defined and the site corrective
 
action process is utilized when the criteria are not met. The procedure verifies that the
 
system is capable of retaining pressure and is not obstructed or adversely affected by
 
degradation such as corrosion or fouling.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-10 acceptable because it adequately describes how the aging effects requiring management of loss of material
 
resulting from galvanic, general, pitting, and MIC mechanisms for carbon or low alloy steel
 
combinations would be managed for the components in question. Therefore, the staff's concern
 
described in RAI 2.3.3.A.9-10 is resolved. The above information is reflected in the ALRA.
In RAI 2.3.3.A.9-11 dated November 17, 2004, the staff stated that the GALL Report describes recommendations for aging management of the fire protection water system based on the
 
combination of component type, material, and environment.
The original LRA Table 3.3.2.A-8 for the auxilia ry systems for the NMP1 fire detection and protection system summarizes the aging managem ent program for each of the combinations mentioned above. When the combinations do not exactly match the requirements of the GALL
 
Report, the original LRA table includes a note indicating that the prescribed AMP has been
 
modified for use or that another AMP is being used.
For the combination of orifices, carbon or low alloy steel (yield strength < 100 Ksi), cast iron, raw water, and low flow, a table note indicates that the Fire Water System Program has been
 
modified to manage loss of material in orifices which are not specifically identified in GALL
 
Report Chapter VII for the fire protection system.
Therefore, to complete its review, the staff required further information regarding the use of the Fire Water System Program to manage loss of material for orifices. The staff requested that the
 
applicant supply the Fire Water System Program documents and procedures that are applicable
 
to the combination of orifices, carbon or low alloy steel (yield strength < 100 Ksi), raw water, and
 
low flow that are credited with managing loss of material in orifices.
In its response by letter dated December 17, 2004, the applicant stated that the population of orifices satisfying the criteria above is limited to flow orifice FO R-100-509 (diesel fire pump to EDG cooling). This orifice is susceptible to loss of material from galvanic, general, pitting, and
 
microbiologically influenced corrosion mechanisms. A fire system flow test and a site chemistry procedure are credited with managing the aging along with a new inspection activity yet to be
 
generated. As stated in the response by the applicant, these credited activities are as follows:
The new site activity (see NMP1 Commitment 20 and NMP2 Commitment 18) is identified as an enhancement in "parameters monitored/inspected" in original LRA Sections A1.1.18 and
 
B2.1.17. The enhancement adds procedural guidance for performing visual inspections to
 
monitor internal corrosion and detect biofouling. This new activity will include inspections for
 
loss of material in the above orifice and will be implemented prior to the period of extended
 
operation.
3-320 Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is credited with managing loss of material as a result of microbiological activity. This procedure provides
 
guidance for sampling and analysis of raw water systems for the presence of bacteria.
 
Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the Fire Water System
 
Program will be enhanced prior to the period of extended operation to include periodic sampling
 
of water-based fire protection systems.
Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with managing corrosion, biofouling, and microbiologically influenced corrosion of the fire protection water
 
distribution system. The testing actiivity provides full flow testing of the system in accordance with the NFPA Fire Protection Handbook. Acceptance criteria are defined and the site corrective
 
action process is utilized when the criteria are not met. The procedure verifies the system is
 
capable of retaining pressure and is not obstructed or degraded by corrosion or fouling.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-11 acceptable because it adequately describes how the aging effects requiring management for orifices would
 
be managed for the combination in question. Therefore, the staff's concern described in
 
RAI 2.3.3.A.9-11 is resolved. The above information is reflected in the ALRA.
In RAI 2.3.3.A.9-12 dated November 17, 2004, the staff stated that the GALL Report describes recommendations for aging management of the fire protection water system based on the
 
combination of component type, material, and environment.
The original LRA Table 3.3.2.A-8 for the auxilia ry systems for the NMP1 fire detection and protection system summarizes the AMP for each of the combinations mentioned above. When
 
the combinations do not exactly match the requirements of the GALL Report, the original LRA
 
table includes a note indicating that the prescribed AMP has been modified for use or that
 
another AMP is being used.
For the combination of orifices, wrought austenitic stainless steel, raw water, low flow, a table note indicates that the Fire Water System Program has been modified to manage cracking in addition to loss of material.
Another table note indicates that orifices are not specifically identified in GALL Report Chapter VII for the fire protection system.
Therefore, to complete its review, the staff required further information regarding the use of the Fire Water System Program to manage cracking and loss of material. The staff requested that
 
the applicant supply the Fire Water System Program documents and procedures that are
 
applicable to the combination of orifices, wrought austenitic stainless steel, raw water, and low
 
flow that are credited with managing cracking and loss of material.
In its response by letter dated December 17, 2004, the applicant stated that identification of the Fire Water System Program as the agi ng management program for cracking of wrought austenitic stainless steel orifices in raw water with low flow (original LRA Table 3.3.2.A-8) was
 
an error. The Fire Water System Program is focused on managing loss of material rather than
 
cracking. The One-Time Inspection Program should have been designated as the aging
 
management program for the subject flow orifices. Use of the One-Time Inspection Program to manage cracking is appropriate because the aging mechanism that can cause cracking of
 
wrought austenitic stainless steel in raw water with low flow is SCC. While SCC is possible in 3-321 non-brackish fresh water, it is unlikely. Therefore, a one-time inspection is sufficient to verify that SCC is not occurring. As presented in original LRA Sections A1.1.28 and B2.1.20, the
 
One-Time Inspection Program is a new AMP for NMP that is to be implemented prior to the period of extended operation. Development of the new program is a commitment made with the
 
original LRA submittal (see NMP1 Commitment 23 and NMP2 Commitment 21), as
 
supplemented by NMP Nuclear Station letter (NMP1L 1880) dated October 29, 2004. As such, NMP does not currently have any program doc uments or procedures specific to managing cracking of flow orifices in the fire water system. The One-Time Inspection Program attribute
 
assessment addresses program implementation at NMP relative to the requirements of SRP-LR Appendix A.
The subject orifices are also susceptible to loss of material from galvanic, general, pitting, and microbiologically influenced corrosion mechanisms. A new inspection activity, for which a procedure must be generated, a site chemistry procedure, and a fire system flow test are
 
credited with managing aging. These credited activities are discussed below:
* The new site activity is identified as an enhancement in "parameters monitored/ inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement adds procedural guidance
 
for performing visual inspections to monitor internal corrosion and to detect biofouling. This
 
new activity will include inspections for loss of material in the subject orifices and will be
 
implemented prior to the period of extended operation. As such, there are no existing
 
procedures implementing these inspections at this time. The Fire Water System Program
 
attribute assessment addresses program implementation at NMP relative to the
 
requirements of SRP-LR Appendix A
* Site pProcedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is credited with managing loss of material as a result of microbiological activity. The
 
procedure provides guidance for sampling and analysis of raw water systems for the
 
presence of bacteria. Acceptance criteria are defined and the site corrective action process
 
is utilized when the criteria are not met. Additionally, as presented in original LRA
 
Sections A1.1.18 and B2.1.17, the Fire Water System Program will be enhanced prior to
 
the period of extended operation to add specific requirements for periodic sampling of
 
water-based fire protection systems.
* Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with the possible discovery of corrosion, biofouling, and MICof the fire protection water distribution
 
system. The testing activity provides full flow testing of the system in accordance with the NFPA fire protection handbook. Acceptance criteria are defined and the site corrective
 
action process is utilized when the criteria are not met. The procedure, therefore, verifies
 
the system is capable of retaining pressure and is not obstructed or degraded by corrosion
 
or fouling.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-12 acceptable
 
because it adequately describes how the aging effects requiring management for orifices would
 
be managed for the combination in question. The applicant also revised the original LRA AMR
 
table for the component type in question to show the One-Time Inspection Program for the
 
management of cracking. Therefore, the staff's concern described in RAI 2.3.3.A.9-12 is
 
resolved.In RAI 2.3.3.A.9-13 dated November 17, 2004, the staff stated that the GALL Report describes recommendations for aging management of the fire protection water system based on the 3-322 combination of component type, material, and environment.
Original LRA Section 3.3.2.A-8 for the auxilia ry systems for the NMP1 fire detection and protection system summarizes the AMP for each of the combinations mentioned above. When
 
the combinations do not exactly match the requirements of the GALL Report, the original LRA
 
table includes a note indicating that the prescribed AMP has been modified for use or that
 
another AMP is being used.
For the combination of sluice gate for motor driven fire pump, carbon or low alloy steel (yield strength < 100 Ksi), raw water, and low flow, a table note indicates that the Fire Water System
 
Program has been modified to manage loss of material in the sluice gate for motor driven fire
 
pump which is not specifically identified in GALL Report Chapter VII for the fire protection system.Therefore, to complete its review, the staff required further information regarding the use of the Fire Water System Program to manage loss of material for the sluice gate for the motor driven
 
fire pump. The staff requested that the applicant supply the Fire Water System Program
 
documents and procedures that are applicable to the combination of sluice gate for motor driven
 
fire pump, carbon or low alloy steel (yield strength < 100 Ksi), raw water, and low flow that are
 
credited with managing loss of material in the sluice gate for motor driven fire pump.
In its response by letter dated December 17, 2004, the applicant stated that the sluice gate for the motor-driven fire pump is susceptible to loss of material from galvanic, general, pitting, and
 
MIC mechanisms. A new inspection activity (see NMP Commitment 20 and NMP2 Commitment 21), for which a procedure must be generated, a site chemistry procedure, and a fire system
 
flow test are credited with managing aging. These activities are discussed below:
* The new site activity is identified as an enhancement in "parameters monitored/inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes performing visual
 
inspections to monitor component corrosion and to detect biofouling. This new activity will
 
include inspections for loss of material in the sluice gates identified above and will be
 
implemented prior to the period of extended operation. As such, there are no existing
 
procedures implementing these inspections at this time. The Fire Water System Program
 
attribute assessment addresses program implementation at NMP relative to the
 
requirements of SRP-LR Appendix A.
* Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is credited with managing loss of material as a result of microbiological activity. The
 
procedure includes sampling and analysis of raw water systems for the presence of
 
bacteria. Acceptance criteria are defined and the site corrective action process is utilized
 
when the criteria are not met. Additionally, as presented in original LRA Sections A1.1.18
 
and B2.1.17, the Fire Water System Program will be enhanced prior to the period of
 
extended operation to add specific requirements for periodic sampling of water-based fire
 
protection systems.
* Site procedure N1-FST-FPW-3A001, "FPW System Flow Test," is credited with the possible discovery of corrosion, biofouling, and microbiologically influenced corrosion of the
 
fire protection water distribution system. The procedure provides for full flow testing of the
 
system in accordance with the NFPA fire protection handbook. Acceptance criteria are
 
defined and the site corrective action process is utilized when the criteria are not met. The 3-323 procedure verifies that the system is capable of retaining pressure and is not obstructed or adversely affected by degradation such as corrosion or fouling.
 
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-13 acceptable
 
because it adequately describes how the aging effects requiring management for sluice gates
 
would be managed for the combination in question. Therefore, the staff's concern described in RAI 2.3.3.A.9-13 is resolved.The above information is reflected in the ALRA.
In RAI 2.3.3.A.9-14 dated November 17, 2004, the staff stated that the GALL Report describes recommendations for aging management of the fire protection water system based on the
 
combination of component type, material, and environment.
The original LRA Table 3.3.2.A-8 for the auxilia ry systems for the NMP1 fire detection and protection system summarizes the AMP for each of the combinations mentioned above. When
 
the combinations do not exactly match the requirements of the GALL Report, the original LRA
 
table includes a note indicating that the prescribed AMP has been modified for use or that
 
another AMP is being used.
For the combination of spray nozzles, copper alloys (zinc <
15%), raw water, and low flow, a table note indicates that the Fire Water Sy stem Program has been modified to manage loss of material in the spray nozzles which are not specifically identified in GALL Report Chapter VII for
 
the fire protection system.
To complete its review, the staff required further information regarding the use of the Fire Water System Program to manage loss of material for spray nozzles. The staff asked the applicant to
 
supply the Fire Water System Program documents and procedures that are applicable to the
 
combination of spray nozzles, copper alloys (zinc  15%), raw water, low flow, that are credited with managing loss of material in spray nozzles.
In its response by letter dated December 17, 2004, the applicant stated that the spray nozzles fabricated from copper alloys (zinc <
15%), in an environment of raw water and low flow, are susceptible to loss of material. A new inspection activity (NMP1 Commitment 20 and NMP2
 
Commitment 18), for which a procedure must be generated, a site chemistry procedure, and a
 
fire system functional test are credited with managing aging. These activities are discussed
 
below: The new site activity is identified as an enhancem ent in "parameters monitored/inspected" in original LRA Sections A1.1.18 and B2.1.17. The enhancement includes performing visual
 
inspections to monitor component corrosion and to detect biofouling. This new activity will
 
include inspections for loss of material in the sluice gates identified above and will be
 
implemented prior to the period of extended operation. As such, there are no existing
 
procedures implementing these inspections at this time. The Fire Water System Program
 
attribute assessment addresses program implementat ion at NMP relative to the requirements of SRP-LR Appendix A.
Site procedure S-CTP-V632, "Sampling and Analysis of Water Systems for Bacteria," is credited with managing loss of material as a result of microbiological activity. The procedure includes
 
sampling and analysis of raw water systems for the presence of bacteria. Acceptance criteria
 
are defined and the site corrective action process is utilized when the criteria are not met.
 
Additionally, as presented in original LRA Sections A1.1.18 and B2.1.17, the Fire Water System 3-324 Program will be enhanced prior to the period of extended operation to add specific requirements for periodic sampling of water-based fire protection systems.
Site procedure N1-FST-FPW-C003, "Fire Protection Preaction, Deluge and Automatic Sprinkler Test," verifies the operability of the fire protection preaction, deluge, and automatic systems by
 
performing a system functional test which includes simulated automatic actuation of the system and a visual inspection of the sprinkler heads and system piping to verify their integrity and
 
verify no blockage. Acceptance criteria are defined and the site corrective action process is
 
utilized when the criteria are not met.
Based on its review, the staff found the applicant's response to RAI 2.3.3.A.9-14 acceptable because it adequately describes how the aging effects requiring management for spray nozzles
 
would be managed for the combination in question. Therefore, the staff's concern described in
 
RAI 2.3.3.A.9-14 is resolved.
By supplemental letter dated November 17, 2005, the applicant stated that an additional item will be added to Table 3.3.2.A-8. This being an external surfaces item for "gray cast iron in soil, above the water table" environment with the AERM of LOM, the AMP of Buried Piping and
 
Tanks Inspection Program, the GALL Report Item of VII.C2.1-b, the Type 1 Table Item of
 
3.3.1.A-18, and Note F. This item is added based on the determination that the barrel of the
 
gray cast iron fire hydrants is partially buried. The staff reviewed this change and found it
 
acceptable.
As documented in the Audit and Review Report, the staff requested that the applicant describe the aging management of the fire hose reel supports to capture the stated changes to the
 
Assessment Summary of the Fire Water Program Basis Document. The applicant subsequently
 
described the procedures used to test hose stations and standpipe. The applicant also stated
 
that when reviewing the AMR Reports and the ALRA, it was found that NMP2 credits the Fire
 
Protection Program for hose reels, while this "hose reels" was not included as a component type
 
for the NMP1 fire detection and protection system.
By supplemental letter dated December 1, 2005, the applicant stated an additional item will be added to ALRA Table 3.3.2.A-8. This component being "hose reels" with the intended function
 
of pressure boundary. The aging management information for this item will be the same shown
 
for hose reels in ALRA Table 3.3.2.B-13. The staff reviewed this change made to the ALRA and
 
found that it is acceptable for the aging management of hose reels.
By letter dated December 20, 2005, the applicant submitted a summary of the CLB changes that have occurred during the staff review of the application that materially affects the contents
 
of the application. The summary included an additional item added to ALRA Table 3.3.2.A-8.
 
This being a valve item for "gray cast iron in raw water, low flow table" environment with the
 
AERM of LOM, the AMP of Fire Water System and Selective Leaching of Materials Programs, the GALL Report Items of VII.G.6-b, VII.C1.5-a, the Type 1 Table Items of 3.3.1.A-21 3.3.1.A-
 
29, and Note A, C respectively. The applicant stated that the changes were made as a result of
 
replacing the carbon steel pressure safety valve that serves as the air release valve for the
 
NMP1 diesel-driven fire pump with a cast iron model. The staff reviewed these changes and
 
found that it is acceptable for the aging management of cast iron pressure safety valve.
3-325 An addition to the letters mentioned above, the staff also reviewed the applicant's letter, dated July 14, 2005. This letter detailed changes that were made to the LRA, and found in the ALRA.
 
The staff reviewed the changes to ALRA Table 3.3.2.A-8, and found that they are acceptable.
In its letter dated December 1, 2005, the applicant stated that the note for bolting will be modified from A to B in Table 3.3.2.A-8. This change is due to an exception found in the Bolting
 
Integrity Program, which is the AMP for bolting. The staff evaluation for this exception is
 
documented in Section 3.0.3.2.23. This staff reviewed the change in note, and found that it is
 
acceptable.
3.3A.2.3.9  Auxiliary Systems NMP1 Hydrogen Water Chemistry System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-9 The staff reviewed ALRA Table 3.3.2.A-9, which summarizes the results of AMR evaluations for the hydgrogen water chemistry system com ponent-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-9. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.10-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include flow element, piping and fittings, and valves.
For these component types the applicant identified the following materials, environments, and AERMs:
* wrought austenitic stainless steel exposed to treated water or steam, temperature > 212 &deg;F,but < 482 &deg;F, subject to cracking The staff reviewed the information In ALRA Section 2.3.3.A.10, Table 2.3.3.A.10-1, Section 3.3.2.A.9, and Table 3.3.2.A-9.
The staff's review of the information provided in the ALRA found the aging effects of the hydrogen water chemistry system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The
 
staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had
 
identified the appropriate aging effects for the materials and environments of the components in
 
the hydrogen water chemistry system.
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-9 identifies the following AMPs for managing the aging effects for the hydrogen water chemistry system com ponents not addressed by the GALL Report:
* One-Time Inspection Program
* Water Chemistry Control Program 3-326 The staff's detailed review of these AMPs is found in Sections 3.0.3.1.4 and 3.0.3.2.2 of this SER. Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the hydgrogen water chemistry system components will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.10  Auxiliary Systems NMP1 Liqui d Poison System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-10 The staff reviewed ALRA Table 3.3.2.A-10, which summarizes the results of AMR evaluations for the liquid poison system component groups.
This auxiliary system is listed here for inform ation and completeness. The AMR results for the NMP1 liquid poison system are consistent with the GALL Report. The staff's evaluation of these results is presented in SER Section 3.3A.2.2.5 3.3A.2.3.11  Auxiliary Systems NMP1 Mi scellaneous Non Contaminated Vents and Drains System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-11 The staff reviewed ALRA Table 3.3.2.A-11, which summarizes the results of AMR evaluations for the miscellaneous non contaminated vents and drains system of those AERM combinations
 
not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-11. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.12-1lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include piping and fittings.
For these component types, the applicant identified the following materials, environments, and AERMs:
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.12, Table 2.3.3.A.12-1, Section 3.3.2.A.11, and Table 3.3.2.A-1. During its review the staff determined that additional
 
information was needed.
The RAIs are organized in two groups, general and system-specific. The general RAI applicable to this system is a-RAI 3.3.2-1 3-327 In a-RAI 3.3.2-1 dated November 2, 2005, the staff requested that the applicant provide additional information on the system aging effects. By letter dated November 30, 2005, the
 
applicant responded. The RAI, the applicant's response, and the staff's evaluation of the
 
response are described in SER Section 3.3A.2.3.0.
There are no relevant system-specific RAIs associated with this system.
The staff's review of the information provided in the ALRA and the additional information in the applicant's response to the RAI found the aging effects of the miscellaneous noncontaminated
 
vents and drains system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not
 
identify any omitted aging effects. Therefore, the staff found that the applicant had identified the
 
appropriate aging effects for the materials and environments of the components in the
 
miscellaneous noncontaminated vents and drains system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-11 identifies the following AMPs for managing the aging effects for the miscellaneous noncontaminated vents and drains system components not addressed by the GALL Report:
* One-Time Inspection Program
 
In the applicant's response to general RAI a-RAI 3.3.2-1, dated November 30, 2005, as described in SER Section 3.3A.2.3.0 the applicant revised its management strategy for the
 
aging effects of some components in this syst em by replacing the One-Time Inspection Program with the Preventive Maintenance Program. The staff's detailed review of the
 
Preventive Maintenance Program is in SER Section 3.0.3.3.1.
Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the miscellaneous non contaminated v ents and drains system components will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.12  Auxiliary Systems NMP1 Neut ron Monitoring System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-12 This auxiliary system is listed here for inform ation and completeness. The AMR results for the NMP1 neutron monitoring system are consistent with the GALL Report. The staff's evaluation of these results is presented in SER Section 3.3A.2.2.5 3-328 3.3A.2.3.13  Auxiliary Systems NMP1 Radioac tive Waste Solidification and Storage Building HVAC System - Summary of Aging Managem ent Evaluation - ALRA Table 3.3.2.A-13 This auxiliary system is listed here for inform ation and completeness. The AMR results for the NMP1 radioactive waste solidification and storage building HVAC system are consistent with the
 
GALL Report. The staff's evaluation of these results is presented in SER Section 3.3A.2.2.5 3.3A.2.3.14  Auxiliary Systems NMP1 Radi oactive Waste System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-14 The staff reviewed ALRA Table 3.3.2.A-14, which summarizes the results of AMR evaluations for the radioactive waste system component-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-14 as revised in the applicant's letter NMPIL 2005 dated December 1, 2005. The
 
staff verified that the applicant had identified all AERMs and had credited appropriate AMPs with
 
managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs to
 
ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.16-1 lists individual system components within the scope of license renewal and subject to AMR. The component types that do not rely on the GALL Report
 
for an AMR include external surfaces, filters/strainers, flow element, heat exchangers, piping
 
and fittings, pumps, separator, tanks, and valves.
For these component types the applicant identified the following materials, environments, and AERMs:
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water subject to loss of material
* gray cast iron exposed to air subject to loss of material
* wrought austenitic stainless steel exposed to demineralized untreated water subject to loss of material
* wrought austenitic stainless steel exposed to air, moisture or wetting, temperature > 140 &deg;F, subject to loss of material
* nickel based alloys exposed to demineralized untreated water subject to loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to treated water, temperature
> 140 &deg;F, but < 212 &deg;F, subject to loss of material
* gray cast iron exposed to demineralized untreated water subject to loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to treated water, temperature< 140 &deg;F, subject to loss of material
* cast austenitic stainless steel exposed to demineralized untreated water subject to loss of material
* wrought austenitic stainless steel exposed to treated water, temperature < 140 &deg;F, subject to loss of material
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated water, low flow, subject to loss of material 3-329
* copper alloys (zinc < 15 percent) exposed to demineralized untreated water subject to loss of material
* wrought austenitic stainless steel exposed to treated water, temperature > 140 &deg;F, but< 212 &deg;F, subject to cracking The staff reviewed the information in ALRA Section 2.3.3.A.16, Table 2.3.3.A.16-1, Section 3.3.2.A.14, and Table 3.3.2.A-14. During its review, the staff determined that additional
 
information was needed.
The RAIs are organized in two groups, general and system-specific. The general RAI applicable to this system is a-RAI 3.3.2-1 as discussed below:
By letter dated November 2, 2005, the staff requested that the applicant provide additional information on the issue addressed in a-RAI 3.3.2-1. By letter dated November 30, 2005, the
 
applicant responded. The RAI, the applicant's response, and the staff's evaluation of the
 
response are described in SER Section 3.3A.2.3.0.
There are no relevant system-specific RAIs for this system.
 
The staff's review of the information provided in the ALRA and the additional information included in the applicant's response to the RAI found the aging effects of the radioactive waste
 
system component types not addressed by t he GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not identify any
 
omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate
 
aging effects for the materials and environments of the components in the radioactive waste system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-14 identifies the following AMPs for managing the aging effects for the radioactive waste system components not addressed by the GALL Report:
* One-Time Inspection Program
* Selective Leaching of Materials Program
* System Walkdown Program In the applicant's response to general RAI a-RAI 3.3.2-1 as described in SER Section 3.3A.2.3.0, the applicant revised its strategy for managing the aging effects of some
 
components in this system by replacing the O ne-Time Inspection Program with the Preventive Maintenance Program. The staff's detailed review of the Preventive Maintenance Program is in
 
SER Section 3.0.3.3.1.
The staff's detailed review of Selective Leaching of Materials Program and System Walkdown Program is in SER Sections 3.0.3.1.5 and 3.0.3.3.2.
3-330
 
== Conclusion:==
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the radioactive waste system components will be adequately managed so that the intended
 
functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.15  Auxiliary Systems NMP1 Reacto r Building Closed Loop Cooling Water System -
Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-15 The staff reviewed ALRA Table 3.3.2.A-15, which summarizes the results of AMR evaluations for the reactor building closed loop cooli ng water system com ponent-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F
 
through J in ALRA Table 3.3.2.A-15 as revised by the applicant's letter NMPIL 1996 dated
 
November 17, 2005, the applicant's response to a-RAI 3.3.2.A-5-1 dated November 30, 2005, and the applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that the
 
applicant had identified all AERMs and had credited appropriate AMPs with managing them.
 
The staff also reviewed the applicable UFSAR supplements for the AMPs to ensure that the
 
program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.17-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include external surfaces, filt ers/strainers, flow elements, heat exchangers, orifices, piping and fittings, pumps, temperature elements, and valves.
For these component types, the applicant identified the following materials, environments, and AERMs:
* gray cast iron exposed to air subject to loss of material
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated water subject to loss of material
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water subject to loss of material
* gray cast iron exposed to demineralized untreated water, or demineralized untreated water, low flow, subject to loss of material
* wrought austenitic stainless steel exposed to demineralized untreated water subject to loss of material
* carbon or low alloy steel (yield strength < 100 ksi) exposed to demineralized untreated water subject to loss of heat transfer
* copper alloys (zinc > 15 percent) and aluminum bronze exposed to demineralized untreated water subject to loss of heat transfer and loss of material
* copper alloys (zinc > 15 percent) and aluminum bronze exposed to raw water, low flow, subject to loss of heat transfer and loss of material 3-331
* copper alloys (zinc > 15 percent) and aluminum bronze exposed to treated water,temperature < 140 &deg;F, subject to loss of heat transfer
* wrought austenitic stainless steel exposed to demineralized untreated water subject to loss of heat transfer
* wrought austenitic stainless steel exposed to raw water subject to loss of heat transfer
* wrought austenitic stainless steel exposed to treated water, temperature > 482 &deg;F, subject to cracking
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to raw water, low flow, subject to loss of material
* wrought austenitic stainless steel exposed to demineralized untreated water, low flow, subject to loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to air, Moisture or wetting,temperature < 140 &deg;F, subject to loss of material
* carbon or low alloy steel (Yield strength < 100 Ksi) exposed to demineralized untreated water, low flow, subject to loss of material
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water, low flow, subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.17, Table 2.3.3.A.17-1, Section 3.3.2.A.15, and Table 3.3.2.A-15. During its review the staff determined that additional
 
information was needed.
The RAIs are organized in two groups, general and system-specific. There are no general RAIs associated with this system. System-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The staff's detailed review of the applicant's response to a-RAI 3.3.2.A-5-1 is in SER
 
Section 3.3A.2.3.5.
The staff's review of the information provided in the ALRA and the additional information included in the applicant's response to the RAI found the aging effects of the reactor building
 
closed loop cooling water system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The
 
staff did not identify any omitted aging effects. Therefore, the staff found that the applicant had
 
identified the appropriate aging effects for the materials and environments of the components in
 
the reactor building closed loop cooling water system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the program adequately.
ALRA Table 3.3.2.A-15 identifies the following AMPs for managing the aging effects for the reactor building closed loop cooling water system components not addressed by the GALL
 
Report:
* System Walkdown Program
* Closed-Cycle Cooling Water System Program 3-332
* Selective Leaching of Materials Program
* One-Time Inspection Program
* Water Chemistry Control Program The staff's detailed review of the AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.8, 3.0.3.1.5, 3.0.3.1.4, and 3.0.3.2.2.
 
==
Conclusion:==
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the reactor building closed loop cooling water system components will be adequately
 
managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.16  Auxiliary Systems NMP1 Reacto r Building HVAC System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-16 The staff reviewed ALRA Table 3.3.2.A-16, which summarizes the results of AMR evaluations for the reactor building HVAC system com ponent-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-16. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.18-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include external surfaces and flow elements.
For these component types the applicant identified the following materials, environments, and AERMs:
* gray cast iron exposed to air subject to loss of material
* gray cast iron exposed to air, moisture or wetting, temperature < 140 &deg;F, subject to loss of material
* polymers exposed to air subject to cracking, hardening and shrinkage, and loss of strength The staff reviewed the information in ALRA Section 2.3.3.A.18, Table 2.3.3.A.18-1, Section 3.3.2.A.16, and Table 3.3.2.A-16.
The staff's review of the information provided in the ALRA found the aging effects of the reactor building HVAC system component types not addr essed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not
 
identify any omitted aging effects. Therefore, the staff found that the applicant had identified the
 
appropriate aging effects for the materials and environments of the components in the reactor
 
building HVAC system.
 
3-333 Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-16 identifies the following AMPs for managing the aging effects for the reactor building HVAC system com ponents not addressed by the GALL Report:
* System Walkdown Program
* One-Time Inspection Program The staff's detailed review of these AMPs is in SER Sections 3.0.3.3.2 and 3.0.3.1.4.
 
==
Conclusion:==
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the reactor building HVAC system components will be adequately managed so that the
 
intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.17  Auxiliary Systems NMP1 Reac tor Water Cleanup System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-17 The staff reviewed ALRA Table 3.3.2.A-17, which summarizes the results of AMR evaluations for the reactor water cleanup system component-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-17 as revised by the applicant's letter NMPIL 1996 dated November 17, 2005, the
 
applicant's response to a-RAI 3.3.2.A-5-1 dated November 30, 2005, and the applicant's letter
 
NMPIL 2005 dated December 1, 2005. The staff verified that the applicant had identified all
 
AERMs and had credited appropriate AMPs with managing them. The staff also reviewed the
 
applicable UFSAR supplements for the AMPs to ensure that the program descriptions describe
 
them adequately.
Aging Effects. ALRA Table 2.3.3.A.19-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include bolting, heat exchangers, piping and fittings, and pumps.
For these component types the applicant identified the following materials, environments, and AERMs:
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to demineralized untreated water, low flow, subject to loss of material
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water or steam, temperature > 212 &deg;F, but < 482 &deg;F, subject to cumulative fatigue damage and loss of material 3-334
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water subject to loss of material
* wrought austenitic stainless steel exposed to demineralized untreated water subject to loss of material
* gray cast iron exposed to treated water, temperature < 140 &deg;F, subject to loss of material The staff reviewed the information in Section 2.3.3.A.19, Table 2.3.3.A.19-1, Section 3.3.2.A.17, and Table 3.3.2.A-17 of the ALRA. During its review the staff determined that additional
 
information was needed.
The RAIs are organized in two groups, general and system-specific. There are no general RAIs associated with this system. System-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The staff's detailed review of the applicant's response to a-RAI 3.3.2.A-5-1 is in SER
 
Section 3.3A.2.3.5.
The staff's review of the information provided in the ALRA and the additional information included in the applicant's response to the RAI found the aging effects of the reactor water
 
cleanup system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not identify any
 
omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate
 
aging effects for the materials and environments of the components in the reactor water cleanup system.Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the program adequately.
ALRA Table 3.3.2.A-17 identifies TLAA and the following AMPs for managing the aging effects for the reactor water cleanup system components not addressed by the GALL Report:
* Closed-Cycle Cooling Water System Program
* Flow-Accelerated Corrosion Program
* One-Time Inspection Program
* Water Chemistry Control Program
* Selective Leaching of Materials Program The staff's evaluation of the TLAA is in SER Section 4.3. The staff's detailed review of the AMPs is in SER Sections 3.0.3.2.8, 3.0.3.13, 3.0.3.1.4, 3.0.3.2.2, and 3.0.3.1.5.
 
==
Conclusion:==
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the reactor water cleanup system components will be adequately managed so that the
 
intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3-335 3.3A.2.3.18  Auxiliary Systems NMP1 Sa mpling System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-18 The staff reviewed ALRA Table 3.3.2.A-18, which summarizes the results of AMR evaluations for the sampling system component-material-env ironment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA Table 3.3.2.A-18 as
 
revised by the applicant's letter NMPIL 2005 dated December 1, 2005. The staff verified that the
 
applicant had identified all AERMs and had credited appropriate AMPs with managing them.
 
The staff also reviewed the applicable UFSAR supplements for the AMPs to ensure that the
 
program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.20-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include heat exchangers, piping and fittings, and rupture disc.
For these component types the applicant identified the following materials, environments, and AERMs:
* elastomer exposed to raw water subject to hardening and shrinkage
* wrought austenitic stainless steel exposed to treated water or steam, temperature > 482 &deg;F, low flow, subject to cracking The staff reviewed the information in ALRA Section 2.3.3.A.20, Table 2.3.3.A.20-1, Section 3.3.2.A.18, and Table 3.3.2.A-18.
The staff's review of the information provided in the ALRA and the additional information included in the applicant's response to the RAI found the aging effects of the sampling system
 
component types not addressed by the GALL Report consistent with industry experience for
 
these combinations of materials and environments. The staff did not identify any omitted aging
 
effects. Therefore, the staff found that the applicant had identified the appropriate aging effects
 
for the materials and environments of the components in the sampling system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the program adequately.
ALRA Table 3.3.2.A-18 identifies the following AMPs for managing the aging effects for the sampling system components not addressed by the GALL Report :
* One-Time Inspection Program
* Water Chemistry Control Program
* Preventive Maintenance Program The staff's detailed review of the above AMPs is in SER Sections 3.0.3.1.4, 3.0.3.2.2, and 3.0.3.3.1.
Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated 3-336 with the sampling system component components will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.19  Auxiliary Systems NMP1 Servic e Water System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-19 The staff reviewed ALRA Table 3.3.2.A-19, which summarizes the results of AMR evaluations for the service water system component-m aterial-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-19. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.21-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include external surfaces and filters/strainers.
For these component types, the applicant identified the following materials, environments, and AERMs:
* copper alloys (zinc > 15 percent) and aluminum bronze exposed to air subject to loss of material
* gray cast iron exposed to air subject to loss of material
* gray cast iron exposed to raw water subject to loss of material The staff reviewed the information in ALRA Section 2.3.3.A.21, Table 2.3.3.A.21-1, Section 3.3.2.A.19, and Table 3.3.2.A-19.
The staff's review of the information provided in the ALRA found the aging effects of the service water system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not identify any
 
omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate
 
aging effects for the materials and environments of the components in the service water system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-19 identifies the following AMPs for managing the aging effects for the service water system components not addressed by the GALL Report :
* System Walkdown Program
* Open-Cycle Cooling Water System Program 3-337
* Selective Leaching of Materials Program The staff's detailed review of these AMPs is in SER Sections 3.0.3.3.2, 3.0.3.2.7, and 3.0.3.1.5.
 
==
Conclusion:==
 
On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the service water system component s will be adequately managed so that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.20  Auxiliary Systems NMP1 Shut down Cooling System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-20 The staff reviewed ALRA Table 3.3.2.A-20, which summarizes the results of AMR evaluations for the shutdown cooling system component-m aterial-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in ALRA
 
Table 3.3.2.A-20. The staff verified that the applicant had identified all AERMs and had credited
 
appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.22-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include heat exchangers.
For these component types the applicant identified the following materials, environments, and AERMs:
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water, temperature
< 140 degree F, subject to loss of heat transfer The staff reviewed the information in ALRA Section 2.3.3.A.22, Table 2.3.3.A.22-1, Section 3.3.2.A.20, and Table 3.3.2.A-20.
The staff's review of the information provided in the ALRA found the aging effects of the shutdown cooling system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not
 
identify any omitted aging effects. Therefore, the staff found that the applicant had identified the
 
appropriate aging effects for the materials and environments of the components in the shutdown
 
cooling system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing them. The staff also verified that the UFSAR supplement describes
 
the programs adequately.
3-338 ALRA Table 3.3.2.A-20 identifies the following AMP for managing the aging effects for the shutdown cooling system components not addressed by the GALL Report:
* Open-Cycle Cooling Water System Program
 
The staff's detailed review of this AMP is in SER Sections 3.0.3.2.7.
 
Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the shutdown cooling system components will be adequately managed so that the intended
 
functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.21  Auxiliary Systems NMP1 Spent Fuel Pool Filtering and Cooling System - Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-21 The staff reviewed ALRA Table 3.3.2.A-21, which summarizes the results of AMR evaluations for the spent fuel pool filtering and cooli ng system component-mat erial-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F through J in
 
ALRA Table 3.3.2.A-21 as revised by the applicant's response to a-RAI 3.3.2.A-5-1 dated
 
November 30, 2005 and the applicant's letter NMPIL 2005 dated December 1, 2005. The staff
 
verified that the applicant had identified all AERMs and had credited appropriate AMPs with
 
managing them. The staff also reviewed the applicable UFSAR supplements for the AMPs to
 
ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.23-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include external surfaces, filters/strainers, heat exchangers, pump, andvalves.For these component types the applicant identified the following materials, environments, and AERMs:
* gray cast iron exposed to air subject to loss of material
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water, temperature< 140 &deg;F, oxygenated, subject to loss of material
* wrought Austenitic stainless steel exposed to demineralized untreated water subject to loss of heat transfer and loss of material
* copper alloys (zinc <
15 percent) exposed to demineralized untreated water subject to loss of material
* copper alloys (zinc < 15 percent) exposed to treated water, temperature <  &deg;F, oxygenated, subject to loss of material 3-339
* gray cast iron exposed to treated water, temperature < 140 &deg;F, oxygenated, subject to loss of material
* aluminum alloys containing copper or zinc as the primary alloying elements exposed totreated water, temperature < 140 &deg;F, oxygenated, subject to cracking
* aluminum alloys containing copper or zinc as the primary alloying elements exposed totreated water, temperature < 140 &deg;F, low flow, oxygenated, subject to cracking
* carbon or low alloy steel (yield strength < 100 Ksi) exposed to treated water, temperature< 140 &deg;F, low flow, oxygenated, subject to loss of material
* copper alloys (zinc < 15 percent) exposed to treated water, temperature < 140 &deg;F, low flow, oxygenated, subject to loss of material
* aluminum, and aluminum alloyed with manganese, magnesium, and magnesium plussilicon exposed to treated water, temperature < 140 &deg;F, oxygenated, subject to loss of
 
material The staff reviewed the information in ALRA Section 2.3.3.A.23, Table 2.3.3.A.23-1, Section 3.3.2.A.21, and Table 3.3.2.A-21. During its review the staff determined that additional
 
information was needed.
The RAIs are organized in two groups, general and system-specific. There are no general RAIs associated with this system. System-specific a-RAI 3.3.2.A-5-1 is applicable to this system. The staff's detailed review of the applicant's response to a-RAI 3.3.2.A-5-1 is in SER
 
Section 3.3A.2.3.5.
The staff's review of the information provided in the ALRA and the additional information in the applicant's response to the RAI found the aging effects of the spent fuel pool filtering and
 
cooling system component types not addressed by the GALL Report consistent with industry experience for these combinations of materials and environments. The staff did not identify any
 
omitted aging effects. Therefore, the staff found that the applicant had identified the appropriate
 
aging effects for the materials and environments of the components in the spent fuel pool
 
filtering and cooling system.
 
Aging Management Programs. After evaluating the applicant's identification of aging effects for each of the components the staff evaluated the AMPs to determine whether they are
 
appropriate for managing the identified aging effects. The staff also verified that the UFSAR
 
supplement describes the programs adequately.
ALRA Table 3.3.2.A-21 identifies the following AMPs for managing the aging effects for the spent fuel pool filtering and cooling system components not addressed by the GALL Report:
* System Walkdown Program
* One-Time Inspection Program
* Water Chemistry Control Program
* Closed-Cycle Cooling Water System Program The staff's detailed review of the AMPs is in SER Sections 3.0.3.3.2, 3.0.3.1.4, 3.0.3.2.2, and 3.0.3.2.8.
3-340 Conclusion
: On the basis of its review, as discussed above, the staff concludes that there is reasonable assurance that the applicant has demonstrated that the aging effects associated
 
with the spent fuel pool filtering and cooling system components will be adequately managed so
 
that the intended functions 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 applicable UFSAR supplement program descriptions and concludes that the UFSAR supplement provides an adequate description of the AMPs credited for
 
managing aging of these components, as required by 10 CFR 54.21(d).
3.3A.2.3.22  Auxiliary Systems NMP1 Turbi ne Building Closed Loop Cooling Water System -
Summary of Aging Management Evaluation - ALRA Table 3.3.2.A-22 The staff reviewed ALRA Table 3.3.2.A-22, which summarizes the results of AMR evaluations for the turbine building closed loop cooli ng water system com ponent-material-environment AERM combinations not addressed in the GALL Report. These combinations use Notes F
 
through J in ALRA Table 3.3.2.A-22 as revised by the applicant's letter NMPIL 1996, dated
 
November 17, 2005. The staff verified that the applicant had identified all AERMs and had
 
credited appropriate AMPs with managing them. The staff also reviewed the applicable UFSAR
 
supplements for the AMPs to ensure that the program descriptions describe them adequately.
Aging Effects. ALRA Table 2.3.3.A.25-1 lists individual system components within the scope of license renewal and subject to an AMR. The component types that do not rely on the GALL
 
Report for an AMR include heat exchangers, piping and fittings, pumps, strainers, tanks, and valves.For this component typ}}

Latest revision as of 08:42, 15 January 2025

Safety Evaluation Report Related to the License Renewal of the Nine Mile Point Nuclear Station, Units 1 and 2
ML061460313
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 06/01/2006
From:
Office of Nuclear Reactor Regulation
To:
Le N. B., NRR/DLR/RLRB, 415-1458
Shared Package
ML061460333 List:
References
TAC MC3272, TAC MC3273
Download: ML061460313 (993)
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