HNP-07-124, License Renewal Application Amendment 3 and Responses to Requests for Additional Information - Questions Related to Scoping and Aging Management Review Methodology

License Renewal Application Amendment 3 and Responses to Requests for Additional Information - Questions Related to Scoping and Aging Management Review Methodology

ML072750528
Person / Time
Site:	Harris
Issue date:	09/24/2007
From:	Natale T Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-07-124
Download: ML072750528 (12)

Text

Progress Energy SEP 2 4 2007 SERIAL: HNP-07-124 10 CFR 54 U. S. Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, DC 20555

References:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 LICENSE RENEWAL APPLICATION AMENDMENT 3 AND RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION

-QUESTIONS RELATED TO SCOPING AND AGING MANAGEMENT REVIEW METHODOLOGY

1. Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: I-INP-06-136), "Application for Renewal of Operating License," dated November 14, 2006 2. Letter from Maurice Heath (NRC) to Robert J. Duncan II, "Requests for Additional Information for the Review of the Shearon Harris Nuclear Power Plant, Unit 1, License Renewal Application," dated August 27, 2007 3. Letter from Thomas J. Natale to the U. S. Nuclear Regulatory Commission (Serial: HNP-07-115), "Responses to Requests for Additional Information

-License Renewal Application:

Questions Related to Scoping of Fire Protection Components, Engineered Safety Features, and Civil Structures," dated September 5, 2007 4. Letter from Thomas J. Natale to the U. S. Nuclear Regulatory Commission (Serial: HNP-07-122), "Responses to Requests for Additional Information

-License Renewal Application

-Additional Questions Related to Scoping and Screening Methodology and Results," dated September 18, 2007 Ladies and Gentlemen:

On November 14, 2006, Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc., requested the renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (HNP), to extend the term of its operating license an additional 20 years beyond the current expiration date.By letter dated August 27, 2007, the Nuclear Regulatory Commission (NRC) provided requests for additional information (RAIs) concerning the HNP License Renewal Application.

This letter provides responses to those RAIs.Progress Energy Carolinas, Inc.Hariis Nuclear Plant P. 0. Box 165 New Hill, NC 27562 At,)-(,

Document Control Desk HNP-07-124

/ Page 2 Also, by letters dated September 5, 2007 and September 18, 2007, ProgressEnergy Carolinas responded to previous NRC RAIs regarding License Renewal. In those letters, the need to amend the HNP License Renewal Application (LRA) was identified.

Based on the above, this letter contains two enclosures.

Enclosure 1 provides responses to the RAIs in the NRC letter dated August 27, 2007. Enclosure 2 is a table that identifies the changes to the LRA and the source of those changes. Neither this letter nor the enclosures contain any new or revised regulatory commitments.

Any actions identified herein should be considered intended or planned actions; they are included for informational purposes but are not considered to be regulatory commitments.

Please refer any questions regarding this submittal to Mr. Roger Stewart, Supervisor

-License Renewal, at (843) 857-5375.I declare, under penalty of perjury, that the foregoing is true and correct (Executed on SEP 2 4 2007 )*Sincerely, Thomas J. Natale Manager -Support Services Harris Nuclear Plant TJN/hnhf

Enclosures:

1. Responses to Requests for Additional Information dated August 27, 2007 2. Amendment 3 Changes to the License Renewal Application cc: Mr. P. B. O'Bryan (NRC Senior Resident Inspector, HNP)Ms. B. 0. Hall (Section Chief, N.C. DENR)Mr. M. L. Heath (NRC License Renewal Project Manager, HNP)Ms. M. G. Vaaler (NRC Project Manager, HNP)Dr. W. D. Travers (NRC Regional Administrator, Region II)

HINP-07-124 Enclosure 1 Page 1 of 7 Responses to Requests for Additional Information dated August 27, 2007 Background On November 14, 2006, Carolina Power & Light Company (CP&L), doing business as Progress Energy Carolinas, Inc., requested the renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (HNP), to extend the term of its operating license an additional 20 years beyond the current expiration date.By letter dated August 27, 2007, the Nuclear Regulatory Commission (NRC) provided requests for additional information (RAIs) concerning the HNP License Renewal Application.

This enclosure provides the responses to the NRC RAIs.Table of Contents Page N R C R A I 2 .3 .3 -1 .............................................................................................................................

1 N R C R A I 2 .3 .3 -2 .............................................................................................................................

1 N R C R A I 2 .3 .3 -3 .............................................................................................................................

3 N R C R A I 2 .3 .3-4 ........................

....................................................................................................

4 NRC RAI 2.3.3-5............................................................................................

.4 NRC RAI 2.3.3-6 .................................................................................................

4 N R C R A I 2 .3 .3-7 .............................................................................................................................

6 NRC RAI 2.3.3-1 The top of license renewal application (LRA) page 3.3-440 reads: "Notes for Tables 3.3.2-1 through 3.3.2-68:" It appears that these Notes are also applicable to Tables 3.3.2-69 through 3.3.2-71.

Also, the top of page 3.5-198 reads: "Notes for Tables 3.5.2-1 through 3.5.2-26." It appears that these Notes are also applicable to Tables 3.5.2-27 through 3.5.2-29.

Please confirm.RAI 2.3.3-1 Response Yes, the notes are applicable as described.

These notes were addressed in Amendment I to the LRA as Self-Identified Changes 2 and 3 on page 12 of Enclosure 2 of HNP Letter to the NRC Serial: HNP-07-112, dated August 20, 2007, ML072350552.

NRC RAI 2.3.3-2 Plant Specific Note No. 716 for Tables 3.3.2-1 through 3.3.2-68 (LRA Page 3.3-447) reads"Alignments for piping and ducting may be considered equivalent components.

This is supported by equivalencies in NUREG-1801, such as found in NUREG-1801,Section V.A-I ." NUREG-1801 Section VA Engineered Safety Features -Containment Spray System (PWR) has an Item V.A-I for Steel Ducting, piping and components external surfaces in Air -Indoor uncontrolled (External) environment with the effect being loss of material/general corrosion and identifies the HNP-07-124 Enclosure 1 Page 2 of 7 applicable aging management program as NUREG- 1801 Chapter XI.M36, "External Surfaces Monitoring." Is this the "Section V.A-I" being referred to? What is the definition of"alignments"?

Are "alignments for piping and ducting" referring to supports, fittings /components, assemblies or something else? In what sense or with what are they "considered equivalent components" and exactly how does NUREG- 1801 Section VA Item V.A- 1 support this equivalency determination?

RAI 2.3.3-2 Response The response to this RAI is organized into four parts corresponding to the separate questions in the RAI. The questions are quoted, and the answer follows the quote.Part I NUREG-1801 Section VA Engineered Safety Features -Containment Spray System (PWR)has an Item V.A-1 for Steel Ducting, piping and components external surfaces in Air -Indoor uncontrolled (External) environment with the effect being Loss of material / general corrosion and identifies the applicable aging management program as NUREG-1801 Chapter XI.M36, "External Surfaces Monitoring".

Is this the "Section V.A-I" being referred to?Yes.Part II What is the definition of "alignments"?

Referring to Section 4.2.2 of NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 -The License Renewal Rule," Rev. 6, "alignments" are discussed as follows: Section 4.2.2 Consistency With NUREG-1801 Volume 2 Line Items: Each combination of component type, material, environment and aging effect requiring management should be compared with NUREG-1801 Volume 2 line items to identify consistencies.

If there is no corresponding line item in NUREG-1801 Volume 2, the combination is a plant-specific aging evaluation result.Each applicant should identify how the aging evaluation results align with information in NUREG-1801, Volume 2. This is accomplished through a series of notes identified on Table 4.2-2. All note references with letters are standard notes that will be the same from application to application throughout the industry.

Any notes the plant requires that are in addition to the standard notes will be identified by a number and deemed plant-specific.This alignment process is discussed in more detail in LRA Section 3.0.

HNP-07-124 Enclosure 1 Page 3 of 7 Part III Are "alignments for piping and ducting" referring to supports, fittings/components, assemblies or something else?No. See discussion above.Part IV In what sense or with what are they "considered equivalent components" and exactly how does NUREG-1801 Section VA Item V.A-1 support this equivalency determination?

The various NUREG- 1801 chapters contain summary descriptions and tabulations of evaluations of aging management programs for structures and components in the various major plant systems in light-water reactor nuclear power plants. However, the evaluations in NUREG-1 801 for a given system may not contain all of the material/environment combinations likely to be encountered.

For example, NUREG-1801, Volume 2,Section VII, AUXILIARY SYSTEMS, F3 Primary Containment Heating and Ventilation System (i.e., VII F3), contains only one line item for stainless steel ducting (VII.F3-1).

This line item contains condensation as the only environment choice. Referring to LRA Table 3.3.2-56 on Page 3.3-370 for the line items Containment Cooling System -ducting and components/stainless steel -Air/Gas (Wetted) (Inside) and Air -Indoor (Outside), it was deemed that a better alignment could be made to a line item in a different NUREG-1801 Section (i.e., VII.J-15) that is described as components of the type"Piping, piping components, and piping elements." Note 716 is stating that the duct and pipe are considered equivalent components and provides an example in NUREG-1801 (i.e., V.A-1) where precedence for such an equivalency is made.Section VA Item V.A-I supports this equivalency determination because the component"ducting" is treated equivalently with the component "piping and components" in this line item.NRC RAI 2.3.3-3 Drawing 8-G-0517-LR has a box shaded green titled "DISCHARGE FROM CRDM COOLING FANS" at grid location G-9. Is this depicting a common discharge ductwork plenum -or just a contaimnent volume where mixing occurs? If the latter, why is it highlighted green?RAI 2.3.3-3 Response The box shaded green titled "DISCHARGE FROM CRDM COOLING FANS" at grid location G-9 on drawing 8-G-0517-LR represents the volume of air within the containment to which the Control Rod Drive Mechanism (CRDM) Cooling fans discharge.

This volume should not have been highlighted on the subject scoping drawing.

HNP-07-124 Enclosure 1 Page 4 of 7 NRC RAI 2.3.3-4 Drawing 8-G-0517-SO3-LR Grid B-2 shows fan P-5 lB housing as being partially highlighted while fan P-5 IA housing is entirely highlighted.

Is fan P-5 1B housing entirely in scope?RAI 2.3.3-4 Response P-5 (1A-NNS) and P-5 (1B-NNS) are pumps. Drawing 8-G-0517 S03-LR should have shown pump P-5 (1B-NNS) casing as being entirely highlighted identically as the casing for pump P-5 (IA-NNS) is entirely highlighted.

The casing for pump P-5 (1B-NNS) is in scope and is included in the aging management review (AMR) results in LRA Table 3.3.2-61 Auxiliary Systems -Summary of Aging Management Evaluation

-Reactor Auxiliary Building Ventilation System in the component/commodity "Piping, piping components, and piping elements." NRC RAI 2.3.3-5 Drawing 8-G-0548-LR Grid B-8 shows a Screen that is partially highlighted.

Is the Screen, the"bird screen" and is it entirely in scope? At Grid J-4 two damper bodies/enclosures, DG-GD3 (SA-1) and DG-GD4 (SA-1) appear to be partially highlighted.

Are they entirely in scope?RAI 2.3.3-5 Response The screen shown on drawing 8-G-0548-LR grid location B-8 should be entirely highlighted.

The screen is in scope and is included in the AMR results in Table 3.3.2-62 Auxiliary Systems -Summary of Aging Management Evaluation

-Emergency Service Water Intake Structure Ventilation System in the component/commodity "Bird Screens." The two damper bodies/enclosures, DG-GD3 (SA- 1) and DG-GD4 (SA- 1), shown on drawing 8-G-0548-LR at location J-4 should be entirely highlighted.

The two damper bodies/enclosures are in scope and are included in the AMR results in Table 3.3.2-65 Auxiliary Systems -Summary of Aging Management Evaluation

-Diesel Generator Building Ventilation System in the component/commodity "Damper Housings." NRC RAI 2.3.3-6 In Section 2.1.1.1, the requirements of Title 10 of the Code of Federal Regulations (10 CFR)54.4(a)(1) pertaining to safety-related systems, structures, and components (SSCs) within the scope of the license renewal were compared to those of PassPort Equipment Data Base (EDB)Quality Class A designation.

It was stated that the definition of PassPort EDB Quality Class A is determined to be consistent with the scoping criteria of 10 CFR 54.4(a)(1), such that this designation is sufficient to facilitate scoping of the Shearon Harris Nuclear Power Plant (HNP)SSCs under 10 CFR 54.4(a)(1).

However, it was stated in Section 2.1.1.2 (2 d paragraph in page 2.1-11) that an evaluation of components located in Turbine Building and classified as safety-related has determined that these components do not meet the license renewal definition of HNP-07-124 Enclosure 1 Page 5 of 7 safety-related.

Please explain the differences in the safety-related classifications between HNP Passport EDB and license renewal and how a component that is classified as safety-related in PassPort EDB may not meet the license renewal safety-related classification?

RAI 2.3.3-6 Response Identification of SSCs that fall within the scope of the Rule at HNP is performed at the system or structure level, and is consistent with the guidance found in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 -The License Renewal Rule," Rev. 6. The initial step in the scoping process is to compile a list of SSCs. HNP plant components are maintained in a controlled database called the PassPort Equipment Database (EDB). Each HNP system is identified in EDB by a unique system number, and each component in a given system is assigned a unique EDB component identification number. EDB also contains a designation of quality class for each component.

Scoping relied heavily on reviews of the Final Safety Analysis Report (FSAR) and other plant documentation that constitute the Current Licensing Basis (CLB), and reviews of the EDB component quality classifications.

In using EDB component quality classifications, it was recognized that in some cases the scoping criteria of 10 CFR 54.4 would be narrower than the quality class designation of SSCs shown in EDB. For instance, EDB quality classifications apply the safety related, Quality Class A designation to certain items that do not perform a safety related function but whose failure could prevent the satisfactory accomplishment of a safety related function during or following design basis accidents and transients.

These were classified as Quality Class A unless a non-safety related classification had been justified.

Therefore, in assessing the compatibility of EDB quality classifications with License Renewal scoping criteria, there were specific instances where EDB quality classifications may not be appropriate.

HNP License Renewal procedures allow for the refinement of scoping results on a case by case basis to exclude items or quality classifications that are outside of the scoping criteria of 10 CFR 54.4 based on a functional review of the component.

It was noted during the scoping phase that certain IINP components located in the Turbine Building are classified in EDB as safety-related.

To determine if the subject components met the definition of safety related as stated in 10 CFR 54.4(a)(1), an evaluation was performed using plant documentation such as the FSAR, Design Basis Documents, System Descriptions, Plant Operating Manual procedures, calculations such as the Safe Shutdown Analysis and docketed correspondence.

During this process, it was determined that the safety related quality classifications of the subject Turbine Building components were selected to ensure they were treated as important to safety. Examples of the evaluations performed are provided in the response to RAI 2.1.1.2-1 in HNP letter to the NRC, Serial: H4NP-07-122, dated September 18, 2007.Based on the above, it was concluded that there are a small number of components, classified in EDB as Quality Class A, that did not meet the License Renewal definition of safety-related as stated in 10 CFR 54.4(a)(1).

HNP-07-124 Enclosure 1 Page 6 of 7 NRC RAI 2.3.3-7 In Section 2.3 "Scoping and Screening Results," the following statements were made for many systems (e.g. Sections 2.3.2.1, 2.3.3.56, 2.3.3.57): "The -system contains nonsafety-related components that have the potential to cause an adverse physical interaction with safety related equipment and/or nonsafety-related piping components connected to and providing support for the safety-related functional boundary of the system. These components have been included in scope of license renewal as a result of the 10 CFR 54.4(a)(2) review. Also, the system contains components that are conservatively assumed to meet the criteria of 10 CFR 54.4(a)(2) based on their quality class and are, therefore, included in scope of license renewal." a) What are the intended functions of the non-safety related components?

Are they reflected in Table 2.0-1 "Intended Function Abbreviations and Definitions," Table 3.2.1 "Summary of Aging Management Evaluations in Chapter V of NUREG- 1801 for Engineered Safety Features," Table 3.2.2 "Engineered Safety Features -Summary of Aging Management Evaluation," and Table 3.3.2 "Auxiliary Systems -Summary of Aging Management Evaluation?" b) What components are included in scope of License Renewal due to the conservative assumption that they meet the criteria of 10 CFR 54.4(a)(2)?

Are they reflected in the appropriate tables mentioned in the question above? Take any one system as an example and clarify how this information can be traced in the LRA.RAI 2.3.3-7 Response a) The HNP mechanical screening methodology does not treat components within the scope of License Renewal based on 10 CFR 54.4(a)(2) differently than components within the scope of License Renewal based on 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3).

The list of mechanical component intended functions in LRA Table 2.0-1 can be used individually or in combination to describe a component's intended function that supports the overall system intended function.b) Major structures and plant components such as pumps, valves, tanks, heat exchangers, and instruments at HNP are assigned unique component numbers that are maintained in a controlled database called the PassPort Equipment Database (PassPort EDB or EDB).PassPort EDB is a corporate database platform which is utilized for, among other things, compiling and archiving quality requirements for SSCs at Progress Energy nuclear power plants. PassPort EDB is used to implement the graded quality classification system defined at HNP. HNP procedure, Component Quality Class, defines different categories of quality classifications for these unique components.

Among these quality classifications is Quality Class B. Quality Class B is reserved for non-safety related, quality augmented SSCs. This quality class is further broken down into subclasses, which provide a more specific basis for quality designations.

Two of these Quality Class

• L6 HNP-07-124 Enclosure 1 Page 7 of 7 B subclasses are not currently defined in the HNP procedure but were incorporated into the EDB based on an historical augmented classification.

For the purposes of License Renewal, these undefined Quality Class B subclasses were aligned with the License Renewal rule such that components with those designations were included within the scope of License Renewal for 10 CFR 54.4(a)(2).

Generally, a statement such as "Also, the system contains components that are conservatively assumed to meet the criteria of 10 CFR 54.4(a)(2) based on their quality class and are, therefore, included in scope of License Renewal" is included in the system -descriptions of the LRA to indicate this case.For example, Subsection 2.3.3.1 of the LRA describes the Chemical Volume and Control System. On the bottom of Page 2.3-49 it states: Also, the system contains components that are conservatively assumed to meet the criteria of 10 CFR 54.4(a)(2) based on their quality class and are, therefore, included in scope of License Renewal.Some of the components associated with this category include instrument valves. These instrument valves have been screened as passive and long-lived with an M- 1 intended function.

These valves are included in the "Piping, piping components, and piping elements" component/commodity group in Table 2.3.3-1 on Page 2.3-51 of the LRA.As discussed in the response to a) above, the HNP methodology treats components within the scope of License Renewal equally regardless of the reason that they were brought into scope; and, therefore, components that are included in scope of License Renewal due to the conservative assumption that they meet the criterion of 10 CFR 54.4(a)(2) are included in the appropriate tables.

HNP-07-124 Enclosure 2 Page 1 of 3 Amendment 3 Changes to the License Renewal Application Source of Change License Renewal ADolication Amendment 3 Changes Progress Energy Revise the final paragraph in LRA Subsection 2.4.1.1 on Page 2.4-7 to read: Letter to NRC, 1NP-07-115, dated Insulation is provided on various piping going through pipe penetrations.

Type I September 5, 2007 mechanical piping hot penetrations and several Type 11 mechanical penetrations with small diameter lines have insulation installed to prevent high temperature conditions in the RAI 2.4-2 concrete surrounding the penetrations.

Also revise LRA Subsection 3.5.2.2.1.3 on Page 3.5-31 by deleting the word "hot" from the fourth sentence (two places). In addition, revise Plant-Specific Note 509 to read: 509 The HNP AMR methodology concluded that the insulation for penetrations in the Containment air environment has no aging effects.Progress Energy Revise LRA Table 3.5.2-13 and 3.5.2-22 to add for component/commodity "Platforms, Pipe Letter to NRC, Whip Restraints, Jet Impingement Shields, Masonry Wall Supports, and Other Miscellaneous HNP-07-115, dated Structures (includes support members, welds, bolted connections, support anchorage to September 5, 2007 building structure)" a new material/environment for carbon steel in a raw water environment as follows: RAI 2.4-3 aw Water Loss of Material Structures Monitoring III.A6-11 3.5.1-47 E, 515, (T-21) 575 Add new Plant-Specific Note 575 to read: 575 HNP utilizes the Structures Monitoring Program instead of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program for inspections of the coarse screens in a Raw Water environment.

Add the following after the first sentence in the discussion column of LRA Table 3.5.1, Item 3.5.1-47: However, HNP uses the Structures Monitoring Program for the coarse screens in raw water at the Emergency Service Water and Cooling Tower Makeup Intake Structure and Emergency Service Water Screening Structure.

Progress Energy Add the following to the paragraph preceeding the bulleted list of structures on LRA Letter to NRC, Page 2.1-9: H1NP-07-122, dated September 18, Note that for the Turbine Building the only safety related equipment is located within the 2007 Seismic Category I Diesel Generator Service Water Pipe Tunnel and the Class 1 electrical cable area above the pipe tunnel. Also, the Waste Processing Building contains no safety RAI 2.1.1.2-1 related equipment.

Based on the evaluations presented in the following Spatial Interactions discussion, there are no 10 CFR 54.4(a)(2) spatial interactions in the Turbine or Waste Processing Buildings.

Progress Energy On LRA Page 2.3-266, change the number of table "Component/Commodity Groups Letter to NRC, Requiring Aging Management Review and Their Intended Functions:

Turbine System" from HNP-07-122, dated Table 2.3.3-13 to Table 2.3.4-13.September 18, 2007 RAI 2.3-1 HNP-07-124 Enclosure 2 Page 2 of 3 Source of Change License Renewal Application Amendment 3 Changes Progress Energy Revise the following LRA subsections and tables to delete the aging effect requiring Self-Identified management of Cracking due to Stress Corrosion Cracking (SCC) for stainless steel Change components.

SCC was determined to be not applicable in these cases because the fluid temperature is not expected to exceed the temperature threshold of 140°F required for this aging mechanism to occur. These changes represent a generic implementation of the specific LRA change documented in the response to NRC Audit Question 3.3.1-90-MK-01.

Diesel Generator Air Starting System -In Subsection 3.3.2.1.21, delete Cracking.

In Table 3.3.2-2 1, delete Cracking due to SCC and Plant-Specific Note 397 from the AMR line items for "Piping, piping components, and piping elements" on Page 3.3-240 and for "System strainers screens/elements" on Page 3.3-241.Radioactive Floor Drains System -In Subsection 3.3.2.1.30, delete Cracking.

In Table 3.3.2-30, delete Cracking due to SCC from the AMR line items for "Piping, piping components, and piping elements" on Page 3.3-302; from "System strainers" on Pages 3.3-302 and 3.3-303; and from "Tanks" on Page 3.3-304.Radioactive Equipment Drains System -In Subsection 3.3.2.1.31, delete Cracking.

In Table 3.3.2-3 1, delete the entire Cracking due to SCC AMR line items for "Piping, piping components, piping elements, and tanks" on Page 3.3-307 and for "Reactor Coolant Drain Tank Heat Exchanger Components" on Page 3.3-308. Also, add Plant-Specific Note 737 to the line item associated with Crevice and Pitting Corrosion in Treated Water (Inside) for"Piping, piping components, piping elements, and tanks" on Page 3.3-307. Plant-Specific Note 737 reads: The RCDT piping and components are evaluated at a temperature

<140°F. The coolant in the RCDT is normaly maintained well below 140°F by the continual circulation of the coolant through the RCDT heat exchanger, which is cooled by the Component Cooling Water System.Liquid Waste Processing System -In Subsection 3.3.2.1.40, delete Cracking.

In Table 3.3.2-40, delete Cracking due to SCC from the AMR line items for the "Liquid Waste Holdup Tank" on Page 3.3-332 and for "Piping, piping components, and piping elements" on Page 3.3-333.Secondary Waste Treatment System -In Subsection 3.3.2.1.41, delete Cracking.

In Table 3.3.2-41, delete Cracking due to SCC from the AMR line item for "Piping, piping components, piping elements, and tanks" on Page 3.3-335.Gaseous Waste Processing System -In Subsection 3.3.2.1.43, delete Cracking.

In Table 3.3.2-43, delete the entire Cracking due to SCC AMR line item for "Piping, piping components, piping elements, and tanks" on Page 3.3-342.Radwaste Sampling System -In Subsection 3.3.2.1.44, delete Cracking.

In Table 3.3.2-44, delete Cracking due to SCC from the AMR line item for "Piping, piping components, and piping elements" on Page 3.3-343.Spent Resin Storage and Transfer System -In Subsection 3.3.2.1.49 delete Cracking.

HNP-07-124 Enclosure 2 Page 3 of 3 Source of Change License Renewal Application Amendment 3 Changes Conforming Revise the NUREG-1801 Comparison column on LRA Table B-i on Page B-7 by adding the changes required words "with exception" to the extant entries for the following programs: by LRA Amendment I Thermal Aging and Neutron Irradiation Embritttlement of Cast Austenitic Stainless Steel submitted in (CASS) Program, Progress Energy Letter to NRC Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification HNP-07-112, dated Requirements Program, and August 20, 2007 Environmental Qualification (EQ) Program