ML062480297

Email: (PA) Questions and Answers of Pilgrim LRA Aging Management Reviews

ML062480297
Person / Time
Site:	Pilgrim
Issue date:	06/30/2006
From:	Ellis D Entergy Corp
To:	Jennifer Davis, Subbaratnam R Division of Regulatory Improvement Programs
References
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Download: ML062480297 (45)

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I James Davis - Questions and Answers of Pilgrim LRAAging Management Reviews -... . Pageq .il From: "Ellis, Douglas" <dellisl @entergy.com>

To: "James Davis" <JAD @nrc.gov>, <erachp @comcast.net>, <duh @nrc.gov>,

<rxs2@nrc.gov>, <david.lewis @pillsburylaw.com>

Date: 06/30/2006 1:44:57 PM

Subject:

Questions and Answers of Pilgrim LRA Aging Management Reviews Jim - as you requested, including cc:s. Doug Ellis, Pilgrim Licensing.

CC: "Ellis, Douglas" <dellisl @entergy.com>, "Ford, Bryan" <BFord@entergy.com>

Pagel1 cAtemp\GWJ00001.TMP c:\temp\GWIOOOO1 .TMP Page 1 I Mail Envelope Properties (44A5630F.CE2: 18: 64738)

Subject:

Questions and Answers of Pilgrim LRA Aging Management Reviews Creation Date 06/30/2006 1:44:24 PM From: "Ellis, Douglas" <dellisl @entergv.com>

Created By: dellis 1@entergy.com Recipients nrc.gov OWGWPOO3.HQGWDOO1 JAD (James Davis) nrc.gov TWGWPO02.HQGWDOO1 RXS2 (Ram Subbaratnam) entergy.com BFord CC (Bryan Ford) pillsburylaw.com david.lewis nrc.gov NRCWIA01 .NRCWDOO1 "duh@nrc.gov"

NR C LRA AMR A udit of PNPS Number Status Request Response NRC PNPS Lead 341 Accepted In Table 4.1-1 of the LRA, the applicant did not identify a The license renewal rule, in 10 CFR 54.3, defines a TLAA as a Patel, Erach Finnin, Ron crane load cycle limit as a TLAA for the cranes within the licensee calculation or analysis that, among other things, involves scope of license renewal. Normally, based on the design time-limited assumptions defined by the current operating term. For code of the crane, a load cycle limit is specified at rated cranes, there is no calculation or analysis related to crane load capacity over the crane's projected life. Therefore, it is cycles. In addition, the number of cycles is NOT based on the generally necessary to perform a TLAA relating to crane load current operating term. CMAA-70 specifies an allowable stress cycles estimated to occur up to the end of the extended range based on joint category and service class. Service class is period of operation. Please explain why the crane load cycle based on load class (mean effective load factor) and number of limit was not included as a TLAA. cycles. The projected cycles for the PNPS reactor building crane are well below any of the cycle ranges given in CMAA-70.

The discussion column of Item 3.3.1-1 of Table 3.3.1 will be clarified to read as follows: "No PNPS calculation or analysis related to cumulative fatigue damage for steel cranes met the definition of TLAA in 10 CFR 54.3. The projected cycles for the PNPS reactor building crane are well below the cycle ranges given in CMAA-70. Steel cranes are evaluated as structural components in Section 3.5."

This requires an amendment to the LRA.

342 Accepted In Table 4.3-1, Maximum CUFs for Class I Components, note The transients on the RPV main steam, vent and instrument nozzles Patel, Erach Finnin, Ron 2 addresses exclusion rules for ASME Code. Please explain are mild and stresses remain below the endurance limit. The what these rules are. original CE (Combustion Engineering) vessel analysis demonstrates that the requirements of ASME Section 111 -1965 with summer 1966 Addenda (Original Construction Code), Paragraph N-415.1 Vessels Not Requiring Analysis for Cyclic Operation, were met. This was later confirmed to be the case in the Altran analysis.

A mistake exists in Table 4.3-1 of the LRA. The recirculation outlet nozzle usage factor does not meet the criteria of paragraph N-415.1.

LRA Table 4.3-1 will be revised to add the appropriate usage factor for the recirculation outlet nozzle. Note 2 will no longer be applied to the recirculation outlet nozzle. Note 2 will be revised to read as follows.

Detailed fatigue analysis is not required since component meets the requirements of ASME Section III -1965 with summer 1966 Addenda (Original Construction Code), Paragraph N-415.1 Vessels Not Requiring Analysis for Cyclic Operation.

This requires an amendment to the LRA.

Page) of 77

Number Status Request Response NRC PNPS Lead 343 Accepted Section 4.3.1.3, Class 1 piping and components states all Section 4.3.1.3 of the LRA is correct. PNPS has no site-specific Patel, Erach Finnin, Ron remaining RCS pressure boundary piping is designed and fatigue analysis for the feedwater piping. Section 4.3.3 of the LRA analyzed in accordance with ANSI B31.1. However, in is discussing the effects of the reactor coolant environment on section 4.3.3, on page 4.3-8, it implies that fatigue analysis fatigue. Entergy will remove the generic (NUREG-6260) values for exists for feedwater piping (which is part of the RCS pressure the core spray safe end, the RR outlet nozzle and the feedwater boundary piping designed and analyzed lAW B31.1.). piping from Table 4.3-3. There are no PNPS-specific analyses for Please clarify this discrepancy, since B31.1 does not require these locations.

a fatigue analysis calculation.

See the response to Question 346A below for the PNPS commitment for performing EAF (environmentally adjusted fatigue) analyses.

This requires an amendment to the LRA.

344 Accepted Section 4.3.1.3, Class I piping and components second PNPS will add the following sentence at the end of Section 4.3.1.3: Patel, Erach Finnin, Ron paragraph states that the design transients are tracked and "The effects of the reactor coolant environment on fatigue are evaluated to ensure that cycle limits are not exceeded, addressed in Section 4.3.3 of the LRA."

thereby assuring that CUFs do not exceed 1.0. It further states that continuation of this program, therefore, will The TLAA addressed by Section 4.3.1.3 Is calculation of CUFs ensure that the allowed number of transient cycles is not without accounting for the effects of reactor coolant environment.

exceeded. Consequently, the TLAA (fatigue analyses) for This TLAA remains valid for the period of extended operation as Class 1 piping and components will remain valid for the long as the analyzed number of transients is not exceeded.

period of extended operation in accordance with 10 CFR 54.2 1(c)(1 )(i) or the effects of aging on the intended function(s) The calculation of CUFs accounting for the effects of the reactor will be adequately managed for the period of extended coolant environment does not exist, as the current licensing basis operation in accordance with 10 CFR 54.21(c)(1)(iii). This by does not require consideration of environmental fatigue factors.

itself could be a true statement, however, cycle counting Since 10 CFR 54.3 defines TLAAs as licensee calculations and does not address the effects of environmental fatigue, which analyses, there is not a TLAA that considers environmental fatigue is not included here. Acknowledging that section 4.3.3 factors.

addresses environmental fatigue, please clarify how that section is tied into the conclusion made in section 4.3.1.3. To remove the perceived implication that exceeding the allowable number of transients would cause the CUFs to exceed 1.0, the following changes will be made to the LRA.

LRA Section 4.3.1, page 4.3-4 will be modified as follows: "The PNPS Fatigue Monitoring Program ensures that the numbers of transient cycles experienced by the plant remain within the allowable numbers of cycles, and hence the component CUFs remain below their analyzed values."

LRA Section 4.3.1.3, Second sentence of the second paragraph will be changed as follows:

"The design transients are tracked and evaluated to ensure that cycle limits are not exceeded, thereby assuring that CUFs remain below their analyzed values."

This response requires an amendment to the LRA.

Page 2 of 77

Number Status Request Response NRC PNPS Lead 345 Accepted Section 4.3.1.4, Feedwater Nozzle Fatigue states that this The Thermal Power Optimization Task Report T0302 updated the Patel, Erach Finnin, Ron extrapolated usage factor for the feedwater nozzles, feedwater nozzle CUF to <1.0 based on the associated (1.5%) power considering both the currently analyzed system design uprate. The extrapolation in LRA section 4.3.1.4 is thus no longer transients and rapid cycling through the period of extended valid. PNPS will modify the LRA to delete this extrapolation. PNPS operation, is thus <0.899. This number is not correct. Please will perform a new feedwater nozzle fatigue analysis prior to the explain how this number was calculated. period of extended operation.

This commitment is Item 35 of the PNPS commitments for license renewal.

This requires an amendment to the LRA.

346 Open - Section 4.3.3, Effects of Reactor Water Environment on A. Further refinement of the ASME Class I fatigue analysis for the Patel, Erach Finnin, Ron NRC Fatigue Life. RPV and nozzle locations will be performed considering the Please provide more details on your implementation plan: predicted number of transients at each location adjusted to the end A. How will the further refinement of the fatigue analyses be of the extended license period using refined finite element performed? Will it consider finite element analyses? evaluation as applicable. The refined analysis will account for B. Ifan aging management program is used, please include environmental effects as applicable using the FEN methodology a commitment to issue for NRC approval 24 months prior to described by the GALL report or other industry Codes and Standards entering period of extended operation. as approved by NRC.

C. Will replacement be of the same material type?

B. License renewal Commitment 31 includes a commitment to submit the aging management program to the NRC 24 months prior to the period of extended operation if the aging management program option is chosen.

C. Appropriate replacement material will be selected in accordance with PNPS design control procedures, if replacement is a chosen option.

347 Accepted Table 4.3-3, Note 1 states "No PNPS-specific value was A. Yes, this is a typo, it should be NUREG-6260. Patel, Erach Finnin, Ron available; used generic value from NUREG/CR-6220."

a. Wrong NUREG identified - should it be NUREG-6260? B. The CUF values from NUREG-6260 were intended as typical

b. The NUREG-6260 CUF is based on the specific plant values used to predict the magnitude of the effect of considering the used in that NUREG and is dependent on that plant's piping reactor coolant environment on fatigue for PNPS. PNPS will amend configuration. That value cannot be used for PNPS the LRA to remove the CUFs from Table 4.3-3 that are taken from calculation. Please justify how this value applies to PNPS NUREG-6260.

unless the PNPS piping configurations are same as the NUREG-6260 plant or provide a PNPS specific CUF value. See Item 346 for PNPS's commitment to perform additional environmentally adjusted fatigue analyses prior to the period of extended operation.

This response requires an amendment to the LRA.

Page3 of 77

Number Status Request Response NRC PNPS Lead 349 Closed 13.4.1-W-011 Listing TLAA - metal fatigue in the tables In Section 3 indicates Wen, Peter Finnin, Ron that the conditions for fatigue were present and that they needed to In numerous line items in Tables 3.4.2-2, 3.3.2-14-3, 9, 10, be evaluated. Associated components were subsequently 11, 17 and 18 of the Steam and Power Conversion System, evaluated in LRPD-06, TLAA - Metal Fatigue. If the evaluation found the applicant credits TLAA - Metal Fatigue to manage the no TLAA, it was not listed in Section 4 of the LRA. For aging effect of metal fatigue (cumulative fatigue damage), clarification, Entergy will revise the Section 3 tables to remove the and indicates that the evaluation of this TLAA is addressed TLAA - metal fatigue entries whenever there was no associated in Section 4.3 of the LRA. However, it appears that the TLAA discussed in Section 4 of the LRA.

write-up of the Section 4.3 does not cover the discussion for most components. Please explain the discrepancy. This item is closed to item 506.

350 Accepted [3.4.1-W-02] The Section 3.4.2.2.2 (1) further evaluation discussion is referenced Wen, Peter Lingenfelter, by Table 3.4.1 items 3.4.1-2, 3.4.1-4 and 3.4.1-6. The discussion Section 3.4.2.2.2 (1) of the LRA (page 3.4-4), the applicant column entry of item 3.4.1-6 indicates that the PSPM program states: applies to the condensate storage tanks. Although the water in these tanks would be subject to the water chemistry controls - BWR "Loss of material due to general, pitting and crevice program, the PSPM program Is sufficient to manage loss of material corrosion for carbon steel piping, piping components, and and was the only program credited for these tanks. See the tanks, exposed to treated water and for carbon steel piping response to question 3.4.1-5 (item #353) which documents that the and components exposed to steam is an aging effect Water Chemistry Control - BWR program should have been credited requiring management in the steam and power conversion along with the PSPM program for the condensate storage tanks.

systems at PNPS, and is managed by the Water Chemistry Control - BWR and Periodic Surveillance and Preventive This requires a supplementlamendment to the LRA.

Maintenance (PSPM) Programs."

Please clarify the above summary, regarding the use of PSPM program. Is the use of PSPM program Is in lieu of the OTI program to verify the effectiveness of the Water Chemistry Control - BWR program or some of the AEM combination will be managed by using PSPM alone.

351 Closed [3.4.1-W-03] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Tables 3.4.2-x and Table 3.3.2-14-x (corresponding to 3.4.1 indicates that the One-Time Inspection Program Is credited VIII.E-33, condensate system, VIII.C-6, extraction steam along with the water chemistry control programs for line items for system. VIII.D2-7, feedwater system, and VIII.B2-6, main which GALL recommends a one-time inspection to confirm water steam system) that reference item 3.4.1-4? chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

Page 4 of 77

Nuniber Statuis Request Response NRC PNPS Lead 352 Closed [3.4.1 -W-04] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Table 3.3.2-14-x (corresponding to VIII.E-7, heat exchanger 3.4.1 indicates that the One-Time Inspection Program is credited components in condensate system) that reference item along with the water chemistry control programs for line items for 3.4.1-5? which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table I line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

353 Closed [3.4.1-W-05] Since the condensate storage tank contains fluid that is subject to Wen, Peter Orlicek, Jack the controls of the Water Chemistry Control - BWR Program, the The applicant references GALL item VIII.E-40 (steel tank in program applies to the tank. The LRA will be clarified to explicitly condensate system) for the condensate storage system credit the Water Chemistry Control - BWR Program in addition to carbon steel tank, as listed in LRA Table 3.4.2-1, (page PSPM with managing the effects of aging for the condensate 3.4-28), but takes credit of PSPM to manage the aging effect storage tank surfaces exposed to the treated water environment.

of loss of material. The GALL recommends using "Water Chemistry" and '01"" programs for this component and AEM Since the One-Time Inspection (OTI) Program is applicable to each combination. Although the PSPM, as described in PNPS water chemistry control program, it is also applicable to each line LRA B1.24, has more stringent inspection requirement than item that credits a water chemistry control program. As stated in OTI, it does not include controlling water chemistry to LRA Table 3.4.1, the One-Time Inspection Program Is credited to minimize component exposure to aggressive environment. verify effectiveness of the water chemistry control program for line Please explain why relying on PSPM alone is sufficient for items that reference item 3.4.1-6.

meeting the GALL's recommendations to manage the aging effect of loss of material for the condensate storage system This requires an amendment to the chemistry program descriptions carbon steel tank. in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water The carbon steel tank listed in Table 3.3.2-14-10, feedwater Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems system (page 3.3-171) and Table 3.3.2-14-11, feedwater and the Water Chemistry Control- Closed Cooling Water programs.

heater drains and vents system (page 3.3-178), also reference GALL item VIII.E-40. Why is OTI program not This item is closed to Item 372.

credited for these line items that reference item 3.4.1-6.

Page 5 of 77

Number Status Request Response NRC PNPS Lead 354 Closed [3.4.1-W-06] During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.3.2-14-35 (corresponding to VIII.A-14) that reference ineffective Oil Analysis Program. The corrective action program at item 3.4.1-7? PNPS has a low threshold for the Identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item Is closed to Item 376.

355 Closed [3.4.1-W-07] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Table 3.2.2-4, HPCI System, (page 3.2-49) and Table 3.4.1 indicates that the One-Time Inspection Program is credited 3.2.2-5, RCIC System, (page 3.2-62) (corresponding to along with the water chemistry control programs for line items for VIII.E-10) that reference item 3.4.1-9? which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

Page 6 of 77

Number Status Request Response NRC PNPSLead 356 Closed [3.4.1-W-08] During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.3.2-5, Station Blackout Diesel, (page 3.3-90) and ineffective Oil Analysis Program. The corrective action program at Table 3.3.2-6, Security Diesel Generator System, (page PNPS has a low threshold for the Identification of degraded 3.3-102) (corresponding to VIII.G-15) that reference item conditions such that corrosion or cracking of components would be 3.4.1-10? identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an Ineffective oil analysis program or that Identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that Identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

357 Closed [3.4.1-W-09] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Table 3.4.2-2, Main Condenser and MSIV Leakage Pathway, 3.3.1 indicates that the One-Time Inspection Program is credited Table 3.3.2-14-9, Extraction Steam System, Table along with the water chemistry control programs for line items for 3.3.2-14-16, HPCI, Table 3.3.2-14-18, Main Steam System, which GALL recommends a one-time inspection to confirm water and Table 3.3.2-14-19, Offgas and Augmented Offgas chemistry control. Table 2 credits the OTI program through System that reference item 3.4.1-13? reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to cleariy indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

Page 7 of 77

Numnber Status Request Response NRC PNPS Lead 358 Closed [3.4.1-W-10] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Since notes 'A"and "C*were used in various Table item that credits a water chemistry control program. LRA Table 3.3.2-14-x line items, which reference item 3.4.1-14, why OTI 3.3.1 indicates that the One-Time Inspection Program is credited program is not credited for those lines? along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

359 Closed [3.4.1-W-11] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Since note "C" was used in Table 3.3.2-14-4, Condensate item that credits a water chemistry control program. LRA Table Demineralizer System line items, which reference item 3.3.1 indicates that the One-Time Inspection Program is credited 3.4.1-15, why OTI program is not credited for those lines? along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table I line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

Page 8 of 77

Number Status Request Response NRC PNPS Lead 360 Closed [3.4.1-W-12] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Since notes "A" and "C"were used in Table 3.4.2-14, item that credits a water chemistry control program. LRA Table Condensate Storage System and various Table 3.3.2-14-x 3.3.1 indicates that the One-Time Inspection Program is credited line items which reference item 3.4.1-16, why OTI program is along with the water chemistry control programs for line items for not credited for those lines? which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

361 Closed 3.4.1-W-13 During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.4.2-14-35, Turbine Generator and Auxiliary System ineffective Oil Analysis Program. The corrective action program at (corresponding to VIII.A-3) that reference item 3.4.1-18? PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not Identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page 9 of 77

Number Status Request Responise NRC PNPS Lead 362 Closed [3.4.1-W-14] During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.4.2-14-35, Turbine Generator and Auxiliary System ineffective Oil Analysis Program. The corrective action program at (corresponding to VIII.A-9 and VIII.G-3 ) that reference item PNPS has a low threshold for the identification of degraded 3.4.1-19? conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page 10of77

Number Status Request Response NRC PNPS Lead 363 Open - [3.4.1-W-15] Preventive Actions: Wen, Peter Ford, Bryan NRC Table 3.4.1, item 3.4.1-20 for steel tanks exposed to air - Protective coatings were applied during fabrication or installation of outdoor. PNPS uses the System Walkdown Program to the subject tanks well before development of aging management manage the aging effect of loss of material due to general, programs for license renewal.

pitting, and crevice corrosion through the use of periodic visual inspections. The GALL Report recommends the AMP The System Walkdown Program entails visual inspections of of Aboveground Steel Tanks Program (GALL XI. M29) to be external surfaces of carbon steel tanks to identify degradation of used. While the System Walkdown Program may be an coatings, sealants, and caulking plus indications of leakage. The acceptable alternate for Aboveground Steel Tanks AMP for site corrective action process would require evaluation and repair, if inspection, the Aboveground Steel Tanks AMP has some necessary, of degraded coatings or caulking.

program attributes not addressed in the System Walkdown Program. For examples, the System Walkdown Program is Detection of Aging Effects:

silent on the preventive actions, but the Aboveground Steel Tanks AMP includes preventive measures to mitigate The condensate storage tank is a non-safety related carbon steel corrosion by protecting the external surface of steel tanks tank that contains treated water. The tank sits on a concrete pad with paint or coatings in accordance with standard industry with a sand and oil base cushion that is designed to remove practice. moisture from the bottom of the tank to minimize the potential for corrosion. The internals of the tank which are subjected to Please explain how the preventive actions and detection of continuous wetting are periodically inspected for corrosion and aging effects at inaccessible locations such as the tank pitting including inaccessible areas (under water) as documented in bottom surface will be performed for the subject tanks using site procedure NE8.02. This same procedure also inspects exterior the System Walkdown AMP. caulking at the base of the tank for cracking in order to prevent water accumulation under the tank. This procedure is credited in the Periodic Surveillance and Preventive Maintenance program section 4.17 and Attachment 3 of LRPD-02 for management of the external and internal surfaces of this tank. Any degradation of the internals of the tank will result in a condition report and an evaluation of the extent of the condition, which may involve ultrasonic examination to determine remaining thickness.

Because the environment inside the tank is significantly harsher than the environment on the underside of the tank, internal degradation would be expected long before corrosion on the outside.

If degradation occurs on the inside (including the bottom),

examinations of the degraded areas would require a determination of the remaining wall thickness which ensures the integrity of the tank is maintained.

However, to ensure that significant degradation on the bottom of the tank is not occurring, PNPS commits to perform a one-time ultrasonic thickness examination in accessible areas on the bottom of the condensate storage tank prior to the period of extended operation. Standard examination and sampling techniques will be utilized. This is commitment number 36.

This requires an amendment to the LRA.

Page 11of 77

Number Status Request Response NRC PNPS Lead 364 Closed [3.4.1-W-16] A Bolting Integrity Program will be developed that will address the Wen, Peter Fronabarger, aging management of bolting In the scope of license renewal.

Table 3.4.1, item 3.4.1-22, for steel bolting and closure bolting exposed to air with steam or water leakage, air - The Bolting Integrity Program will be implemented prior to the period outdoor (external), or air - indoor uncontrolled (external). The of extended operation in accordance with commitment number 32.

applicant references GALL items VIII.H-1 and H-4 for the closure bolting in various Steam and Power Conversion This requires an amendment to the LRA to Include descriptions of System, as listed in LRA Table 3.4.2-1 and 3.3.2-14-x, but the Bolting Integrity Program in Appendices A and B and to identify takes credit for the System Walkdown Program to manage where the program is applicable.

the aging effect of loss of material. The GALL Report recommends AMP XI.M18, Bolting Integrity Program, which This item is closed to Item 373.

includes a comprehensive bolting integrity program, as delineated in NUREG-1 339, and industry recommendations, as delineated in the EPRI report NP-5769. Please justify how the additional attributes listed in GALL AMP XI.M18 for aging management of closure bolting are addressed in the System Walkdown Program.

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Number Status Request Response NRC PNPS Lead 365 Open - [3.6.2.2-N-01] The PNPS electrical AMR, AMRE-01, In section 3.4.1 states for Nguyen, Duc Stroud, Mike NRC cable connections (metallic parts), "An evaluation of thermal In LRA Table 3.6.2-1 under Cable connections (metallic cycling, ohmic heating, electrical transients, vibration, chemical parts), you have stated that no aging effects and no AMP is contamination, corrosion, and oxidation stressors for the metallic required. NUREG-1 801, Revision 1, AMP XI.E6, "Electrical parts of electrical cable connections identified no aging effects Cable Connection not Subject to 10 CFR 50.49 requiring management.

Environmental Qualification Requirements," specifies that connections associated with cables within the scope of - Metallic parts of electrical cable connections potentially exposed license renewal are part of this program, regardless of their to thermal cycling and ohmic heating are those carrying significant associated with active or passive components. Also, refer to current in power supply circuits. Typically, power cables are in a pages 107, 256, and 257 of NUREG-1 833, "Technical continuous run from the supply to the load. Therefore, the Bases for Revision to the License Renewal Guidance connections are part of an active component and not subject to Documents," for additional information regarding AMP XI.E6. aging management review.

Provide a basis document including an AMP with the ten - The fast action of circuit protective devices at high currents elements for cable connections or provide a justification for mitigates stresses associated with electrical faults and transients.

why an AMP is not necessary. In addition, mechanical stress associated with electrical faults is not a credible aging mechanism because of the low frequency of occurrence for such faults. Therefore, electrical transients are not applicable stressors.

- Metallic parts of electrical cable connections exposed to vibration are those associated with active components that cause vibration.

Because they are part of an active component, they are not subject to aging management review.

" Corrosive chemicals are not stored in most areas of the plant.

Routine releases of corrosive chemicals to areas inside plant buildings do not occur during plant operation. Such a release, and its effects, would be an event, not an effect of aging. In addition, their location inside active components protects the metallic parts of electrical cable connections from contamination. Therefore, this stressor is not applicable.

- Oxidation and corrosion usually occur in the presence of moisture or contamination such as industrial pollutants and salt deposits.

Enclosures or splice materials protect metal connections from moisture or contamination.

Since bolted connections are considered part of an active device and are maintained by the plant Maintenance Rule program, there are no aging effects requiring management for bolted connections of cable systems. Since PNPS maintains cable connections under a current maintenance program and has no Indication of an aging mechanism due to loose connections, no AMP is needed in addition to the Maintenance Rule program.

Page 13 of 77

Number Status Request Response NRC PNPS Lead 366 Accepted [3.6.2.2-N-02] As shown by the OE (Operating Experience) cited in this question, Nguyen, Duc Stroud, Mike flashover due to salt contamination of insulators is caused by In LRA Table 3.6.2-1 under high voltage insulator (SBO), you events, typically storms, regardless of the age of the Insulators.

have stated that no aging effects and no AMP is required. This is cleariy not an effect of aging. Therefore, surface You further stated, in Section 3.6.2.2.2 of the LRA, that contamination is not an applicable aging mechanism for PNPS is located near the seacoast where salt spray is high-voltage insulators at PNPS. Since the condition is caused by considered. However, salt spray buildup is a short-term severe weather conditions unrelated to aging, an aging management concern based on local weather conditions (event driven). program is not appropriate to address this concern. However, while Therefore, you have concluded that surface contamination is salt spray buildup is a short-term concern based on local weather not an applicable aging mechanism for high voltage conditions (event-driven), such buildup can cause problems with the insulators at PNPS. offsite power supply system. Because of this operating experience, PNPS has applied Sylgard (RTV silicone) coatings to some NUREG 1800, Rev. 1, Standard Review Plan for Review of switchyard insulators to reduce flashover. The addition of Sylgard to License Renewal Application for Nuclear Power Plant, the insulators has reduced the likelihood of insulator flashover.

Section 3.6.2.2.2 identified degradation of high voltage insulator in presence of salt deposits or surface System walkdowns are performed at least once per refueling cycle contamination. Various airborne materials such as dust, and are normally performed more frequently to do a visual inspection salt and industrial effluent can contaminate insulator of the switchyard high-voltage Insulators that are In-scope of surfaces. A large buildup of contamination enables the license renewal in accordance with EN-DC-178. These walkdowns conductor voltage to track along the surface more easily and will continue to be performed into the period of extended operation.

can lead to insulator flash over. Surface contamination can be problem in areas where there are greater concentration of airborne particles such as near facilities that discharge soot LRPD-02 will be revised as follows:

or near the sea coast where salt spray is prevalent. Industry The System Walkdown Program will be revised to include the visual operating experience identified the potential of loss of offsite inspection of high-voltage insulators in-scope of license renewal.

power due to salt deposition to switchyard insulators. On March 17, 1993, Crystal River Unit 3 experienced a loss of the 230 kV switchyard (normal offsite power to safety-related busses) when a light rain caused arcing across salt-laden 230 kV insulators and opened breakers in switchyard. In March 1993, the Brunswick Unit 2 switchyard experienced a flash over of some high-voltage insulators. The incident was attributed to a winter storm in the area. Since 1982, Pilgrim station has also experienced several loss of offsite power events when ocean storms deposited salt on the 345 kV switchyard causing the insulator to arc to ground. In light of these industry and plant operating experiences, provide justification of why an AMP is not necessary.

Page 14 of 77

Nunber Status Request Response NRC PNPS Lead 367 Closed [3.6.2.2-N-03] At PNPS, bus to bus connections are welded instead of bolted. Nguyen, Duc Stroud, Mike Switchyard buses are connected by flexible connectors to insulators In LRA, Table 3.6.2-1, under switchyard bus and and active components. Since switchyard bus is typically under a connections, you have stated that no aging effects requiring constant load, thermal cycling that could cause torque relaxation is management and no AMP is required. NUREG 1800, Rev. 1, infrequent. With no connections to vibrating equipment, vibration Is Standard Review Plan for Review of License Renewal not an aging mechanism for switchyard bus. The switchyard Application for Nuclear Power Plant, Section 3.6.2.2.3 connections to the startup transformer are part of the active identifies loss of preload is an aging effect for switchyard assembly maintained by the plant maintenance program. Therefore, bus connections. Torque relaxation for bolted connection is torque relaxation is not an aging effects requiring management for a concern for switchyard bus connections and transmission switchyard bus.

conductor connections. An electrical connection must be designed to remain tight and maintain good conductivity In addition, thermography Is performed at least once every 6 months through a large temperature range. Meeting this design to maintain the integrity of the connections. This program will requirement is difficult if the material specified for the bolt continue into the period of extended operation.

and the conductor are different and have different rates of thermal expansion. For example, copper or aluminum bus/conductor materials expand faster than most bolting materials. If thermal stress is added to stresses inherent at assembly, the joint members or fasteners can yield. If plastic deformation occurs during thermal loading (i.e.,

heatup) when the connection cools, the joint will be loose.

EPRI document TR-104213, 'Bolted Joint Maintenance &

Application Guide,* recommends inspection of bolted joints for evidence of overheating, signs of buming or discoloration, and indication of loose bolds. Provide a discussion for why torque relaxation for bolted connections of switchyard bus is not a concern for PNPS.

368 Closed [3.6.2.2-N-041 The preferred source of offsite power comes from the 345kV Nguyen, Duc Stroud, Mike switchyard. The feed from the switchyard breakers, 352-2 and 352-3, In LRA, Section 3.6.2.2.3, you have stated that PNPS does travels by switchyard bus to the startup transformer, X4, and then not utilize transmission conductors in the circuits for travels by underground cables to the safety buses in the plant. The recovery of offsite power following an SBO. Describe SBO alternate offsite power source comes from the 23kV switchyard and recovery paths for PNPS. Confirm that no transmission travels from breaker 252 by underground cables to the shutdown conductors are utilized in the circuits for recovery paths. transformer, X13, and then by underground cables to bus A8. From Support these answers with a main one line diagram. A8 the power travels by underground cables to the safety buses in the plant. Neither PNPS recovery path for offsite power uses transmission conductors. These paths are shown on Figure 2.5-1 of the LRA.

Page 15 of 77.

Number Status Request Response NRC PNPS Lead 369 Closed [3.6.2.2-N-05] At PNPS, the station blackout diesel generator provides the Nguyen, Duc Stroud, Mike alternate AC power source. All SSCs associated with the AAC 10 CFR 54.4 (a)(3) requires, in part, that all systems, diesel are in scope for license renewal. The LRA provides the structures, and components (SSCs) relied on in safety aging management review results for long-lived, passive SSCs analyses or plant evaluation to perform a function that associated with the AAC power source in each discipline section demonstrates compliance with the commission's of the LRA.

regulations for station black out (10 CFR 50.63) are within the scope of license renewal. What is your altemate ac (AAC) source used to meet SBO requirements? Are all SSCs (including electrical components) associated with AAC sources included in the scope of licensee renewal? If they are not, explain why not. If they are, provide an AMR for long-lived, passive SSCs associated with the AAC sources.

370 Accepted [3.6.2.2-N-06] The PNPS LRA Section 3.6.2.2 will be revised to read as follows: Nguyen, Duc Stroud, Mike "Some of the penetration assemblies at PNPS are not EQ. The Are all electrical and I&C containment penetrations EQ? If non-EQ penetration assemblies are subject to aging management not, provide AMRs and AMPs for non-EQ electrical and I&C review. The aging management review is provided in AMRE-01 and containment penetrations. The AMRs should include both the AMP for penetration assembly pigtails is provided in the non-EQ organic ( XLPE, XLPO, and SR internal conductor/pigtail insulated cables and connections program will manage the aging insulation, etc.,) as well as inorganic material (such as effects of the penetration assembly cables and connections. Table cable fillers, epoxies, potting compounds, connector pins, 3.6.2-1 includes the electrical penetration conductors and plugs, and facial grommets). connections in the line item for electrical cables and connections not subject to 10 CFR 50.49 - EQ."

The structural report for bulk commodities, AMRC-06, addresses the penetration assembly components, seals and sealing elements that form the radiological control barrier for containment in Table 3.5.2-1.

This requires an amendment to the LRA.

Page 16 of 77

Number Status Request Response NRC PNPS Lead 371 Closed (G.3.3.1-P-01] Section 14 includes all the systems that have intended functions Patel, Erach Fronabarger, that meet 10 CFR 54.4(a)(2) for physical interaction. To indicate Tables 3.3.2.14-1 through 3.3.2.14-35 address non-safety individual systems included in the aging management review for related components affecting safety related systems. (a)(2), Table 3.3.2-14 is subdivided by system. For example, Table However, these tables address all such systems in section 3.3.2-14-1 is for the circulating water system, a system which only 3.3, Auxiliary Systems, even though some of these systems has components included for (a)(2). For the core spray system, belong to section 3.2, ESF Systems, and section 3.4, Steam Table 3.3.2-14-7 shows the components included for (a)(2) but since and Power Conversion (S&PC) Systems. Tables 3.3.14-7, the system is also in scope for other reasons, Table 3.3.2-2 shows 14-16, 14-25, and 14-28 are for systems that belong to the components included for 54.4(a)(1) and (a)(3).

Section 3.2; and tables 3.3.14-1, 14-3, 14-5, 14-9, 14-10, 14-11, 14-17, and 14-18 are for systems that belong to The aging management review of the systems that have functions Section 3.4. The Table 1 item reference also specifies that met 10 CFR 54.4(a)(2) for physical interaction was done Tables 3.2.1 and 3.4.1. The audit report and the SER are separately from the review of systems with intended functions that based on systems as defined in GALL Report sections of met 10 CFR 54.4 (a)(1) or (a)(3). The results of this review were ESF, Auxiliary, and S&PC systems. As written in the LRA, it presented separately so that they could be reviewed separately on will make the audit report and SER confusing because the the basis of physical proximity rather than system function. This ESF systems section 3.2 write-up will include Tables from allows a reviewer to clearly distinguish which component types in a section 3.3, and the S&PC systems section 3.4 write-up will system were included for 10 CFR 54.4(a)(2) for physical interaction.

include Tables from section 3.3. Different reviewers write Since most of these systems are auxiliary systems they were added these sections. as part of the auxiliary systems section.

Please justify why the non-safety systems associated with ESF and S&PC systems were included in the Auxiliary system section.

372 Accepted [G.3.3.1-P-02] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Discrepancy between Table 3.3.1 line items and Tables item that credits a water chemistry control program. LRA Table 3.3.2-X for those line items that credit water chemistry or oil 3.3.1 indicates that the One-Time Inspection Program is credited analysis program and a verification program such as along with the water chemistry control programs for line items for one-time inspection (OTI) program. The Table 1 item is which GALL recommends a one-time Inspection to confirm water consistent with the GALL report and correctly credits the chemistry control. Table 2 credits the OTI program through chemistry program and the OTI program or for plant-specific reference to the associated Table I line item.

program also credits chemistry and OTI programs. However, the Table 2 line items that reference these Table 1 line This requires an amendment to the chemistry program descriptions items do not credit the OTI program. These Table 2 line in LRA Appendices A and B to clearly indicate that the One-Time items however have a footnote 'A', or 'C' which states that it Inspection Program will confirm the effectiveness of the Water is consistent with the MEAP combination inthe GALL Chemistry Control - BWR, Water Chemistry Control - Auxiliary Report. Systems and the Water Chemistry Control - Closed Cooling Water programs.

Please justify why the OTI program is not credited in Table 2, even though it is credited in Table 1 and footnote 'A' implies total consistency with GALL for MEAP combination.

Page 17 of077

Number Status Request Response NRC PNPS Lead 373 Accepted [G.3.3.1-P-03] A Bolting Integrity Program will be developed that will address the Patel, Erach Fronabarger, aging management of bolting in the scope of license renewal. A PNPS does not include Bolting Integrity Program in the LRA, copy of the aging management program basis document for the however credits other programs as alternate to the bolting Bolting Integrity Program will be provided for review with the LRA integrity program. The GALL Report AMP XI.M18, Bolting supplement.

Integrity Program provides several recommendations in the 10-element evaluation, specifically recommendations The Bolting Integrity Program will be implemented prior to the period associated with preventive actions such as selection of of extended operation in accordance with commitment number 32.

bolting material, use of lubricants and sealants and additional recommendations of NUREG-1339. Some of the This requires an amendment to the LRA to include descriptions of alternate programs may be acceptable for inspection, the Bolting Integrity Program inAppendices A and B and to identify however, they do not address the preventive actions. where the program is applicable.

Please clarify how PNPS meets these recommendations when using alternate programs or please credit a Bolting Integrity Program for the various Table 2 line items as appropriate. For section 3.3, this applies to Table 3.3.1, line items 3.3.1-19, 3.3.1-27, 3.3.1-42, 3.3.1-43, 3.3.1-58, and 3.3.1-78.

374 Accepted [T.3.3.1-P-01] As defined in 10 CFR 54.3, a TLAA is a licensee calculation or Patel, Erach Finnin, Ron analysis that, among other things, involves time-limited Table 3.3.1, item 3.3.1-1, for steel cranes with an aging assumptions defined by the current operating term. There is no effect of cumulative fatigue damage, the GALL recommends analysis for steel cranes at PNPS that satisfies the definition.

TLAA to be evaluated for structural girders of cranes. The CMAA-70 defines allowable stress range based on joint category discussion section states that this line item was not used in and service class. Service class is based on load class (mean section 3.3, however steel cranes are evaluated In section effective load factor) and number of cycles.

3.5. Tables 3.5.2-2 and 3.5.2-4 address cranes but for an aging effect of loss of materials. Cumulative fatigue damage However, the number of cycles is NOT based on 40 years of of cranes is not addressed in section 3.5 or in the TLAA operation of this crane. The anticipated cycles for the PNPS reactor section 4.7 (plant specific TLAA). Also see TLAA question. building crane are well below any of the cycle ranges given in CMAA-70. Based on realistic estimates and the historical rate of use of the cranes to date, the PNPS reactor building and turbine Please explain where this line item is addressed in the LRA. building cranes would take over 350 years to reach the minimum cycle range for CMAA-70. Consequently there is no TLAA associated with crane load cycles.

Page 18 of 77

Number Status Request Response NRC PNPS Lead 375 Closed [T.3.3.1-P-02] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-5, for heat exchanger exposed to item that credits a water chemistry control program. LRA Table treated water > 60C (>140F), discussion states that OTI will 3.3.1 indicates that the One-Time Inspection Program is credited be used as verification program for water chemistry. along with the water chemistry control programs for line items for However, for those line items in Table 3.3.2-3 where item which GALL recommends a one-time inspection to confirm water 3.3.1-5 is referenced, OTI program is not credited. See chemistry control. Table 2 credits the OTI program through question G.3.3.1.2 above. reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

376 Closed [T.3.3.1-P-03] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1-14 for steel components exposed to would identify degraded conditions that could be attributed to an lubricating oil, GALL report recommends lubricating oil ineffective Oil Analysis Program. The corrective action program at analysis program and OTI as a verification program. PNPS has a low threshold for the identification of degraded However, in the discussion section only the oil analysis conditions such that corrosion or cracking of components would be program is credited. Section 3.3.2.2.7, item 1 states that Identified as part of this program. The review of operating operating experience at PNPS has confirmed the experience at PNPS for the last five years did not Identify any effectiveness of this program in maintaining contaminants condition reports that indicated an ineffective oil analysis program or within limits such that corrosion has not and will not affect that identified degraded component conditions such as corrosion or the intended functions of these components. cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to Please explain how PNPS can make this statement if provide confirmation of the effectiveness of the Oil Analysis inspection has not been performed. Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past Inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

Page 19 of 77

Number Status Request Response NRC PNPS Lead 377 Closed [T.3.3.1-P-04] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-17 for steel elements exposed treated item that credits a water chemistry control program. LRA Table water discussion states that OTI will be used as verification 3.3.1 indicates that the One-Time Inspection Program is credited program for water chemistry. Refer to question T.3.3.1.2 and along with the water chemistry control programs for line items for G.3.3.1.2. This applies to several line items in various which GALL recommends a one-time inspection to confirm water Table 2's that reference item 3.3.1-17. chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

378 Accepted [T.3.3.1-P-05] Enhancements will be made to the Fire Protection program to credit Patel, Erach Fronabarger, existing or implement new preventive maintenance tasks for the fire Table 3.3.1, item 3.3.1-18 for steel and SS diesel engine pump diesel to ensure that all aging effects identified in Table exhaust piping, in the discussion column references section 3.3.2-9 line items that apply to the fire pump diesel components are 3.3.2.2.7 item 3 for further evaluation. Section 3.3.2.2.7 item adequately managed and intended functions are maintained without 3 states that the carbon steel diesel exhaust piping and crediting the detection of leakage as managing an aging effect.

components in the fire protection system is managed by the Fire Protection Program. The Fire Protection Program uses This requires an amendment to LRA appendices A and B.

visual inspections of diesel exhaust piping and components to manage loss of material. However, Appendix B.1.13.1 program description which identifies the system/commodities in scope for inspection does not include the inspection of the diesel exhaust piping and components. There is no enhancement identified in the program write-up to include this inspection during the period of extended operation.

Please explain this discrepancy between section 3.3.2.2.7 item 3 and the AMP B.1.1 3.1 program description or include this inspection in the AMP as an enhancement.

Page 20 of 77

Number Status Request Response NRC PNPS Lead 379 Closed [T.3.3.1-P-06] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1-21 for steel components exposed to would identify degraded conditions that could be attributed to an lubricating oil. This is the same issue as in question ineffective Oil Analysis Program. The corrective action program at T.3.3.1.3 above, except the section is 3.3.2.2.9, item 2. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

380 Closed [T.3.3.1-P-07] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-23 for SS heat exchanger item that credits a water chemistry control program. LRA Table components exposed to treated water. This is the same 3.3.1 indicates that the One-Time Inspection Program is credited issue as in question T.3.3.1.2 above, except the section is along with the water chemistry control programs for line items for 3.3.2.2.10, item 2. which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

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Number Status Request Response NRC PNPSLead 381 Closed [T.3.3.1-P-08] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it Is also applicable to each line Table 3.3.1, item 3.3.1-24 for SS and aluminum components item that credits a water chemistry control program. LRA Table exposed to treated water. This is the same issue as in 3.3.1 indicates that the One-Time Inspection Program is credited question T.3.3.1.2 above, except the section is 3.3.2.2.10, along with the water chemistry control programs for line items for item 2. There are over 80 line items associated with this in which GALL recommends a one-time inspection to confirm water different table 2s. chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

382 Closed [T.3.3.1-P-09] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1-26 for copper alloy components would Identify degraded conditions that could be attributed to an exposed to lubricating oil. This is the same issue as in ineffective Oil Analysis Program. The corrective action program at question T.3.3.1.3 above, except the section is 3.3.2.2.10. PNPS has a low threshold for the Identification of degraded item 4. conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not Identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

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Number Status Request Response NRC PNPS Lead 383 Closed [T.3.3.1-P-10] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-30 for SS components exposed to item that credits a water chemistry control program. LRA Table sodium pentaborate solution. This is the same issue as in 3.3.1 indicates that the One-Time Inspection Program is credited question T.3.3.1.2 above, except the section is 3.3.2.2.10, along with the water chemistry control programs for line items for item 8. which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

384 Closed [T.3.3.1-P-11] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1.33 for SS components exposed to would identify degraded conditions that could be attributed to an lubricating oil. This is the same issue as in question ineffective Oil Analysis Program. The corrective action program at T.3.3.1.3 above, except the section is 3.3.2.2.12, item 2. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would Identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that Identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page 23 of 77

Number Status Request Response NRC PNPS Lead 385 Closed [T.3.3.1-P-12.1] Original Type 304 stainless steel piping and fittings between drywell Patel, Erach Taylor, Andy penetration X-14 and the 6" x 4" reducer downstream of MO-1201-5 Table 3.3.1, item 3.3.1-37 for SS components exposed to were replaced with type 316L stainless steel.

treated water >60C (>140F). This line item applies to RWCU system and GALL Report recommends AMP XI.M25, BWR Reactor Water Cleanup System. The applicant states "Supplement 1 to GL 88-01 states that IGSCC inspection of RWCU piping outside of the containment isolation valves is recommended only until actions associated with GL 89-10 on motor operated valves are completed. Since PNPS has satisfactorily completed all actions requested in NRC GL 89-10, the Water Chemistry Control BWR Program is used in lieu of the BWR Reactor Water Cleanup System Program to manage this potential aging effect." However, the AMP also states that in addition to meeting this criterion, piping is made of material that is resistant to IGSCC.

Please confirm what grade of stainless material is used and justify that it is resistant to IGSCC.

386 Closed [T.3.3.1-P-12.2] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Same issue as question T.3.3.1.2 above also applies here item that credits a water chemistry control program. LRA Table where OTI is not credited in Table 2 line items where 3.3.1 indicates that the One-Time Inspection Program Is credited 3.3.1-37 is referenced. along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

Page 24 of 77

Number Status Request Response NRC PNPS Lead 387 Closed [T.3.3.1-P-13] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-38 for SS components exposed to item that credits a water chemistry control program. LRA Table treated water >60C (>140F). 3.3.1 indicates that the One-Time Inspection Program is credited This is the same issue as in question T.3.3.1.2 above. along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table I line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

388 Accepted [T.3.3.1-P-14] No carbon steel tanks in the fuel oil system exposed to air - outdoor Patel, Erach Nichols, Bill are included in scope for license renewal. The LRA will be Table 3.3.1, item 3.3.1-40 for steel tank in diesel fuel oil amended to remove the line item in table 3.3.2-7 for carbon steel system exposed to air-outdoor external environment. The tanks exposed to air-outdoor. The discussion for line item 3.3.1-40 GALL Report recommends AMP XI.M29 Aboveground Steel will be amended to state the line item is not used.

Tanks, however PNPS is crediting a different program, System Walkdown Program. This program is consistent with This requires a supplement/amendment to the LRA.

GALL Report AMP XI.M36, External Surfaces Monitoring.

While the System Walkdown Program is an acceptable alternate for Aboveground Steel Tanks AMP for inspection, however, the Aboveground Steel Tanks AMP has some preventive actions associated with it that are not addressed in the System Walkdown Program. Furthermore, the GALL AMP specifies wall thickness measurement of tank bottom if it is supported on earthen or concrete foundations.

Please clarify if the steel tanks are coated with protective paint or coating in accordance with industry practice, and whether sealant or caulking is applied at the interface edge between the tank and the foundation as per the GALL AMP XI.M29. Please state how the tank is supported.

Page 25 of 77

Number Status Request Response NRC PNPS Lead 389 Closed [T.3.3.1-P-15] A Bolting Integrity Program will be developed that will address the Patel, Erach Fronabarger.

aging management of bolting in the scope of license renewal.

Table 3.3.1, item 3.3.1-43, for steel bolting and closure bolting exposed to air - indoor uncontrolled (external) or air - The Bolting Integrity Program will be implemented prior to the period outdoor (External). The GALL Report recommends AMP of extended operation in accordance with commitment number 32.

XI.M1 8,Bolting Integrity program, however PNPS Is crediting a different program, System Walkdown Program. PNPS This requires an amendment to the LRA to include descriptions of indicates that the system walkdown program is similar to the Bolting Integrity Program in Appendices A and B and to identify XI.M36, External Surfaces Monitoring Program. However, the where the program is applicable.

XI.M36 AMP does not have any preventive actions, whereas the Bolting Integrity Program considers preventive action. This item is closed to Item 373.

Please justify how the preventive actions of GALL AMP XI.M18 are addressed in the system walkdown program.

390 Accepted [T.3.3.1-P-16] A Bolting Integrity Program will be developed that will address Patel, Erach Lingenfelter, managing the effects of aging on bolting in the scope of license Table 3.3.1, item 3.3.1-58, for steel extemal surfaces renewal. The Bolting Integrity Program will be implemented prior to exposed to air - indoor uncontrolled (external), air outdoor the period of extended operation in accordance with commitment (external), and condensation (external). For those line items number 32.

in Table 2's where this Table 1 line item is referenced for bolting, same issue as question T.15 should be addressed. The LRA will be clarified to include Fire Protection Program in the discussion for Item 3.3.1-58 of Table 3.3.1.

In Table 3.3.2-10, LRA page 3.3.-123, for tank in Halon The revised discussion text will read as follows: "The System system, which references line item 3.3.1-58, Fire Protection Walkdown Program manages loss of material for external surfaces Program is credited. Please justify why the Fire Protection of steel components. For some fire protection system components, Program was not identified in the discussion column of the Fire Protection Program will manage loss of material." The Note Table 3.3.1, item 3.3.1-58 or supplement the LRA to include for the related line in Table 3.3.2-10 (steel halon tank exposed to this program air) will be changed from "B"to "E".

This requires an amendment to the LRA to include descriptions of the Bolting Integrity Program in Appendices A and B and to identify where the program is applicable.

This first part of this item is closed to Item 373.

The Fire Protection portion of this item requires an amendment to the LRA.

Page 26 of 77

Number Status Request Response NRC PNPS Lead 391 Accepted [T.3.3.1-P-17] In Table 3.5.2-6 on Page 3.5-82 of the LRA, the aging effects for the Patel, Erach Lingenfelter, elastomer components penetration sealant and seismic joint filler in Table 3.3..1, item 3.3.1-61, for elastomer fire barrier a protected from weather environment are cracking and change in penetration seals exposed to air- outdoor or air indoor material properties. Depending on the specific application, the Fire uncontrolled. PNPS credits Fire Protection Program and Protection Program or the Structures Monitoring Program will states in the discussion column that this line item was not manage the effects of aging. For clarification, these component line used in the auxiliary systems tables. Fire barrier seals are items will be separated into individual line items as follows.

evaluated as structural components in Section 3.5. Cracking and the change in material properties of elastomer seals are Delete the following line items:

managed by the Fire Protection Program. Penetration sealant(fire rated, flood, radiation) fl EN, FB, FLB, PB, SNS II Elastomer // Protected from weather / Cracking Change in However, in section 3.5, Table 3.5.2-6, Bulk Commodities, material properties// Fire protection/Structures Monitoring//I I1.A6-12 on pages 3.5-82, and 3.5-83, where line item 3.3.1-61 is (TP-7) // 3.5.1-44 // C referenced, PNPS credits the Fire Protection Program and the Structures Monitoring program. However, line item Seismic joint filler// FB, SNS // Elastomer // Protected from weather 3.3.1-61 does not credit structures monitoring program. As a // Cracking Change in material properties /I Structures Monitoring, matter of fact, the Structures Monitoring Program is Fire Protection// VIL.G1 (A-19) //3.3.1-61//C enhanced to add guidance for inspection of elastomer seals, etc. Please clarify if both programs are credited for Add the following line items:

managing aging effects for penetration seals as stated in Penetration sealant (fire rated) / EN, FB, PB, SNS /I Elastomer //

Table 3.5.2-6, and if so, please supplement the LRA to Protected from weather II Cracking Change in material properties /

include the Structures Monitoring program in Table 3.3.1, Fire Protection // VII.G-1 (A-1 9)//3.3.1-61// B item 3.3.1-61.

Penetration sealant (flood, radiation) II EN, FLB, PB, SNS II Elastomer // Protected from weather// Cracking Change in material properties//Structures Monitoring II III.A6-12 (TP-7) // 3.5.1-44 // C Seismic isolation joint / FB, SNS II Elastomer // Protected from weather // Cracking Change in material properties//Fire protection/I VII.G-1 (A-19) //3.3.1-61// D Seismic isolation joint / SNS II Elastomer I/ Protected from weather

//Cracking Change in material properties // Structures monitoring II III.A6-12 (TP-7) // 3.5.1-44//C This requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 392 Accepted [T.3.3.1-P-18] PNPS has a diesel driven fire pump with components addressed in Patel, Erach Fronabarger, Table 3.3.2-9. The fuel oil supply to the diesel driven fire pump is Table 3.3.1, item 3.3.1-64 for steel piping, piping included in Table 3.3.2-7. The line item of carbon steel piping with components, and piping elements exposed to fuel oil. The a fuel oil internal environment in Table 3.3.2-7 for the fuel supply intent of this line is to address the diesel-driven fire pump, line does not credit the Fire Protection Program. Although the which is why the Fire Protection Program is recommended by programs credited in Table 3.3.2-7 for the fuel supply line provide an the GALL Report. PNPS states that this line item was not acceptable alternative approach to manage the effects of aging, in used. Loss of material of steel components exposed to fuel order to achieve consistency with NUREG-1 801 the LRA will be oil was addressed by other items including line Items 3.3.1 revised to credit the Fire Protection Program. LRA Table 3.3.2-7 will 20 and 3.3.1 32. The Fire Protection program specifies that be revised to add an additional line item to credit the Fire Protection the diesel driven fire pump be periodically tested to ensure Program to manage the fuel supply line in addition to the Diesel that the fuel supply line can perform its intended function. Fuel Monitoring Program. This will also require a change to line PNPS B.1.13.1 has not taken any exception to this test and item 3.3.1-64 since the new line item will specify 3.3.1-64 as the is identified as being consistent with the GALL program. Table 1 item.

However, B.1.13.1, Fire Protection program is not credited in line item 3.3.1 20. This requires an amendment to the LRA.

Please clarify if PNPS has a diesel driven fire pump and if not, should an exception be taken to the GALL Report AMP.

IfPNPS does have a diesel driven fire pump, where in the LRA section 3.3 is it addressed and is the Fire Protection program credited.

393 Closed [T.3.3.1-P-19] The internal components of the heat exchanger housing have the Patel, Erach Orlicek, Jack potential for being exposed to a combination of low temperature Table 3.3.1, item 3.3.1-72 for steel HVAC ducting and closed cooling water and high dewpoint indoor drywell air which components internal surfaces exposed to condensation could result (though not expected) in condensation on the cooling (Internal). However, there is only line in Table 2 where this coil that would be collected in the bottom of the housing.

Table 1 line item is referenced. This line item is in Table Condensation was also identified on the un-insulated external 3.3.2-3, RBCCW system and the component is heat surfaces of the heat exchanger housing due to the potential of the exchanger housing. PNPS states in the discussion column housing surface temperature downstream of the cooling coil being of line 3.3.1-72 that loss of material of steel component less than or equal to the dew point of the surrounding air in the internal surfaces exposed to condensation is managed by drywell. These environments were conservatively identified even the System Walkdown Program. The System Walkdown though the expected environment would be indoor air with no Program manages loss of material for external carbon steel condensation since the cooling water temperature is normally components by visual inspection of external surfaces. For maintained at - 80°F. System Walkdown was credited because the systems where internal carbon steel surfaces are exposed to expected environment for both the internal and external surfaces the same environment as external surfaces, extemal would be the same in either case.

surfaces condition will be representative of internal surfaces.

Thus, loss of material on internal carbon steel surfaces is also managed by the System Walkdown Program.

Please clarify how PNPS concluded that the internal surface of the heat exchanger is the same as the external surface in the RBCCW system.

Page 28 of 77

Number Status Request Response NRC PNPS Lead 394 Accepted [".3.3.2-P-011 Since it manages internal and external surfaces with the same Patel, Erach Fronabarger, material and environments, the System Walkdown Program Component types filter housing and turbo charger in Table described in B.1.30 is a more appropriate program for the line items 3.3.2-9, Fire Protection - Water system and piping in Table inTable 3.3.2-9 that have Indoor air (int) as an environment and 3.3.2-10, Fire Protection - Halon system reference Table credit the Fire Protection Program. In addition, line item 3.2.1-32 3.2.1, item 3.2.1-32. This Table 1 line item addresses steel should include the Fire Protection Program since Table 3.3.2-10 piping and ducting components and internal surfaces includes Halon system piping Internal surfaces that credit the Fire exposed to air-indoor uncontrolled (internal) environment. Protection Program and rollup to this line item.

Discussion column of item 3.2.1-32 credits System Walkdown, Periodic Surveillance and Preventive This requires an amendment to the LRA.

Maintenance, and One-Time Inspection programs. However, the Table 3.3.2-9 and Table 3.3.2-10 components identified above credit Fire Protection Program, which is not credited in the discussion column of item 3.2.1-32. Furthermore, the program description of LRA Appendix B.1.13.1, Fire Protection Program does not include inspection of the above identified components.

Please clarify the discrepancy between the credited programs in item 3.2.1-32 and the program credited for the above identified component types. Also, please justify why the Fire Protection program description does not address inspection of these component types in these two systems or enhance the program to include these inspections.

395 Closed [T.3.3.2-P-02] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Component types heat exchanger tubes in Table 3.3.2-4, would identify degraded conditions that could be attributed to an Emergency Diesel Generator system and Table 3.3.2-9, Fire ineffective Oil Analysis Program. The corrective action program at Protection - Water system are made from copper alloy and PNPS has a low threshold for the identification of degraded exposed to lubricating oil environment, which reference conditions such that corrosion or cracking of components would be Table 3.2.1, item 3.2.1-9. PNPS only credits the Oil identified as part of this program. The review of operating Analysis program. This issue is the same as in question experience at PNPS for the last five years did not identify any T.3.3.1.3. condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

See response to item 376.

Page 29 of 77

Number Status Request Response NRC PNPS Lead 396 Closed [T.3.3.2-P-03] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Component types heat exchanger tubes in Table 3.3.2-5, would identify degraded conditions that could be attributed to an Station Blackout diesel Generator system, and Table 3.3.2-6, ineffective Oil Analysis Program. The corrective action program at Security Diesel Generator system are made from steel and PNPS has a low threshold for the identification of degraded exposed to an extemal environment of fuel oil with an aging conditions such that corrosion or cracking of components would be effect of reduction of heat transfer due to fouling, which identified as part of this program. The review of operating reference Table 3.4.1, item 3.4.1-10. PNPS only credits the experience at PNPS for the last five years did not identify any Oil Analysis program. This issue is the same as in question condition reports that indicated an ineffective oil analysis program or T.3.3.1.3 that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating Also, please clarify why one of the above component type experience at PNPS serves in lieu of a one-time inspection to identifies footnote 'D', whereas the other identifies footnote provide confirmation of the effectiveness of the Oil Analysis

'E', even though they have the same MEAP combination. Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these Inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

397 Closed (T.3.3.2-P-041 Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Steel component types thermowell, tubing and valve body in item that credits a water chemistry control program. LRA Table Table 3.3.2-14-19, Off-Gas system reference Table 3.4.1, 3.4.1 indicates that the One-Time Inspection Program is credited item 3.4.1-13, which credits water chemistry and one-time along with the water chemistry control programs for line items for inspection program for verification. However the table 2 line which GALL recommends a one-time inspection to confirm water items do not credit the verification program. This is the chemistry control. Table 2 credits the OTI program through same issue as questions G.3.3.1.2 and T.3.3.1.2. reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

Page 30 of 77

Number Status Request Response NRC PNPS Lead 398 Closed [T.3.3.2-P-05] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Stainless steel component types thermowell, tubing and item that credits a water chemistry control program. LRA Table valve body in Table 3.3.2-14-19, Off-Gas system reference 3.4.1 indicates that the One-Time Inspection Program is credited Table 3.4.1. item 3.4.1-14, which credits water chemistry and along with the water chemistry control programs for line items for one-time inspection program for verification. However the which GALL recommends a one-time inspection to confirm water table 2 line items do not credit the verification program. This chemistry control. Table 2 credits the OTI program through is the same issue as questions G.3.3.1.2 and T.3.3.1.2. reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

399 Closed [T.3.3.2-P-06] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Steel component types ejector, heat exchanger shell, orifice, item that credits a water chemistry control program. LRA Table piping, pump casing, thermowell, and valve body in Table 3.4.1 indicates that the One-Time Inspection Program is credited 3.3.2-14-19, Off-Gas system reference Table 3.4.1, item along with the water chemistry control programs for line items for 3.4.1-2, which credits water chemistry and one-time which GALL recommends a one-time inspection to confirm water inspection program for verification. However the table 2 line chemistry control. Table 2 credits the OTI program through items do not credit the verification program. This is the reference to the associated Table 1 line item.

same issue as questions G.3.3.1.2 and T.3.3.1.2.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

400 Accepted [T.3.3.2-P-07] The appropriate entries for the last three columns for the line in Patel, Erach Lingenfelter, Table 3.3.2-14-27, RWCU system, steel component type heat Table 3.3.2-14-27, RWCU system, steel component type exchanger shell, in treated water environment with an aging effect of heat exchanger shell, in treated water environment with an loss of material, are VII.C2-14 (A-25), 3.3.147, and D.

aging effect of loss of material, PNPS credits Water Chemistry Control - Closed Cooling Water program and This requires an amendment to the LRA.

references Table 3.3.1, line item 3.3.1-17. However, line item 3.3.1-17 addresses Water Chemistry Control - BWR program.

Should line item 3.3.1-47 be referenced, which addresses the Water Chemistry Control - Closed Cooling Water for the same MEAP combination? Please supplement the LRA accordingly.

Page31 of 77

Nunber Status Request Response NRC PNPS Lead 401 Accepted [T.3.3.2-P-08] The appropriate Table I Item entry for the line in Table 3.3.2-14-27, Patel, Erach Lingenfelter, RWCU system, stainless steel component type orifice, in treated Table 3.3.2-14-27, RWCU system, stainless steel water environment with an aging effect of loss of material, is component type orifice, in treated water environment with an 3.3.1-24.

aging effect of loss of material, references Table 3.3.1, line item 3.3.1-17. However, this line item is for steel This requires an amendment to the LRA.

components.

Should line item 3.3.1-24 be referenced, which addresses stainless steel components for the same EAP? Please supplement the LRA accordingly.

402 Closed [3.5.2.2.1.4-H-01] As stated in Section 3.5.2.2.1.4, PNPS inspections of the drywell Hoang, Dan Ahrabli, Reza shell below floor level identified no evidence of corrosion of the Loss of material due to General, Pitting and Crevice drywell shell. The drywell shell steel has a coated surface and no Corrosion. degradation of this coating was identified. The statement in question is not addressing the current condition but rather the Please, explain for your last statement in this section as it conditions expected in the future. It is difficult to say there will be said: "Therefore, significant corrosion of the drywell shell is absolutely no corrosion in the future, but there is reasonable not expected". Does this mean you DO have some assurance that corrosion, if any, will not be significant or meaningful corrosion? Ifnot, why significant? with respect to degradation.

403 Closed [3.5.2.2.1.7-H-01] The "other"method which may be'used to detect cracking is the Hoang, Dan Ahrabli, Reza existing Containment Leak Rate Program with augmented ultrasonic Stress Corrosion Cracking (SCC) becomes significant for exams. Observed conditions that have the potential for impacting an stainless steel if a tensile stress and a corrosion intended function are evaluated or corrected in accordance with the environment exist. The stress may be applied external or corrective action process. The Containment Leak Rate Program is residual (internal). Visual VT-3 examinations may be unable described in Appendix B.

to detect this aging effect. Potential susceptible components at PNPS are penetration sleeves and bellows.

Please identify the "Other" method of examination to detect this style of effect?

404 Closed [3.5.2.2.2.1-H-01o As stated in Section 3.5.2.2.2.1 of the LRA, PNPS has no structures Hoang, Dan Ahrabli, Reza that are not covered by Structures Monitoring Program that are within Aging of structures not covered by Structures Monitoring the scope of license renewal and subject to aging management Program. review.

Do you (PNPS) have any operating experience related to this area? Please, provide the details.

405 Closed [3.5.2.2.2.1.8-H-01] The lubrite plates associated with the radial beam seats are Hoang, Dan Ahrabli, Reza inspected under the Structures Monitoring Program. The lubrite Lock Up due to wear for Lubrite Radial beam Seats in BWR plates associated with the torus support structure are inspected by drywell and other Sliding Support Surfaces.. As indicated in the ISI (IWF) program.

this section that *...lock-up due to wear is not an aging effect requiring management at PNPS. However, Lubrite plates are including within the Structures Monitoring Program and Inservice Inspection (ISI-IWF) Programs..." Please, provide the cross reference in between these two programs.

Page 32 of 77

Number Status Request Response NRC PNPS Lead 406 Closed [3.5.2.2.2.6-H-01] Need clarification. What is meant by "the bolting integrity generic Hoang, Dan Ahrabli, Reza issue"?

Aging Support not covered by Structures Monitoring Program.

Please provide: 1) Bolting material at PNPS consists of A325 -Type 1 conforming to ASTM-A325 and A490 Type 1 conforming to ASTM-A490, per

1. More information is needed about bolting materials used PNPS specification C-94-ER-Q-E3. The nominal yield strength for in structural applications at PNPS including Group B1.1 A325 Is 92 ksl and for A490 is 130 ksl. For structural bolting applications. What are the bolting materials used? What applications, PNPS is consistent with NUREG 1801 in managing are the nominal yield strengths and upper-bound as-received the effects of aging with the structures monitoring program or ISI yield strengths? Describe the PNPS resolution of the bolting (IWF), as applicable. No PNPS bolting has been identified that is integrity generic issue, as it relates to structural bolting. susceptible to SCC.

Was any structural bolting identified as potentially susceptible to cracking due to SCC? Was any structural 2) In general, PNPS manages loss of material for bolting with visual bolting replaced as part of the resolution? inspections. For structural bolting, the visual inspections are part of the Structures Monitoring Program. Loss of preload due to stress

2. Describe the scope and AMR for Class MC Pressure relaxation (creep) would only be a concern in very high temperature Retaining Bolting. How is loss of preload managed? applications (> 700°F) as stated In the ASME Code,Section II, Part D, Table 4. No PNPS structural bolting operates at >700°F.

Therefore, loss of preload due to stress relaxation (creep) is not an applicable aging effect for structural bolting. Other causes of loss of preload include inadequate bolted joint design and ineffective maintenance practices. Loss of preload due to these causes is prevented by incorporation of Industry guidance for good bolting practices into PNPS procedures for design and maintenance of bolted joints.

407 Accepted [3.5.1-13-H-01] Line item 3.5.1-13 addresses steel, stainless steel elements, Hoang, Dan Ahrabli, Reza dissimilar metal welds: torus; ventline; vent header;, ventline bellows In Table 3.5.2-1 on Page 3.5-51 of the LRA, for component and downcomers. For PNPS ventline bellows and associated Bellows the AMPs shown is CII-IWE, which is a welds, this line item is consistent with the NUREG-1801 AMR plant-specific AMP. A Note C has been assigned to this results, but the PNPS ClI-IWE program described in Appendix Bis a AMR line item, component is different, but consistent with plant-specific program. The Drywell to torus vent line bellows item material, environment, aging effect, and aging management on LRA Page 3.5-51 references line item 3.5.1-13 and correctly program for NUREG-1801 line item. This AMP is consistent indicates Note "E".

with NUREG-1 801 the GALL description.

For the Bellows (reactor vessel and drywell) line item in Table Table 1 line item 3.5.1-13 bellows. Explain how the 3.5.2-1 on Page 3.5-51 of the LRA, reference to line item 3.5.1-13 is plant-specific PNPS CII-IWE AMP is consistent with the not appropriate. The Table 3.5.2-1 line item *Bellows (reactor GALL specified AMP. vessel and drywell)" and the corresponding line item in Table 2.4-1, Page 2.4-13, were inadvertently included in the LRA and should be deleted. The reactor vessel and drywell bellows perform no license renewal intended function. These components are not safety-related and are not required to demonstrate compliance with regulations identified In 10 CFR 54.4(a)(3). Failure of the bellows will not prevent satisfactory accomplishment of a safety function.

Leakage, if any, through the bellows is directed to a drain system that prevents the leakage from contacting the outer surface of the drywell shell.

Deleting the line items discussed above requires an amendment to the LRA.

Page 33 of 77

Number Status Request Response NRC PNPS Lead 408 Accepted [3.5.1-16-H-01] PNPS primary containment does not have a moisture barrier. Hoang, Dan Ahrabli, Reza Therefore an AMP is not required. The referenced line item on Page In Table 3.5.2-1 on page 3.5-55 of the LRA for Primary 3.5-55 applies only to primary containment electrical penetration Containment Electrical Penetration seals and sealant, the seals and sealant.

AMP shown is Structures Monitoring. The applicant is asked to verify that the ClI-IWE AMP will not be used instead to Table Line Item 3.5.1-16 will be updated to read: "The aging effects manage the aging of the moisture barrier. cited in the NUREG-1 801 item are loss of sealing and leakage.

Loss of sealing is a consequence of the aging effects cracking and change in material properties. For PNPS, the Containment Leak Rate program manages cracking and change in material properties for the primary containment seals and gaskets. There is no moisture barrier where the drywell steel shell becomes embedded in the drywell concrete floor."

This requires an amendment to the LRA.

409 Accepted [3.5.1-44-H-01] In Table 3.5.2-6 on Page 3.5-83 of the LRA, for component seals Hoang, Dan Ahrabli, Reza and gaskets, material rubber in a protected from weather In Table 3.5.2-6 on Page 3.5-83 of the LRA, for component environment, Note "E" was used because it applies to the top half of seals and gaskets, material rubber in a protected from the line item. The LRA will be clarified to indicate that Note "A" weather environment; the aging effects are cracking and applies to the lower half of the line item.

change in material properties. One of the aging management programs shown is the Structures Monitoring This requires an amendment to the LRA.

Program. The GALL line item referenced is III.A6-12 and the Table 1 reference is 3.5.1-44. The note shown is E, a different AMP than shown in GALL. However, GALL Line Item II1.A6-12 and Table 1 Line Item 3.5.1-44 both specify the Structures Monitoring Program. Explain why the note shown is not A instead of E for the lower half of this AMR line item.

410 Accepted [3.5.1-58-H-01] NUREG-1801 does not mention every type of component that may be Hoang, Dan Ahrabli, Reza subject to aging management review (e.g., panel is not in In Table 3.5.2-6 on Page 3.5-73 of the LRA, for component NUREG-1801) nor does the terminology used at a specific plant electrical and instrument panels and enclosures, material always align with that used in GALL. Consequently, matching plant galvanized steel in a protected from weather environment; the components to NUREG-1 801 components is often subjective. In aging effect is none. The GALL line item referenced is this particular case, panels, which have no specific function other III.B3-3, which is for the following components: Support than to support and protect electrical equipment, were considered members; welds; bolted connections; support anchorage to support members and Note A was applied. The use of either Note A building structure. Explain why the LRA AMR line item has a or C has no impact on the aging management review results.

Note A shown instead of a Note C, different component with respect to the GALL line item. Or as an alternative, a letter Note "A" will be changed to Note "C" for component electrical and Note A with a number note explaining that the component is instrument panels and enclosures, material galvanized steel in a different. protected from weather environment in Table 3.5.2-6 on Page 3.5-73 of the LRA. No change is required to the other entries for this line item.

This requires an amendment to the LRA.

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Nuimber Status Request Response NRC PNPS Lead 411 Accepted [3.5.1-8-H-011 For Table 3.5.2-1 on Page 3.5-54 of the LRA for component Torus Hoang, Dan Ahrabli, Reza shell with the aging effect cracking-fatigue, Note "E" will be changed In Table 3.5.2-1 on Page 3.5-54 of the LRA for component to Note "A*.

Torus shell with the aging effect cracking-fatigue, the note assigned is E. Note E is consistent with NUREG-1 801 This requires an amendment to the LRA.

material, environment, and aging effect but a different aging management program is credited. Explain why this note is E when the AMP shown for this line item is TLAA and the referenced GALL Line Item ll.B1.1-4 also specifies a TLAA.

412 Accepted [3.5.1-5-H-01] For LRA Table 3.5.1, Item 3.5.1-5, the discussion in Section Hoang, Dan Ahrabli, Reza 3.5.2.2.1.4, Page 3.5-9, should have the reference to moisture barrier LRA table 3.5.1, Item Number 3.5.1-5, has the following deleted, since the PNPS drywell does not contain this commodity.

statement under the discussion column: "The drywell steel where the drywell shell is embedded is inspected in accordance with the Containment Inservice Inspection (IWE) For LRA Table 3.5.1, Item 3.5.1-5, the discussion column should Program and Structures Monitoring Program". This is an read: "The drywell steel shell and the area where the drywell shell difficult inspection. Change this discussion statement to becomes embedded in the drywell concrete floor are inspected In agree with LRA Section 3.5.2.2.1.4 that states: The drywell accordance with the Containment Inservice Inspection (IWE) steel shell and the moisture barrier where the drywell shell Program.*

becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice The last sentence of the first paragraph in LRA Section 3.5.2.2.1.4, Inspection (IWE) Program and Structures Monitoring should read: "The drywell steel shell and the area where the drywell Program. shell becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice Inspection (IWE)

Program."

This requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 413 Accepted [3.5.1-9-H-01O Fatigue analyses have been evaluated for the tows, torus vent Hoang, Dan Ahrabli, Reza system, and torus penetrations. The following line will be added to LRA Table 3.5.1, Item Number 3.5.1-9, has the following Table 3.5.2-1: 'Torus mechanical penetrations II PB, SSR // Carbon statement under the discussion column: Not applicable. steel// Protected from weather // Cracking // TLAA-metal fatigue I See Section 3.5.2.2.1. This should be read as Section I1.B4-4(C-13) // 3.5.1-9 // A" 3.5.2.2.1.6. However, the following statement is made in LRA Section 3.5.2.2.1.6: "Fatigue TLAAs for the steel The evaluation of the torus vent system fatigue analysis determined drywell, torus, and associated penetrations are evaluated that it was not a TLAA. The significant contributor to fatigue of the and documented in Section 4.6." The components vent system is post-LOCA chugging, a once in plant-life event. As associated with LRA Table 3.5.1, Item Number 3.5.1-9 are: there will still be only one design basis LOCA for the life of the penetration sleeves, penetration bellows; suppression pool plant, including the period of extended operation, this analysis is not shell, unbraced downcomers. Explain how Item number based on a time-limited assumption and is not a TLAA. Fatigue for 3.5.1-9 is not applicable when a fatigue TLAA has been the vent system is event-driven and is not an age-related effect.

performed for the torus and penetrations. Explain why the vent line, vent header and vent line bellows are not listed in The discussion column entry for Table 3.5.1 item 3.5.1-8 will be LRA Sections 3.5.2.2.1.6 and 4.6 as referenced in Table changed to read as follows: 'Fatigue analysis Is a TLAA for the 3.5.1, Line Item 3.5.1-8. torus shell. Fatigue of the vent system is event-driven and the analysis is not a TLAA. See Section 3.5.2.2.1.6."

The discussion column entry for Table 3.5.1 item 3.5.1-9 will be changed to read as follows: "Fatigue analysis is a TLAA for the torus penetrations. See Section 3.5.2.2.1.6."

Section 3.5.2.2.1.6 will be changed to read as follows: "TLAA are evaluated in accordance with 10 CFR 54.21(c) as documented in Section 4. Fatigue TLAAs for the torus and associated penetrations are evaluated and documented in Section 4.6."

Section 3.5.2.3, Time-Limited Aging Analyses, will be changed to read as follows: "TLAA identified for structural components and commodities include fatigue analyses for the torus and torus penetrations. These topics are discussed in Section 4.6."

These changes require an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 414 Accepted [3.5.1-12-H-01] A link from items 3.5.1-12 and 3.5.1-13 will be added to section Hoang, Dan Ahrabli, Reza 3.5.2.2.1.8.

LRA Table 3.5.1, Item Number 3.5.1-12 and 3.5.1-13, under the discussion column, does not make reference to LRA Section 3.5.2.2.1.8 should state: 'Cyclic loading can lead to Section 3.5.2.2.1.8 for further evaluation. Explain why this cracking of steel and stainless steel penetration bellows, and link is not made to the further evaluation section. Explain the dissimilar metal welds of BWR containments and BWR need for augmented ultrasonic exams to detect fine cracks suppression pool shell and downcomers."

since a CLB fatigue analysis does exist.

Cracking due to cyclic loading is not expected to occur in the drywell, torus and associated penetration bellows, penetration sleeves, unbraced downcomers, and dissimilar metal welds. A review of plant operating experience did not identify cracking of the components and primary containment leakage has not been identified as a concern. Nonetheless, the Containment Leak Rate Program with augmented ultrasonic exams and Containment Inservice Inspection - IWE, will continue to be used to detect cracking. Observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process. The Containment Inservice Inspection - IWE and Containment Leak Rate programs are described in Appendix B.

This requires an amendment to the LRA.

415 Closed [3.5.1-16-H-011 There is no gap to seal at the joint between the containment drywell Hoang, Dan Ahrabli, Reza shell and the concrete floor. Concrete grout is poured directly LRA Table 3.5.1, Item Number 3.5.1-16, under the against the drywell shell. The installation is shown as Detail 1 on discussion column, states that seals and gaskets are not Drawing C-71. The Containment Inservice Inspection Program included in the Containment Inservice Inspection Program at includes inspection of this joint.

PNPS. One of the components for this item number is moisture barriers. Explain how PNPS seals the joint (Also see audit question #408 which addresses changes to LRA) between the containment drywell shell and drywell concrete floor if there is no moisture barrier. Explain why the inspection of this joint is not part of the Containment Inservice Inspection Program.

416 Closed [3.5.1-33-H-01] The maximum bulk area ambient temperatures for Groups 1-5 occurs Hoang, Dan Ahrabli, Reza in the drywell and is an average temperature of 148°F, reference For LRA Table 3.5.1, Item Number 3.5.1-33, provide the UFSAR Table 5.2-2. For structures outside the drywell the bulk area maximum temperatures that concrete experience in Group maximum temperature is 120°F for Groups 1-5 structures as 1-5 structures. identified in Table 10.9-2 of PNPS UFSAR. Concrete within the drywell consist of the reactor pedestal, sacrificial shield wall and the drywell floor. Assurance that bulk concrete temperatures within the drywell remain below 150 degrees F is obtained through maintaining average bulk containment temperature within the limits allowed by PNPS Technical Specification Section 3.2-H (Page 3/4.2-5). Although upper elevations of the drywell may exceed 150°F, the concrete of the drywell is at lower elevations. The drywell cooling system provides cooling to ensure temperature limits are not exceeded. The highest concrete in the drywell is the sacrificial shield wall. The concrete in this wall is not load bearing.

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Number Status Request Response NRC PNPS Lead 417 Accepted [3.5.1-34-H-01O NUREG-1 800, Item Number 3.5.1-34 indicates that further evaluation Hoang, Dan Ahrabli, Reza is necessary only for aggressive environments. No reference was LRA Table 3.5.1, Item Number 3.5.1-34, under the provided to further evaluation in LRA Section 3.5.2.2.2.4 (1) since discussion column, does not make reference to LRA Section the PNPS environment is not aggressive as noted in LRA Table 3.5.2.2.2.4 (1) for further evaluation. Explain why this link Is 3.5.1, Item Number 3.5.1-34, under the discussion column.

not made to the further evaluation section.

For clarification, LRA Table 3.5.1, Line Item 3.5.1-34 discussion will be'revised to add "See Section 3.5.2.2.2.4(1)".

This requires an amendment to the LRA.

418 Accepted [3.5.1-35-H-01] For clarification, LRA Table 3.5.1, Item 3.5.1-35 discussion will be Hoang, Dan Ahrabli, Reza revised to add reference to Section 3.5.2.2.2.4(2). LRA Table 3.5.1, LRA Table 3.5.1, Item Number 3.5.1-35, under the Item 3.5.1-35 discussion will be revised to refer to ACI 318 in lieu of discussion column, does not make reference to LRA Section ACI-301, since the provided reference to ACI should have been ACI 3.5.2.2.2.4 (2) for further evaluation. Explain why this link is 318 and not ACI 301.

not made to the further evaluation section.

This requires an amendment to the LRA.

419 Accepted [3.5.1-36-H-01] LRA Table 3.5.1, Line item Number 3.5.1-36 discussion will be Hoang, Dan Ahrabli, Reza revised to read as follows: "Reaction with aggregates is not an LRA Table 3.5.1, Item Number 3.5.1-36, under the applicable aging mechanism for PNPS concrete components. See discussion column, does not make reference to LRA Section Section 3.5.2.2.2.1(5) (although for Groups 1-5, 7, 9 this discussion 3.5.2.2.2.4 (3) for further evaluation. Explain why this link is is also applicable for Group 6) and Section 3.5.2.2.2.4(3) additional not made to the further evaluation section. The statement: discussion. Nonetheless, the Structures Monitoring Program will "See Section 3.5.2.2.2.1 (5) for additional discussion" needs confirm the absence of aging effects requiring management for further clarification that this section is for Groups 1-5, 7-9, PNPS Group 6 concrete components."

however it would apply to accessible Group 6 concrete.

Explain why LRA Section 3.5.2.2.2.4 (3) lists cracking of Due to an administrative oversight, the heading of LRA Section concrete due to Stress Corrosion Cracking (SCC). 3.5.2.2.2.4 (3) inadvertently lists cracking of concrete due to Stress Corrosion Cracking (SCC). This section heading should have begun with "Cracking Due to Expansion and Reaction with Aggregates...".

Stress corrosion cracking is not discussed in the body of this section.

This change requires an amendment to the LRA.

420 Accepted [3.5.1-40-H-01] Building concrete at locations of expansion and grouted anchors; Hoang, Dan Ahrabli, Reza grout pads for support base plates are shown as "foundation" and LRA Table 3.5.1, Item Number 3.5.1-40, under the "Reactor vessel support pedestal" in LRA Table 3.5.2-1 (page discussion column, states: "...Plant experience has not 3.5-55), "foundation" in Tables 3.5.2-2 through 3.5.2-5 (pages 3.5-59, identified reduction in concrete anchor capacity or other 3.5-61, 3.5-64, and 3.5-67), and as "Equipment pads/foundations" In concrete aging mechanisms. Nonetheless, the Structures Table 3.5.2-6 (page 3.5-80). Further evaluation is provided in LRA Monitoring Program will confirm absence of aging effects section 3.5.2.2.2.6(1), page 3.5-15.

requiring management for PNPS concrete components."

The project team cannot find an AMR line item in Table 2 for For clarification, LRA Table 3.5.1, Item Number 3.5.1-40 discussion this component (Building concrete at locations of expansion will be revised to add "See Section 3.5.2.2.2.6(i)".

and grouted anchors; grout pads for support base plates).

Provide the Table 2 number, LRA page number, and This requires an amendment to the LRA.

component for where this AMR line item is evaluated and shown.

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Number Status Request Response NRC PNPS Lead 421 Accepted [3.5.1-50-H-01] For LRA Table 3.5.1, Item Number 3.5.1-50, the discussion column Hoang, Dan Ahrabli, Reza should read: "This aging effect is managed by the Structures LRA Table 3.5.1, Item Number 3.5.1-50, under the Monitoring Program."

discussion column, states that loss of material is not applicable to PNPS. NUREG-1833 on Page 93 for Item TP-6 Components that may be considered in the B2 and B4 grouping states an approved precedent exists for adding this material, consist of those line items in Table 3.5.2-6 with materials environment, aging effect, and program combination to the galvanized steel, aluminum, or stainless steel.

GALL Report. As shown in RNP SER Section 3.5.2.4.3.2, galvanized steel and stainless steel in an outdoor air This requires an amendment to the LRA.

environment could result in loss of material due to constant wetting and drying conditions. Aluminum would also be susceptible to a similar kind of aging effect in the outdoor environment. Provide a discussion of the actual group B2 and B4 galvanized steel, aluminum, and stainless steel PNPS components which are within the scope of license renewal and exposed to an outdoor air environment. Discuss the location of these components at PNPS and how they are protected from constant wetting and drying conditions.

422 Accepted (3.5.1-52-H-01O Loss of material due to corrosion is an aging effect that can cause a Hoang, Dan Ahrabli, Reza loss of intended function. Loss of mechanical function would be LRA Table 3.5.1, Item Number 3.5.1-52, under the considered a loss of intended function. Loss of mechanical discussion column, states that loss of mechanical function function is not an aging effect, but is the result of aging effects.

due to the listed mechanisms is not an aging effect. Proper There have been component failures in the industry due to design prevents distortion, overload, and fatigue due to distortion, overload, and excessive vibration. Such failures typically vibratory and cyclic thermal loads. Explain how loss of result from inadequate design or events rather than the effects of mechanical function due to corrosion is not an aging effect aging. Failures due to cyclic thermal loads are very rare for which needs to be managed for the period of extended structural supports due to their relatively low temperatures. The operation. If proper design prevents distortion, overload, and sliding surface material used at PNPS is lubrite, which is a fatigue due to vibratory and cyclic thermal loads, explain if corrosion resistant material. Components are inspected under there has ever been a component failure at PNPS due to any ISI-IWF for torus saddle supports and Structures Monitoring Program of these conditions. Explain if there has ever been a for the lubrite components of radial beam seats. Plant operating component failure in the nuclear industry due to any of these experience has not identified failure of lubrite components used in conditions. Explain where sliding support bearing and structural applications. No current industry experience has Identified sliding support surfaces are used in component groups B2 failure associated with lubrite sliding surfaces. Components and B4 at PNPS and provide the environment they are associated with B2 grouping are limited to the torus radial beam exposed to. seats and support saddles. There are no sliding support surfaces associated with the B4 component grouping for sliding surfaces at PNPS.

For clarification, LRA Table 3.5.1, Item 3.5.1-52 will be revised to read as follows: "Loss of mechanical function due to the listed mechanisms is not an aging effect. Such failures typically result from inadequate design or operating events rather than from the effects of aging. Failures due to cyclic thermal loads are rare for structural supports due to their relatively low temperatures."

This requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 423 Accepted [3.5.1-54-H-01] The discussion for Item Number 3.5.1-54 was not implying that Hoang, Dan Ahrabli, Reza failures have not occurred, but that loss of mechanical function Is LRA Table 3.5.1, Item Number 3.5.1-54, under the not an aging effect. For license renewal, Entergy identifies a discussion column, states that loss of mechanical function number of aging effects that can cause loss of intended function.

due to the listed mechanisms is not an aging effect. Proper Loss of ifitended function includes loss of mechanical function.

design prevents distortion, overload, and fatigue due to The loss of function is not considered an aging effect. Aging vibratory and cyclic thermal loads. Explain how loss of effects that could cause loss of mechanical function for mechanical function due to corrosion is not an aging effect components in Item Number 3.5.1-54 are addressed elsewhere in which needs to be managed for the period of extended the aging management reviews. For example, loss of material due operation. If proper design prevents distortion, overload, and to any mechanism is addressed In Table 3.5.2-6 under listings for fatigue due to vibratory and cyclic thermal loads, explain if component and piping supports ASME Class 1, 2, 3 and MC (Page there has ever been a component failure at PNPS due to any 3.5-71), and component and piping supports (Page 3.5-72).

of these conditions. Explain if there has ever been a Component failures at PNPS and in the nuclear industry have component failure in the nuclear industry due to any of these certainly occurred due to overload (typically caused by an event such conditions. Explain what PNPS inspects for during VT-3 as water hammer) or vibratory and cyclic thermal loads. Because of visual examinations of groups B1.1, B1.2 and B1.3 the low operating temperatures, failures due to cyclic thermal loads components under its Inservice Inspection Program during are extremely rare for structural commodities. Failures due to its current license and also anticipated VT-3 visual distortion or vibratory loads have also occurred due to inadequate examinations during its possible extended license. design, but rarely if ever, due to the normal effects of aging. PNPS inspections during VT-3 visual examinations of groups B1.1, B1.2 and B1.3 components are consistent with what is required by code.

For clarification, LRA Table 3.5.1, Item 3.5.1-54 will be revised to state: "Loss of mechanical function due to distortion, dirt, overload, fatigue due to vibratory, and cyclic thermal loads Is not an aging effect requiring management. Such failures typically result from inadequate design or events rather than the effects of aging. Loss of material due to corrosion, which could cause loss of mechanical function, is addressed under Item 3.5.1-53 for Groups 81.1, B1.2, and B1.3 support members."

This requires an amendment to the LRA.

424 Accepted Table 3.3.2-4, Emergency Diesel Generator System, for PNPS included the expansion joint with the exhaust piping in Patel, Erach Finnin, Ron carbon steel expansion joints in an internal environment of Section 4.3.2 of the LRA. PNPS documentation does not Identify exhaust gases credits the TLAA - fatigue for managing any design code for the expansion joint separate from the exhaust cracking due to fatigue. TLAA section 4.3.2, Non-Class 1 piping (831.1). Partial cycles are not a concern for the diesel Fatigue, assumes, in general 7000 thermal cycles for piping exhaust system since the exhaust temperature is assumed to reach systems, allowing a stress reduction factor of 1.0 in the normal operating temperature with each start of the engine. The stress analysis. This is a good assumption for pipe, fittings, expansion joint is exposed only to the same number of full cycles to etc., however, may not be a good assumption for expansion which the rest of the piping is exposed. The expansion joint Is joints. designed specifically to accommodate movement that could result from the heating and cooling of the exhaust piping; In other words, Please confirm if the expansion joints are included in its design intent is to have better fatigue response than the rest of section 4.3.2, and justify that the assumption of 7000 cycles the piping. Therefore, PNPS assumed the piping would be more is appropriate. limiting than the expansion joint for the allowable number of cycles prior to requiring management of cracking due to fatigue.

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Number Status Request Response NRC PNPS Lead 425 Open - As part of the Thermal Power Optimization Project, GE a) The Pilgrim records system had not been updated to include the Patel, Erach Finnin, Ron NRC performed another fatigue analysis. GE issued a report, changes in CUF due to the 2003 TPO program in time to support GE-NE-0000-0000-1 892-02, Rev. 0, March 2002, Thermal LRA preparation. TPO has a small impact on CUF as detailed in Power Optimization, Task-302 - RPV - Stress Evaluation. GE-NE-0000-000-1898-02, Rev. 1, 312002. The records system has This report calculated new CUFs, which in some cases are been updated and the PNPS corrective action program requires that different than what is shown in the LRA, Table 4.3-1, the information be assessed for potential impact on other LRA Maximum CUFs for Class 1 Components. The GE Report, sections. PNPS will update LRA table 4.3-1 to include the values Section 3.3, Results, states that feedwater nozzle CUF from the TPO.

recalculation indicate a CUF that went from <0.8 to <1.0.

Similarly, Table 3.3.1.3 fatigue summary, last column, In preparing the TPO stress evaluation, GE reviewed only those RPV indicates CLTP/TLTP values. Again, specific values are components whose pressure, temperature, and flow conditions provided for 3 line items, however, for feedwater nozzle, only were more severe due to the TPO and with fatigue usage factors

<1.0 is specified. greater than 0.5. These CUFs were not recalculated by traditional methods, but rather were estimated by conservatively scaling the Please justify what <1.0 means. Please provide a specific stresses, determining the code allowable number of cycles for those calculated value. Also, please justify why the revised TPOP stresses, then determining the incremental usage factor for a group CUF values were not identified in the LRA Table 4.3-1, of cycles considered in the original stress report. Before the TPO, instead of old values calculated by ALTRAN Corporation in the CUF for the feedwater nozzle (Altran Report) was listed as <0.8, 1994. for the TPO this CUF increased to <1.0. No precise value was calculated. As stated in the response to Question 345, PNPS will Are there other LRA TLAA sections affected by the TPO perform a new feedwater nozzle fatigue analysis prior to the period of project, such as Section 4.2, RPV Neutron Embrittlement extended operation.

Analysis.

b) No other sections of the LRA are affected by the TPO. The fluence values used in Section 4.2 were based on the higher power level.

426 Accepted [T.3.3.2-P-09] TLAA-metal fatigue is not an aging management program. Under the Patel, Erach Fronabarger, standard LIRA format, TLAA-metal fatigue is inserted under the Table 3.3.2-4, EDG System, page 3-78, for carbon steel aging management program as a convenience to indicate that a expansion joints, in an internal environment of exhaust gas TLAA for metal fatigue applies to that line item. The carbon steel credits TLAA-fatigue to manage the aging effect of cracking expansion joints are designed per the requirements of ASME B31.1 due to fatigue. for a limited number of thermal cycles. The evaluation of fatigue for ASME B31.1 components is discussed in Section 4.3.2. The Please confirm if TLAA Section 4.3.2, Non-Class 1 Fatigue, evaluation determined that the EDG components will remain below includes these expansion joints. Also, see TLAA question 8. the cycle limit for 60 years such that cracking is not expected.

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Number Status Request Response NRC PNPS Lead 427 Closed [T.3.3.2-P-10] TLAA-metal fatigue is not an aging management program. Under the Patel, Erach Lloyd, Leland standard LRA format, TLAA-metal fatigue is inserted under the For aging effect of cracking due to fatigue, PNPS has aging management program as a convenience to indicate that a credited TLAA - metal fatigue as an aging management TLAA for metal fatigue applies to that line item. The EDG exhaust program for components in an internal environment of systems are designed per the requirements of ASME B31.1 for a exhaust gas in Table 3.3.2-4, EDG Systems; however in limited number of thermal cycles. The evaluation of fatigue for Table 3.3.2-5, SBDG System and Table 3.3.2-6, SDG ASME B31.1 components is discussed in Section 4.3.2. The System, the Periodic Surveillance and Preventive evaluation determined that the EDG components will remain below Maintenance (PSPM) Program is credited, which includes the cycle limit for 60 years such that cracking is not expected. The visual or other NDE techniques to inspect exhaust system exhaust systems for the station blackout diesel generator and components to manage cracking. security diesel generator are not designed to a code or standard where thermal cycles are a consideration. Therefore, the Periodic Please justify why the PSPM program is not credited for the Surveillance and Preventive Maintenance (PSPM) program will EDG system components for managing aging effect of manage or confirm the absence of cracking due to thermal fatigue.

cracking. It is only credited for loss of material and fouling.

428 Closed [T.3.3.2-P-1 1] The aging effect of fatigue cracking Is conservatively identified for Patel, Erach Fronabarger, the fire pump diesel engine. Ifthe exhaust components were Table 3.3.2-9, Fire Protection - Water System, for piping, designed per ASME B31.1 code, a limited number of cycles would silencer and turbocharger in an internal exhaust gas be the threshold for susceptibility to cracking due to fatigue. Since environment with an aging effect of cracking due to fatigue, the system is normally in standby and used primarily during testing, PNPS has credited the Fire Protection Program to manage it is unlikely to reach any legitimate threshold to produce fatigue this aging effect. The program element 6, Acceptance cracking. Furthermore, through monitoring and trending of Criteria, is enhanced to verify that the diesel engine did not performance data under the Fire Protection Program, cracking of exhibit signs of degradation while it was running; such as system components will be identified and corrected through the exhaust gas leakage. corrective action program. As described in section B.1.13.1, observation of degraded performance produced corrective actions Please justify how the aging effect of cracking is managed including engine replacement in 2002 prior to loss of intended by verifying for exhaust gas leakage. Ifthere is leakage, it function. Consequently, continued implementation of the Fire implies a through-wall crack has occurred. Verifying for Protection Program provides reasonable assurance aging effects leakage is not an adequate aging management program for will be managed for the diesel fire pump exhaust subsystem. In managing cracking. addition, PNPS performs fire pump inspection, testing and maintenance in accordance with NFPA 25 which would also detect the presence of cracking inthe exhaust system prior to loss of intended function.

This item is closed to item 378.

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Number Status Request Response NRC PNPS Lead 429 Closed [T3.3.2-P-12] The program description listed in Section 8.1.13.1 matches the Patel, Erach Fronabarger, description cited in GALL section XI.M26, Fire Protection which In LRA Section 3.3.2.2.7.3, PNPS states that the carbon includes the diesel driven fire pump. The exhaust piping and steel diesel exhaust piping and components in the fire components are part of the fire pump. Enhancements for aging protection system is managed by the Fire Protection management of the exhaust subsystem are described for attributes Program. The Fire Protection Program uses visual 3-parameters monitored/inspected and 6-acceptance criteria of the inspections of diesel exhaust piping and components to program.

manage loss of material.

This item is closed to item 378.

IfFire Protection Program (LRA B.1.1 3.1) iscredited for managing aging of these components, please explain why these system components are not included in the program description of the Fire Protection Program. Furthermore, no enhancement is addressed that would include these components in the Fire Protection Program.

430 Closed [T.3.3.2-P-13] See the response to Item 394 that addresses items in Table 3.3.2-9. Patel, Erach Fronabarger, For the piping component line item In Table 3.3.2-10 that has Subsequent to question T.3.3.2.1, the applicant has credited indoor air (int) as an environment the Fire Protection Program Fire Protection Program in lieu of GALL AMP XI.M38, includes a visual inspection of the external surfaces of the Halon Inspection of Internal Surfaces of Miscellaneous Piping and system piping and tanks. Since external surfaces are representative Ducting Components as recommended for GALL item of internal surfaces that are exposed to the same environment, the V.D2-16, which is referenced by the applicant for these line Fire Protection Program is adequate for managing the aging effects items. The GALL AMP XI.M38 states that visual inspection of components exposed to indoor air.

of internal surfaces of plant components is performed during maintenance or surveillance activities for visible evidence of This item is closed to item 378.

corrosion to indicate possible loss of material.

Since PNPS is using the Fire Protection Program in lieu of GALL AMP XI.M38, please explain how the Fire Protection Program performs this visual inspection. As written in the LRA, the Fire Protection Program is not adequate to manage loss of material for these components.

431 Closed [T3.2.2-P-01] NUREG-1 801 does not specify X.M1, Metal Fatigue of Reactor Pavinich, Wayne Lingenfelter, Coolant Pressure Boundary in the AMP column for items identifying Table 3.2.2, question 1 cumulative fatigue damage. NUREG-1801 identifies fatigue as a TLAA and refers to guidance in SRP Section 4.3 which in turn The PNPS B.1.12 Fatigue Monitoring is credited for describes treatment of fatigue in a variety of ways depending on the managing the aging effect "Cracking fatigue" for components component. Since NUREG-1 801 does not credit the Fatigue in the RHR (Table Number 3.2.2- 1), ADS (Table Number Monitoring Program, exceptions in this program have no bearing on 3.2.2- 3), HPIC (Table Number 3.2.2 4). RCIC (Table Number the selection of notes.

3.2.2 5) systems. In most cases the components have been assigned Note "A" or Note "C". However, the PNPS B.1.12 Fatigue Monitoring program has exceptions to the GALL program, X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary. Therefore, Note "C" should be Note "D"and Note "A" should be Note "B" as appropriate for these components.

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