ML050980244
| ML050980244 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/08/2005 |
| From: | Mitra S NRC/NRR/DRIP/RLEP |
| To: | Gannon C Carolina Power & Light Co |
| Mitra, SK, NRR/DRIP/RLEP, 415-2783 | |
| References | |
| TAC MC4639, TAC MC4640 | |
| Download: ML050980244 (41) | |
Text
April 8, 2005 Mr. Cornelius J. Gannon Vice President Carolina Power & Light, Company P.O. Box 10429 Southport, NC 28461-0429
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC4639 AND MC4640)
Dear Mr. Gannon:
By letter dated October 18, 2004, Carolina Power & Light, Company, (CP&L or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Brunswick Steam Electric Plant (BSEP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
These RAIs were discussed with your staff, Mike Heath, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2783 or e-mail SKM1@nrc.gov.
Sincerely,
/RA/
Sikhindra K. Mitra, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-325 and 50-324
Enclosure:
As stated cc w/encls: See next page
April 8, 2005 Mr. Cornelius J. Gannon Vice President Carolina Power & Light, Company P.O. Box 10429 Southport, NC 28461-0429
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC4639 AND MC4640)
Dear Mr. Gannon:
By letter dated October 18, 2004, Carolina Power & Light, Company, (CP&L or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Brunswick Steam Electric Plant (BSEP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
These RAIs were discussed with your staff, Mike Heath, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2783 or e-mail SKM1@nrc.gov.
Sincerely,
/RA/
Sikhindra K. Mitra, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-325 and 50-324
Enclosure:
As stated cc w/encls: See next page DISTRIBUTION: See next page Adams Accession no.: ML050980244 Document Name: E:\Filenet\ML050980244.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP SC.DSSA/SPLB NAME SMitra MJenkins SLee SJones DATE 04/ 01 /05 03/ 31 /05 04/ 08 /05 04/ 01 /05 OFFICIAL RECORD COPY Brunswick Steam Electric Plant, Units 1 and 2
cc:
Mr. Steven R. Carr Executive Director Associate General Counsel - Legal Public Staff - NCUC Department 4326 Mail Service Center Progress Energy Service Company, LLC Raleigh, North Carolina 27699-4326 Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. T. P. Cleary Director - Site Operations Mr. David R. Sandifer, Chairperson Brunswick Steam Electric Plant Brunswick County Board of Commissioners Progress Energy Carolinas, Inc.
Post Office Box 249 Post Office Box 10429 Bolivia, North Carolina 28422 Southport, North Carolina 28461-0429 Resident Inspector Mr. Norman R. Holden, Mayor U. S. Nuclear Regulatory Commission City of Southport 8470 River Road 201 East Moore Street Southport, North Carolina 28461 Southport, North Carolina 28461 Mr. John H. ONeill, Jr. Mr. Warren Lee Shaw, Pittman, Potts & Trowbridge Emergency Management Director 2300 N Street NW New Hanover County Department of Washington, DC 20037-1128 Emergency Management Post Office Box 1525 Ms. Beverly Hall, Section Chief Wilmington, North Carolina 28402-1525 Radiation Protection Section, Division of Natural Resources Mr. Chris L. Burton, Manager N.C. Department of Environment Performance Evaluation and and Natural Resources Regulatory Affairs PEB 7 3825 Barrett Dr. Progress Energy Raleigh, North Carolina 27609-7721 Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. David H. Hinds Plant General Manager Mr. Edward T. ONeill Brunswick Steam Electric Plant Manager - Support Services Carolina Power & Light Company Brunswick Steam Electric Plant Post Office Box 10429 Carolina Power & Light Company Southport, North Carolina 28461-0429 Post Office Box 10429 Southport, North Carolina 28461 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 Mr. Robert P. Gruber
Brunswick Steam Electric Plant, Units 1 and 2 cc:
Allen K. Brittain Mr. Cornelius J. Gannon, Vice President Superintendent, Security Brunswick Steam Electric Plant Brunswick Steam Electric Plant Carolina Power & Light Company Progress Energy Carolinas, Inc. Post Office Box 10429 P.O. Box 10429 Southport, North Carolina 28461-0429 Southport, North Carolina 28461-0429 Mr. Michael Heath Brunswick Steam Electric Plant P.O. Box 10429 Southport, North Carolina 28461-0429 Talmage B. Clements Manager - License Renewal Progress Energy P. O. Box 1551 Raleigh, North Carolina 27602 Mr. Fred Emerson Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Ms. Ilene Brown NCUW William Randall Library 601 S. College Rd.
Wilmington, North Carolina 28403-5616
DISTRIBUTION: Letter to C. Gannon, Re: RAI for review of the Brunswick Steam Electric Plant, Dated: April 8, 2005 Adams Accession No.: ML050980244 HARD COPY RLEP RF E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li K. Winsberg (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff B. Mozafari C. Julian, RII B. Rogers T. Ford J. Golla A. Lee R. Dipert J. Medoff M. Hartzman T. Cheng
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION (LRA)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
RAI 2.1-1 During the Brunswick scoping and screening methodology audit, the staff determined that the applicant had performed component based scoping and had included SCs within the scope of license renewal based upon the SCs classification within the Equipment Data Base relative to the criteria of 10 CFR 54.4 (a)(1), (2), or (3). The applicant had then included all systems within the scope of license renewal which contained any SCs which had been determined to be in-scope based on the SCs classification within the Equipment Data Base. The applicant indicated that the in-scope system CLB documentation, including the system intended functions, had been reviewed to verify that all in-scope SCs had been identified.
The staff reviewed the information contained in the LRA, discussed the process with the applicant and reviewed the applicable process implementation guidance. The staff determined that the process by which the current licensing basis information, including system intended functions, had been reviewed and considered during the scoping process was not clearly documented in the LRA. As a result, the staff request that the applicant document how the current licensing basis information, including system intended functions, was considered during the scoping process.
RAI 2.1-2 Based on a review of the LRA, the applicants scoping and screening implementation procedures, calculations, and discussions with the applicant, the staff determined that additional information is required with respect to certain aspects of the applicants evaluation of the 10 CFR 54.4(a)(2) criteria.
Section 2.1.1.2, Non-Safety Related Criteria Pursuant to 10 CFR 54.4(a)(2), of the LRA, and several of the applicants calculations prepared to address the (a)(2) issue, state that nonsafety-related piping that is attached to safety-related piping, and that is seismically designed and supported up to the first seismic anchor (emphasis added) past the safety-related/non-safety related interface, should be included within the scope of license renewal.
The LRA also states that the analysis of seismic induced effects was continued well into (emphasis added) the non-safety related piping in order to include the effects that non-safety related piping has on the adjoining safety related piping.
Based on the above, the staff requests that the applicant confirm that the first seismic anchor occurs at the point where non-safety related piping is restrained in three directions, or if not practical, supported in three directions by three individual supports. Confirm that this approach is consistent with the CLB position for seismic-induced effects between connected non-safety related and safety-related piping documented in Amendment 15 of the BSEP FSAR; and describe the methodology of its application.
Enclosure
2.3.1 Reactor Vessel, Internals, and Reactor Coolant System RAI 2.3.1.1-1 In FSAR Section 3.9.5.1.1 it states, the core shroud is reinforced at the upper shroud/top fuel guide support ring/middle shroud interface with twelve (12) brackets located at 30 degree intervals starting at the 15 degree azimuth. These brackets provide structural integrity across the interface and compensate for cracking in the heat affected zones of the original fabrication welds. Please indicate whether the top fuel guide support ring and middle shroud interface brackets have been included in scope of license renewal or justify the exclusion of these components.
RAI 2.3.1.1-2 In FSAR Section 3.9.5.1.3 it states, a thermal sleeve is inserted into the control rod drive housing (CRDH) from below and is rotated to lock the control rod guide tube in place. A key is inserted into a locking slot in the bottom of the CRDH to hold the thermal sleeve in position.
Please indicate whether the CRDH thermal sleeve is included in scope of license renewal or justify its exclusion.
RAI 2.3.1.1-3 Please indicate whether thermal sleeves for recirculation inlet nozzles are considered part of reactor vessel nozzles, nozzles safe ends and/or instrumentation penetrations requiring an aging management review (AMR). The subject components represent a pressure boundary and direct flow to core spray spargers and jet pumps.
RAI 2.3.1.1-4 The differential pressure and liquid control line serves a dual function within the reactor vessel:
(1) to inject liquid control solution into the coolant stream and (2) to sense the differential pressure across the core support assembly. Please indicated whether the subject component is considered part of reactor vessel nozzles, nozzles safe ends and/or instrumentation penetrations requiring an AMR.
RAI 2.3.1.1-5 The two 100 percent capacity core spray lines separately enter the reactor vessel through the two core spray nozzles. Each line divides immediately inside the reactor vessel. The two halves are routed to opposite sides of the reactor vessel and are supported by clamps attached to the vessel wall. The header halves are then routed downward into the downcomer annulus and pass through the upper shroud immediately below the flange. The flow divides again as it enters the center of the semi-circular sparger ring which is routed halfway around the inside of the upper shroud. The ends of the two sparger rings for each line are supported by slip-fit brackets designed to accommodate thermal expansion of the rings. The header routing and supports are designed to accommodate differential movement between the shroud and the vessel. Please indicate whether the core spray clamps which are attached to the vessel wall and the slip-fit brackets which support the ends of the two sparger rings are included in scope of license renewal requiring an AMR or justify their exclusion.
RAI 2.3.1.1-6 The staff position on reactor vessel flange leak-off lines is that unless a plant specific justification is provided, the components should be in scope requiring aging management.
Please confirm whether any of the component types listed in LRA Table 2.3.1-1, Reactor Vessel and Internals, include the subject component. If not, then the subject components should be identified as within scope requiring aging management or provide a plant-specific justification for the exclusion.
RAI 2.3.1.1-7 At BSEP the steam separators are attached to the top of stand pipes which are welded into the shroud head. Please indicate whether the subject component is included in LRA Table 2.3.1-1 component group Reactor Vessel Internals (Boiling Water Reactor - Non-Safety Related)
(Shroud Head and Separators).
2.3.2 Engineered Safety Features Systems 2.3.2.1 Residual Heat Removal (RHR) System RAI 2.3.2.1-1 The low pressure coolant injection (LPCI) coupling was identified in the BWRVIP-06 report as a safety-related component. It appears, however, that the component was not identified in the LRA requiring an AMR. Please indicate whether the subject component is in scope of license renewal requiring an AMR or justify its exclusion from aging management.
2.3.3 Balance of Plant Systems RAI 2.3.3.1-1 BSEP UFSAR Section 5.4.8.2 states that the RWCU System provides for continuous purification of the reactor water. Reactor coolant is removed from the Reactor Recirculation System, cooled in the regenerative and non-regenerative heat exchangers, and processed through filter/demineralizer units. The processed water is routed through the shell side of the regenerative heat exchanger and returned to the reactor vessel via the feedwater line. BSEP LRA Section 2.3.3.1, states that portions of the RWCU system support the integrity of the RCPB. LRA Table 2.3.3-1 identifies the license renewal intended function for the Regenerative Heat Exchanger (RHX) shell(s) and access cover(s) as only M-4 Provide structural support/seismic integrity and does not identify M-1 Provide pressure-retaining boundary.
This is in contrast to all other RWCU components listed in LRA Table 2.3.3-1. Please provide additional information describing the basis for the RHX shell and access cover intended function in Table 2.3.3-1.
RAI 2.3.3.1-2 BSEP UFSAR Section 5.4.8.2 states that the RWCU System provides for continuous purification of the reactor water. Reactor coolant is removed from the Reactor Recirculation System, cooled in the regenerative and non-regenerative heat exchangers, and processed through filter/demineralizer units. The processed water is routed through the shell side of the regenerative heat exchanger and returned to the reactor vessel via the feed water line. BSEP LRA Section 2.3.3.1, states that portions of the RWCU system support the integrity of the RCPB. License renewal boundary drawing D-25027-LR Sheet 1A at Quadrant E-4 and drawing D-02527-LR Sheet 1B at Quadrant D-3 show Unit 1 regenerative heat exchanger (RHX) shell 1C and Unit 2 RHX shell 2C as in-scope for license renewal. However, the remaining Unit 1 and Unit 2 RHX shells 1A, 1B, 2A, and 2B and their associated piping are shown as not in-scope for license renewal. In addition, there are several piping sections between the RHX shells and a normally closed isolation valve that are also shown as not in-scope. Please provide additional information to support your determination that these components and associated piping are not in-scope for license renewal relative to the components intended function defined in LRA Section 2.3.3-1.
RAI 2.3.3.1-3 BSEP UFSAR Section 6.2.3 states that the safety objective of the secondary containment is to limit the release of radioactivity to the environs after a design basis accident (e.g., LOCA, refueling accident) so that the resulting exposures are kept to a practical minimum and are within 10 CFR 100 values. The in-scope portion of lines 36-3-153 and 51-3-153 are shown on license renewal boundary drawing D-25027-LR, Sheet 1A Quadrants B-8 and C-8 for Unit 1 and on license renewal boundary drawing D-02527-LR, Sheet 1A Quadrants B-8 and C-8 for Unit 2.
Each line penetrates secondary containment (reactor building). It is not clear why portions of these lines between the inside of the reactor building and valves F035, F034 and F036 are not shown as in-scope for license renewal. Please provide additional information justifying why these are not in-scope for license renewal and why the scope does not include the remaining non-isolable piping between the inside wall of the secondary containment and the adjacent piping to the valves F034, F035 and F036.
RAI 2.3.3.1-4 BSEP LRA Unit 1 license renewal boundary drawing D-25027-LR Sheet 1B at Quadrant D6 and Unit 2 license renewal boundary drawing D-02527-LR Sheet 1B at Quadrant D6 shows that the in-scope portion of line 49-6-907 terminate in the middle of Line 65-6-907. Since the in-scope portion of 49-6-907 also includes two 3/4 -inch capped vent connections, it is not clear why the non-isolable portions connecting piping would not also be in-scope. Please clarify the reason for terminating the scope at line 65-6-907 and not including non-isolable portions connecting piping.
RAI 2.3.3.3-1 The BSEP USFAR, Section 9.3.2.1.3, states that the Operational Sampling System including the Reactor Building Sampling (RXS) system is not required either for safe shutdown or following an accident and is therefore not classed as an essential system. However, it does interface with safety systems, and thus, the sample lines from nuclear safety systems or from engineered safeguard systems are provided with solenoid operated isolation valves operated remotely from local instruments or from the control room panel. The BSEP LRA Section 2.3.3.3 states the RXS system monitors the plant and equipment performance to determine routine chemical properties and radiation levels necessary to provide information for equipment operation, corrosion control, and radiation activity. The system also provides information for making operational decisions with regard to effectiveness, safety, and proper performance.
Portions of the RXS system provide a pressure retaining boundary intended function for license renewal purposes.
C The pressure relief valves PRV-207, PRV-208, PRV-209 and PRV-210 and their associated piping on Unit 1 drawing D-70070-LR Sheet 1 at Locations D-7, D-5, D-2 and D-1 are not shown as being included in scope for license renewal. However, the same pressure relief valves and associated piping shown on the Unit 2 drawing D-07070-LR Sheet 1 at the same Locations are shown as included in scope for license renewal.
C The piping and isolation valves V132, V133, V134, V135, V136, and V137 on Unit 1 drawing D-70070-LR Sheet 1 at Locations D-4 through D-6 are not shown as being included in scope for license renewal. However, the same piping and isolation valves on the Unit 2 drawing D-07070-LR Sheet 1 at the same Locations are shown as included in scope for license renewal.
C The piping for pressure indicators PI-5220 (for both Unit 1 and 2), PI-5221, PI-5222 and PI-R007A shown on Unit 1 drawing D-70070-LR Sheet 1 at Locations D-5 through D-7 are not shown as being included in scope for license renewal. However, the same piping for similar pressure indicators on the Unit 2 drawing D-07070-LR Sheet 1 at the same Locations are shown as included in scope for license renewal.
Failure of the above listed valves and associated piping that are not shown as being in scope for license renewal could prevent the RXS system from performing its intended function.
Provide additional clarification and justification as to whether the above listed valves and associated piping should be or should not be included in scope for license renewal.
RAI-2.3.3.4-1 BSEP UFSAR Section 9.3.2.2 states that the purpose of the Post Accident Sampling System is to provide the capability of obtaining liquid and gas samples from the primary coolant system, primary containment, and the suppression chamber following an accident. LRA Section 2.3.3.4 states that the portions of PASS within the scope of License Renewal consist of components that are safety-related and are relied upon to remain functional during and following design basis events, components which are non-safety related whose failure could prevent satisfactory accomplishment of the safety related functions, and components that are part of the Environmental Qualification Program. LRA Table 3.3.2-4 identifies the aging management intended function PASS in-scope piping and fittings component type is -1 Provide pressure retaining boundary and/or - 4 Provide structural support/seismic integrity. The in-scope license renewal boundaries identified at quadrant E-5 and E-6 on Sheet 1 license renewal boundary drawings D-73027-LR and D-07327-LR terminate in the middle of a pipe run. Please provide additional information and discuss the basis for terminating the in-scope portion of this piping downstream of solenoid valves SV-4180, SV-4181, SV-4184, and SV-4185 in the middle of the piping runs.
RAI 2.3.3.6-1 In LRA Section 2.3.3.6, Screen Wash Water (SCW) System, it states that the SCW system consists of twelve traveling screens. The four traveling screens associated with the service water system were determined in scope, but the screens are active components, not subject to an AMR. The application has not address the other eight traveling screens.
- a. The systems/components having intended functions as identified in 10 CFR 54.4(a) are within the scope of license renewal. Are the other eight traveling screens in scope or not? If not, please identify where these eight traveling screens are located and explain the intended functions of the system.
- b. Based on the NRC review guidance in SRP-LR Table 2.1-5 and industry guidance, Appendix B to NEI 95-10, Revision 3, for passive/active determination, the screen is not included as an active component in general. Justify the screen being an active component for Brunswick, or add screens to LRA Table 2.3.3-5 as component requiring an AMR.
- c. Identify all the systems that have screens and were excluded from an AMR based on screens being active.
RAI 2.3.3.7-1 The BSEP UFSAR states that the Service Water System is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02041-LR, Sheet 1, Location F-2, has strainer 2-SW-ST-3 within the scope of license renewal; however, strainer 2-SW-ST-2 is not within the scope of license renewal. The BSEP LRA Table 2.3.3.6 states that basket strainers and CW strainers are in scope. Failure of this strainer could have an effect on the Intended Function to provide a pressure retaining boundary. Explain why strainer 2-SW-ST-2 is not within the scope of license renewal.
RAI 2.3.3.7-2a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02041-LR, Sheet 1, Location F-1, has a LRA flag in the middle of a section of pipe which is continued on D-2041-3. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary.
Explain why the LRA boundary occurs in the middle of this section of pipe.
RAI 2.3.3.7-2b The BSEP UFSAR states that the Service Water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Drawing D-20041-LR, Sheet 1, Location F-8 has an LRA flag in the middle of a section of pipe which is continued on D-20041, Sheet 3. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary.
Explain why the LRA boundary occurs in the middle of this section of pipe.
RAI 2.3.3.7-3a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02041-LR, Sheet 1, Locations A-8, A-6 and A-3, depict three lines each from the conventional header service water pumps with continuations on drawing F-4024. Drawing F-4024 was not provided with the LRA. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary.
Provide additional information on where the LRA boundary is located for these sections of pipe.
RAI 2.3.3.7-3b The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-20041-LR, Sheet 1, Locations B-1, B-6 and B-3, depict three lines each from the conventional header service water pumps with continuations on drawing F-04024. Drawing F-04024 was not provided with the LRA. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary. Provide additional information on where the LRA boundary is located for these sections of pipe.
RAI 2.3.3.7-4a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02034-LR, Sheet 1, Locations F-2, and E-2, depict five (5) drains which include valves 2-SW-V444, V95, 2-SW-663, 2-SW-669 and 2-SW-664 that are not within the scope of license renewal. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of these sections of pipe and valves could have an effect on the Intended Function to provide a pressure retaining boundary.
Explain why these sections of pipe and valves are not within the scope of license renewal.
RAI 2.3.3.7-4b The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-20034-LR, Sheet 2, Locations F-7, and D-8, depict five (5) drains which include valves 1-SW-V444, V95, 2-SW-663, 2-SW-669 and 2-SW-664 that are not within the scope of license renewal. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of these sections of pipe and valves could have an effect on the Intended Function to provide a pressure retaining boundary.
Explain why these sections of pipe and valves are not within the scope of license renewal.
RAI 2.3.3.7-5a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02034-LR, Sheet 1, Locations E-2, and E-1, depict two (2) manholes that are not within the scope of license renewal. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of these manholes could have an effect on the service water Intended Functions. Explain why these manholes are not within the scope of license renewal.
RAI 2.3.3.7-5b The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-20034-LR, Sheet 2, Locations D-8, and E-7, depict two (2) manholes that appear to be within the scope of license renewal. Please clarify if these manholes are within the scope of license renewal and if not, explain why these manholes are not within the scope of license renewal. Similar manholes for Unit 2 (shown on D-02034-LR, Sheet 1, Locations E-2, and E-1) are not within the scope of license renewal.
RAI 2.3.3.7-6a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02034-LR, Sheet 1, Location E-2, depict three (3) sections of pipe which include valves 2-SW-V443 (2-SW-296-30-R-1) and 2-SW-299 (2-SW-266-1-R-2) and pipe line number (2-SW-22-30-R-1) that are not within the scope of license renewal. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of these sections of pipe and valves could have an effect on the Intended Function to provide a pressure retaining boundary. Explain why these sections of pipe and valves are not within the scope of license renewal.
RAI 2.3.3.7-6b The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-20034-LR, Sheet 2, Location E-7, depict three (3) sections of pipe which include valves 2-SW-V443 (1-SW-296-30-R-1) and 1-SW-299 (1-SW-228-1-R-2) and pipe line number (1-SW-22-30-R-1) that are not within the scope of license renewal. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of these sections of pipe and valves could have an effect on the Intended Function to provide a pressure retaining boundary. Explain why these sections of pipe and valves are not within the scope of license renewal.
RAI 2.3.3.7-7a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02041-LR, Sheet 2, Locations B-3 and B-6 depict three lines each from the nuclear header service water pumps. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary.
Provide additional information as to where the LRA boundary is located for these sections of pipe.
RAI 2.3.3.7-7b The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-20041-LR, Sheet 2, Locations B-3 and B-6 depict three lines each from the nuclear header service water pumps with continuations on drawing F-40024. Drawing F-40024 was not provided with the LRA. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary. Provide additional information as to where the LRA boundary is located for these sections of pipe.
RAI 2.3.3.7-8a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02041-LR, Sheet 2, Location F-7 has a LRA flag in the middle of a section of pipe which is continued on D-2041-3 and D-2034. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary. Explain why the LRA boundary occurs in the middle of this section of pipe.
RAI 2.3.3.7-8b The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-20041-LR, Sheet 2, Location F-2 has a LRA flag in the middle of a section of pipe which is continued on D-20034 and D-20041-3. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary. Explain why the LRA boundary occurs in the middle of this section of pipe.
RAI 2.3.3.7-9a The BSEP UFSAR states that the service water system is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-02537-LR, Sheet 2, Location B-2 has a LRA flag in the middle of a section of pipe which is continued on D-2544. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary. Explain why the LRA boundary occurs in the middle of this section of pipe.
RAI 2.3.3.7-9b The BSEP UFSAR states that the Service Water (SW) System is designed to meet the service water flow requirements for normal operation (including normal operation, outage/shutdown operation, hurricane operation, and flood operation) and for operation during and subsequent to postulated design basis accident conditions. Drawing D-25037-LR, Sheet 2, Location B-2 has a LRA flag in the middle of a section of pipe which is continued on D-25043 Sheet 1B. The BSEP LRA Table 2.3.3.6 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function to provide a pressure retaining boundary.
Explain why the LRA boundary occurs in the middle of this section of pipe.
RAI 2.3.3.8-1 BSEP UFSAR Section 9.2.2.2 states that the RBCCW system pumps, heat exchangers, and equipment required for normal system heat removal are designed to Class II requirements.
Portions of the system, which penetrate primary containment, including the isolation valves, were designed to Class I requirements to meet containment integrity. BSEP LRA section 2.3.3.8 states that the RBCCW system removes heat from the reactor auxiliary systems and their related accessories during normal operation. LRA Section 2.3.3.8 also states that the system also provides an additional barrier between contaminated systems and the service water discharged to the environment. BSEP LRA Table 3.3.2-7 identifies the Piping (Pipe, Fittings, and Flanges) as being in-scope for license renewal to provide a pressure retaining boundary (M1) function. License Renewal boundary drawing D-25038-LR, Sheet 2 at quadrants C4 and D4 shows the LR boundary terminating in the middle of non-isolable portions of lines 1-RCC-6-6-154 and 1-RCC-54-2-154. License Renewal boundary drawing D-02538-LR, Sheet 2 at Quadrants C4 and D4 also indicates that the LR boundary terminates in the middle of non-isolable portions of lines 2-RCC-6-6-154 and 2-RCC-54-2-154. Please discuss the basis for terminating the in-scope portion of the piping at these Locations and provide additional information describing the as-built plant Locations that these scope boundaries represent.
RAI 2.3.3.8-2 BSEP LRA Section 2.3.8 states that the RBCCW System provides cooling for Cleanup Recirculation Pump Coolers. BSEP Unit 1 license renewal boundary drawing D-25038-LR, Sheet 2 at Quadrant E1 and E2 identifies a portion of the RBCCW supply piping to cleanup Recirculation Pump Cooler 1B (1-RCC-57-11/2 -154) and adjacent valve V304 as in-scope for license renewal. This is inconsistent with the RBCCW piping and valve combination for the remaining Unit 1 cleanup recirculation pump cooler 1A (1-RCC-56-11/2 -154 and V307) is shown as not in-scope for license renewal. Also, the equivalent RBCCW supply piping and valve combinations to the Unit 2 cleanup recirculation pump coolers 1A and 1B are shown as not in-scope for license renewal on BSEP boundary drawing D-02538-LR, Sheet 2 at Quadrants E1 and E2 and at Quadrants D1 and D2. Please discuss the basis for terminating the in-scope portion of the piping at these Locations and provide additional information describing the as built plant Locations that the in-scope boundaries represent.
RAI 2.3.3.10-1 Brunswick UFSAR Section 8.3.1.1.6 states that the Diesel Generator (DG) system has several auxiliary support systems that must function in order to perform its safety related functions including the diesel fuel oil system. There are two sections of piping associated with fuel oil transfer Pump 2A shown on drawing D-02268-LR Sheet 1B at Locations B-3 and B-4 that are shown as being out of scope for license renewal. This is not consistent with the fuel transfer Pump 1A shown on drawing D-02268-LR Sheet 1A at Locations B-3 and B-4 which shows the same piping sections as being in scope. Failure of the out of scope piping may affect the pressure boundary integrity of the fuel oil transfer system adversely impacting the system. A degraded fuel oil system could adversely impact the ability of the Diesel Engine No. 2 to perform its safety related function. Provide additional clarification or justification to support the determination that it is acceptable to not include these sections of piping as in scope for license renewal.
RAI 2.3.3.10-2 Brunswick UFSAR Section 8.3.1.1.6 states that the DG system has several auxiliary support systems that must function in order to perform its safety related functions including the diesel fuel oil system. There are several blind flanges and fittings for the diesel generator fuel oil storage tanks listed below that are not consistently treated as being either in scope or out of scope for license renewal.
C DG No. 1 fuel oil day tank the 2" blind flange on drawing D-02268-LR Sheet 1A at Location F-6 is shown as being out of scope.
C DG No. 1 four day storage tank the 6" blind flange, 24" Man Hole, and 2" blind flange on drawing D-02268-LR Sheet 1A at Locations C-4, and B-5 are shown as in scope.
C DG No. 1 fuel oil transfer Pump 1B on drawing D-02268-LR Sheet 1A at Location C-2 has a discharge pressure tap pipe plug down stream of PI-1242-6 that is shown as being out of scope. This is inconsistent with fuel oil transfer Pump 1A that has a similar pipe plug downstream of PI-1241-6 that is shown as in scope.
C DG No. 2 fuel oil day tank the 2" blind flange on drawing D-02268-LR Sheet 1B at Location F-6 is shown as being out of scope.
C DG No. 2 four day storage tank the 6" blind flange on drawing D-02268-LR Sheet 1B at Location C-4 is shown as out of scope.
C DG No. 3 fuel oil day tank the 2" blind flange on drawing D-02269-LR Sheet 2A at Location F-6 is shown as being out of scope.
C DG No. 3 four day storage tank the 6" blind flange, 24" Man Hole, and 2" blind flange on drawing D-02269-LR Sheet 2A at Locations C-4, and B-5 are shown as in scope.
C The diesel seven day storage tank shown on drawing D-02269-LR Sheet 2A at Location B-7 shows a man way, an instrument line flanged access, and a tank fill line that are shown as being out of scope.
C DG No. 4 fuel oil day tank the 2" blind flange, 2" blind flange and 6" blind flange on drawing D-02269-LR Sheet 2B at Location F-6, B-5 and C-4 are shown as being out of scope.
Failure of the blind flanges and fittings listed above that are shown as out of scope may affect the pressure boundary integrity of the fuel oil transfer system adversely impacting the system.
A degraded fuel oil system could adversely impact the ability of the Diesel Engines to perform their safety-related functions. Provide additional clarification or justification to support the determination that it is acceptable to not include the blind flanges and fittings listed above as in scope for license renewal.
RAI 2.3.3.10-3 Brunswick UFSAR Section 8.3.1.1.6 states that the DG System has several auxiliary support systems that must function in order to perform its safety related functions including the diesel lube oil system. There are several instrument lines, fittings and piping segments for the diesel generator lube oil systems listed below that are not consistently treated as being either in scope or out of scope for license renewal.
C DG No. 1 engine control panel pressure gage PI-6520 piping on drawing D-02270-LR Sheet 1A at Location F-7 is shown as out of scope. This is inconsistent with similar pressure gage piping for DG No. 2 on drawing D-02270-LR Sheet 1B at the same Location that is shown as in scope.
C DG No. 2 sensing line for TI-6542-2 on drawing D-02270-LR Sheet 1B at Location C-6 is shown as in scope. This is inconsistent with similar sensing lines for DG No. 1 on drawing D-02270-LR Sheet 1A at the same Location that is shown as out of scope. This same sensing line for DG No. 3, TI-6542-3, and DG No. 4, and TI-6542-4, are also shown as out of scope.
C DG No. 1 level switch LS-6562-1 piping on drawing D-02270-LR Sheet 1A at Location E-6 is shown as out of scope. This is inconsistent with similar level switch piping for DG No. 2 on drawing D-02270-LR Sheet 1B at the same Location that is shown as in scope.
C DG No. 2 pipe cap downstream of SS-6577-2-10 on Drawing D-02270-LR Sheet 1B at Location E-5 is shown as out of scope. This is inconsistent with similar pipe caps for DG No. 1 on drawing D-02270-LR Sheet 1A at the same Location that is shown as in scope. This same pipe cap is also shown as in scope for DG No. 3 and DG No. 4.
C For DG Nos. 1, 3 and 4 there is a three inch diameter piping segment on Drawings 0-02270-LR Sheet 1A at Location E-4, D-02271-LR Sheet 2A at Location B-4, and D-02271-LR Sheet 2B at Location B-4 shown as out of scope. This is inconsistent with DG No. 2 that shows the same three inch diameter piping segment at the same Location as in scope.
Failure of the instrument lines, fittings and piping segments listed above that are shown as out of scope may affect the pressure boundary integrity of the diesel lube oil system adversely impacting the system. A degraded diesel lube oil system could adversely impact the ability of the Diesel Engines to perform their safety related functions. Provide additional clarification or justification to support the determination that it is acceptable to not include the instrument lines, fittings and piping segments listed above as in scope for license renewal.
RAI 2.3.3.10-4 Brunswick UFSAR Section 8.3.1.1.6 states that the DG system has several auxiliary support systems that must function in order to perform its safety-related functions including the diesel service water system. The license renewal documentation shows inconsistencies in how the vent piping and pipe caps are shown for this system. For DG No. 1 there is a vent pipe and pipe caps on drawing D-02274-LR Sheet 1 at Location E-3 that are shown as out of scope.
There is also a pipe cap for DG no. 2 on drawing D-02274-LR Sheet 1 at Location E-6 that is shown as out of scope. The same vent piping and pipe caps for DG No. 3 and DG No. 4 on drawing D-02274-LR Sheet 2 at the same Locations are shown in scope. The piping and pipe caps are downstream of isolation valves, but it is not clear if all of the isolation valves are normally closed. If these isolation valves are not normally closed, failure of the piping and pipe caps could have an adverse impact on the diesel service water system. A degraded service water system could adversely impact the ability of the Diesel Engines to perform their safety-related function. Provide additional clarification or justification for not including these sections of piping and pipe caps as in scope for license renewal.
RAI 2.3.3.10-5 Brunswick UFSAR Section 8.3.1.1.6 states that the diesel generator (DG) system has several auxiliary support systems that must function in order to perform its safety related functions including the diesel exhaust and crankcase vacuum blower system. For all diesel generators the crankcase vacuum blower discharge lines shown on drawings D-02267-LR Sheets 1 and 2 at Locations C-3 and C-6 are not shown as in scope. The crankcase vacuum blower system ensures potentially dangerous crankcase vapors are exhausted to the atmosphere. It is not clear that the crankcase vacuum blower system could perform its intended function if the discharge lines are damaged, pinched off, fail or are otherwise restricted. Failure of the crankcase vacuum blower discharge lines may affect the pressure boundary integrity of the diesel generator crankcase vacuum blower system. A degraded crankcase vacuum blower system could adversely impact the ability of the Diesel Engines to perform their safety related functions. Provide additional clarification or justification to support the determination that it is acceptable to not include the crankcase vacuum blower discharge lines as in scope for license renewal.
RAI 2.3.3.12-1 The BSEP UFSAR states that the Non-Interruptible Instrument Air system is designed with the capability of supplying all instrument air requirements in the reactor building required for plant safety during normal operation. The Nitrogen Backup System provides an independent safety related pneumatic source to selected safety related loads in the event of either a LOCA or loss of pneumatic supply. The BSEP LRA Section 2.3.3.12 states that components in the IA system automatically actuate and monitor nitrogen backup supplies when required. Components in the IA system provide the primary containment isolation function following design basis events.
The IA receivers 1A, 1B, 2A, 2B are in scope and provide a pressure retaining boundary function, however, none of the air receiver discharge lines that allow the system to provide IA to components are identified as in scope on the following drawings:
C D-70029-LR,Sheet 2B at Location E-7 (line 221-2-170)
C D-72006-LR, Sheet 4 at Location B-1 (line 201-2-170, 206-2-170, 215-2-170, 220-2-170)
C D-07029-LR Sheet 2A at Location F-1 (line 201-2-170, 251-2-170, 203-2-170)
C D-07029-LR, Sheet 2B at Location E-7 (line 221-2-170)
Failure of the identified lines could prevent the IA system from performing its required safety functions. Provide additional information and justify your determination to exclude the identified lines from the scope of license renewal.
RAI 2.3.3.12-2 The BSEP USFAR states that the Non-Interruptible Instrument Air System is designed with the capability of supplying all instrument air requirements in the reactor building required for plant safety during normal operation. The Nitrogen Backup System provides an independent safety related pneumatic source to selected safety related loads in the event of either a LOCA or loss of pneumatic supply. The BSEP LRA Section 2.3.3.12 states that components in the IA system automatically actuate and monitor nitrogen backup supplies when required. Components in the IA system provide the primary containment isolation function following design basis events.
Drawings D-70077-LR, Sheet 3A and D-07077-LR, Sheet 3A both identify the Valve B32-F020 at Location B-1 as being in scope for license renewal. However, the lines connecting Valve B32-F020 to the IA header are not shown as being within scope. Failure of the piping could cause loss of function of Valve B32-F020. Provide additional information and justify your determination to exclude the piping that connects the IA header to Valve B32-F020.
RAI 2.3.3.14-1 The BSEP UFSAR states that the Pneumatic Nitrogen System is designed to supply drywell pneumatic requirements (including selected safety-related loads) during normal plant operation.
The BSEP LRA Section 2.3.3.14 states that piping and valves are in scope. Drawing D-02494-LR, Sheet 1, Location F-2, has a section of piping with a continuation to D-07077-3A, Location F-6 that is not within the scope of license renewal. Note that the continuation could not be found on D-07077-3A, Location F-6. Failure of this section of piping could have an effect on the Intended Function to provide structural support and seismic integrity. Provide additional justification as to why this section of pipe is not within the scope of license renewal.
RAI 2.3.3.14-2 The BSEP UFSAR states that the Pneumatic Nitrogen System is designed to supply drywell pneumatic requirements (including selected safety-related loads) during normal plant operation.
The BSEP LRA Section 2.3.3.14 states that piping and valves are in scope. Drawing D-02494-LR, Sheet 1, at Location F-3, depicts the piping, isolation and bypass valves to 2-PNS-FLT-100 to be within the scope of license renewal. A similar piping arrangement for 2-PNS-FLT-101 on drawing D-07077, Sheet 3B, at Location C-3 is shown out of scope. Provide additional information and justification as to why this section of piping, valves and filter for FLT-101 is not within the scope of license renewal.
RAI 2.3.3.14-3 The BSEP UFSAR states that the Pneumatic Nitrogen System is designed to supply drywell pneumatic requirements (including selected safety-related loads) during normal plant operation.
The BSEP LRA Section 2.3.3.14 states that piping and valves are in scope. Drawing D-07077-LR, Sheet 3A, Location C-6, shows a license renewal boundary designator [LR]
between Valves V255 and 2-PNS-V5004. Drawing D-02494-LR, Sheet 1, Location F-3, indicates the piping between V255 and V5004 as in-scope and piping and valves from PSL 5843A2, 2-PNS-V12, and 2-PNS-V8 to V255, including 2-PNS-V5004 are within the scope of license renewal. The piping between 2-PNS-V12, 2-PNS-V8, 2-PNS-V5004 is shown not shaded on D07077 Sheet 3A. A similar situation exists with drawing D-02494-LR, Sheet 1 and D-07077-LR, Sheet 3B from V256 through 2-PNS-V11 & 2-PNS-V7. Please explain these apparent license renewal boundary discrepancies between drawing D-02494-LR, Sheet 1 and drawing D-07077-LR, Sheet 3A & B and provide justification for why the piping between 2-PNS-V12, 2-PNS-V8, 2-PNS-V5004 is not shown as in scope on drawing D07077 sheet 3A.
RAI 2.3.3.15-1 UFSAR Section 9.5.1.4.1.4 discusses the water fire protection system, including the fixed manual suppression system hose stations with hose racks and hose reels. LRA Section 2.3.3.15 references drawing F-02315-LR, Sheet 1 for license renewal scoping boundaries for the Fire Protection system. Drawing F-02315-LR, Sheet 1 shows hose station/hose racks AOG-59 and AOG-60, and hose station/hose reels AOG-57, AOG-58, and AOG-61 in scope. Hose station/hose reel AOG-62 is shown out of scope. Please justify hose station/hose reel AOG-62 as out of scope.
Drawing F-02315-LR Unit 1 & 2 Charcoal Adsorber System Miscellaneous Services Piping & Instrumentation Diagram RAI 2.3.3.15-2 UFSAR Section 9.5.1.4.1.4 discusses the water fire protection system, including the fixed manual suppression system hose stations with hose racks and hose reels. In UFSAR Section 9.5.1.5, the specific fire hazards analysis for fire area MWT-1 Makeup Water Treatment states:
Manual fire fighting in the area should not be difficult. A hose line and portable fire extinguishers are available in the area to assist in manual fire fighting. LRA Section 2.3.3.15 references drawing D-02304-LR for license renewal scoping boundaries for the Fire Protection system. On drawing D-02304-LR, Hose station/hose reel 2-WT-HR-#1 is shown out of scope.
Please justify this hose station/hose reel as out of scope.
Drawing D-02304-LR Unit 1 & 2 Service Water Radwaste Water & Treatment Building Fire Protection Sprinkler System Piping Diagram RAI 2.3.3.15-3 UFSAR Section 9.5.1.4.1.4 discusses the water fire protection system, including the fixed automatic suppression system. In UFSAR Section 9.5.1.5, the specific fire hazards analysis for fire area MWT-1 Makeup Water Treatment states: Fire protection includes an automatic sprinkler system with heads located at the ceiling level. LRA Section 2.3.3.15 references drawing D-02304-LR for license renewal scoping boundaries for the Fire Protection system. On drawing D-02304-LR (B-8), Sprinkler Nozzle 764-I-J-2 is shown out of scope. Please justify this sprinkler nozzle as out of scope.
Drawing D-02304-LR Unit 1 & 2 Service Water Radwaste Water & Treatment Building Fire Protection Sprinkler System Piping Diagram RAI 2.3.3.15-4 UFSAR Section 9.5.1.4.1.4 discusses the water fire protection system, including the fixed manual suppression system foam-water hose stations located in the diesel generator building to provide backup suppression for the four-day tank rooms and the oil bath air filters. In UFSAR Section 9.5.1.5, the specific fire hazards analysis for fire areas DG-19 Fuel Oil Tank Cell 1, DG-20 Fuel Oil Tank Cell 2, DG-21 Fuel Oil Tank Cell 3, and DG-22 Fuel Oil Tank Cell 4 states:
Manual fire fighting could be difficult should a significant oil fire occur. Because the tanks are located below grade, access for fire fighting could be difficult. A foam standpipe is available from an adjacent area. LRA Section 2.3.3.15 references drawing D-02301-LR for license renewal scoping boundaries for the Fire Protection system. On drawing D-02301-LR, foam hose station/hose reel AFFF-HR1 is shown out of scope. Please justify this hose station/hose reel as out of scope.
Drawing D-02301-LR Unit 1 & 2 Diesel Generator Building Fire Protection Foam (AFFF) System Piping Diagram RAI 2.3.3.15-5 UFSAR Section 9.5.1.4.1.4 discusses the water fire protection system, including the fixed manual suppression system foam-water hose stations located in the diesel generator building to provide backup suppression for the four-day tank rooms and the oil bath air filters. In UFSAR Section 9.5.1.5, the specific fire hazards analysis for fire zone DG-16 Fan Room states: Manual fire fighting should not be difficult. Water standpipes and foam standpipes are provided to assist in manual fire fighting. LRA Section 2.3.3.15 references drawing D-02302-LR for license renewal scoping boundaries for the Fire Protection system. On drawing D-02302-LR, foam hose station/hose reels AFFF-HR2 and AFFF-HR-3 are shown out of scope. Please justify these hose station/hose reels as out of scope.
Drawing D-02302-LR Unit 1 & 2 Diesel Generator Building Fire Protection Foam (AFFF) System Piping Diagram RAI 2.3.3.15-6 UFSAR Section 9.5.1.4.1.4 discusses the water fire protection system, including the electric motor driven fire pump (P-2), the diesel engine driven fire pump (P-1) and the two jockey pumps (P-3 and P-4) providing water for fire suppression and fire fighting. UFSAR Section 9.5.1.4.1.5 discusses the instrumentation and control of the water supply, including the jockey pumps and the electric motor driven pump and diesel engine driven pump. LRA Section 2.3.3.15 references drawing D-04106-LR for license renewal scoping boundaries for the Fire Protection system. On drawing D-04106-LR, it is unclear if the Control Panels for Pumps P-1 (Engine Driven Fire Pump), P-2 (Motor Driven Fire Pump), P-3 (Jockey Pump), and P-4 (Jockey Pump) are in scope.
Please clarify the status of these control panels, and justify exclusion if they are out of scope.
Drawing D-04106-LR Unit 1 & 2 Plant Fire Protection System Piping Diagram RAI 2.3.3.15-7 The Brunswick UFSAR Section 9.5.1.4.3.4 discusses propagation/damage control features that are used to prevent the unhindered spread of fire and also to protect equipment from fire exposures. License Renewal Section 2.3.3.15 states that physical barriers are addressed in the License Renewal review as structural commodities in Section 2.4. Please clarify that the following have been included within the scope of license renewal, or justify the exclusion from the scope of license renewal:
- 1. Impingement shields installed between exposed cables of redundant trains of safe shutdown equipment when the trains are within 5 feet vertically or 3 feet horizontally of each other.
- 2. Impingement shields installed between the two fire pumps and between the diesel fire pump fuel tank and the fire pumps. (Discussed in UFSAR Section 9.5.1.5 fire hazard analysis writeup for fire area MWT-1 Makeup Water Treatment)
- 3. Flame retardant coatings applied to conduit and cable trays in cable access ways and spreading areas.
- 4. Fire stops in Cable Trays.
RAI 2.3.3.17-1 The BSEP LRA in Section 2.3.3.17 identifies the radioactive floor drain system as being in scope for license renewal because it contains components that are safety related and relied upon to remain functional during and following design basis events, components which are non-safety related whose failure could prevent satisfactory accomplishment of the safety related functions and components that are part of the Environmental Qualification Program. The LRA includes piping that provides a pressure boundary function and structural support/seismic integrity function. Drawing D-02543-LR, Sheet 1B shows dirty radiological waste (DRW) drain piping at Location E-8, which receives fluid from in-scope drains on the 80' elevation and connects to the in-scope 6" DRW drain to the RHR sump. The DRW drain piping is not identified as being in-scope, even though it is connected to in-scope piping. Provide additional information and justify your determination to exclude the DRW piping at Location E-8 from the scope of license renewal.
RAI 2.3.3.17-2 The BSEP LRA in Section 2.3.3.17 identifies the radioactive floor drain system as being in scope for license renewal because it contains components that are safety related and relied upon to remain functional during and following design basis events, components which are non-safety related whose failure could prevent satisfactory accomplishment of the safety related functions and components that are part of the Environmental Qualification Program. On drawing D-02533-LR, Sheet 2, at Locations B-8 and C-8, for the lines identified below, the transition Locations from out of scope to in-scope is inconsistent with the continuation drawings indicated.
If portions of these lines are out-of-scope for license renewal, their failure may affect the ability of the system to maintain its design function. Provide additional information to clarify the exact Locations of these transition points to show clearly which sections are in-scope and which are out-of-scope for license renewal.
C 1-G16-507-4-160 (D25043-1B, C-8)
C 1-G16-510-2-160 (D25046, C-1)
C 1-G16-511-2-160 (D25046, C-8)
C 2-G16-507-4-160 (D2543-1B, C-8)
C 2-G16-511-2-160 (D2546, C-8)
RAI 2.3.3.17-3 The BSEP LRA in Section 2.3.3.17 identifies the radioactive floor drain system as being in scope for license renewal because it contains components that are safety-related and relied upon to remain functional during and following design basis events, components which are non-safety related whose failure could prevent satisfactory accomplishment of the safety-related functions and components that are part of the Environmental Qualification Program. LRA Table 2.3.3.3-14, Component/Commodity Groups Requiring Aging Management Review and Their Intended Functions for the Radioactive Floor Drain System, identifies pump casing and floor drain tank as in-scope. On drawing D02533-LR, Sheet 2, at Location B-5, the line (213-4-161, 240-4-160) from the floor drain collector tank to the suction of the floor drain collector pump is not identified as in-scope for license renewal. In addition, several other lines (234-6-160 at D-8, V71 to Radwaste Building wall, 528-3-160 at C-7, 532-3-160 at A-7 and 2-G16-958-3-160 at C-7, 223-6-160, 250-3-160) leading to and from the drain tank are not included as in-scope for license renewal. Failure of these lines could cause loss of the pressure retaining boundary function. Provide additional information and justify your determination to exclude these lines and the floor drain collector pump casing from the scope of license renewal.
RAI 2.3.3.18-1 The BSEP LRA in Section 2.3.3.18 identifies the radioactive equipment drain system as being in scope for license renewal because it contains components that are safety related and relied upon to remain functional during and following design basis events, components which are non-safety related whose failure could prevent satisfactory accomplishment of the safety related functions and components that are part of the Environmental Qualification Program. LRA Table 2.3.3.3-15, Component/Commodity Groups Requiring Aging Management Review and Their Intended Functions for the Radioactive Equipment Drains System, identified the equipment drain tank as in-scope because it provides a pressure retaining boundary function. On drawings D-25043-LR, Sheet 1A and D-02543-LR, Sheet 1A, at Location A-7, the equipment drain tank shows several lines entering (8" CRW drain, 6" CV-FO11, 2" 1-160) and two exiting (4" CRW vent and 524-3-161 at A-7) that are not within the license renewal boundary. Failure of any of these lines could negate the pressure retaining boundary function of the equipment drain tank.
Provide additional information and justify your determination to exclude these lines from the scope of license renewal.
RAI 2.3.3.18-2 The BSEP LRA in Section 2.3.3.18 identifies the radioactive equipment drain system as being in scope for license renewal because it contains components that are safety-related and relied upon to remain functional during and following design basis events, components which are non-safety-related whose failure could prevent satisfactory accomplishment of the safety-related functions and components that are part of the Environmental Qualification Program. Drawing D-25043-LR, Sheet 1A, at Location E-5, shows a portion of drain piping as being within the scope of license renewal. However, the Clean Radioactive Waste (CRW) line that it flows into to return to the equipment drain tank is not shown as being in scope. Failure of this piping could prevent the equipment drain piping from performing its intended function. Provide additional information to justify your determination to exclude this piping from the scope of license renewal. Also, the same drain line shown on Unit 2 drawing D-02543-LR, Sheet 1A, at Location E-4, is not in scope for license renewal. Provide rationale as to why the same drain line on Unit 2 is not in-scope.
RAI 2.3.3.18-3 The BSEP LRA in Section 2.3.3.18 identifies the radioactive equipment drain system as being in scope for license renewal because it contains components that are safety-related and relied upon to remain functional during and following design basis events, components which are non-safety-related whose failure could prevent satisfactory accomplishment of the safety-related functions and components that are part of the Environmental Qualification Program. Drawing D-02531-LR, Sheet 1, at Location C-7, shows the waste collector tank as being within scope because it provides a pressure boundary function. There are several lines that exit the tank that are not included as in-scope for license renewal. These lines should be in-scope at least to the nearest isolation valve. Failure of these lines could negate the pressure boundary function of the waste collector tank. Provide additional information and justify your determination to exclude the following piping and associated isolation valves from the scope of license renewal.
C Line 14-4-161 and valve F036 C Line 35-4-161 and valve F033, F141 C Line 677-1/2-161 and its first isolation valve C Line 2G41-59-8-154 C Instrument level transmitter N026 and valve V338 C Waste Collector Pump suction line 1-4-152 and valves F034 C Line 9-8-160 and 2" CDW/SCRD cap RAI 2.3.3.19-1 BSEP LRA Table 2.3.3-16 identifies the intended function for Demineralized Water System tank (shell) components requiring aging management review as M1 provide pressure-retaining boundary. BSEP license renewal boundary drawings D-02040-LR Sheet 1A at Quadrant C-6 and D-02040-LR Sheet 1B at quadrant C-4 show the Unit 1 and Unit 2 Condensate Storage Tank (CST) shells as in-scope for license renewal. Some of the following Unit 1 and Unit 2 condensate storage tank shell nozzle Locations are connected non-isolable portions that are shown as not in-scope for license renewal and some are isolable but the piping is shown as not in-scope up to and including the first isolation valve:
C CST nozzle -15 D-02040-LR Sheet 1A Quadrant C-5 and D-02040-LR Sheet 1B Quadrant C-5 C CST nozzle -5 D-02040-LR Sheet 1A Quadrant C-5 and D-02040-LR Sheet 1B Quadrant C-4 C CST nozzle -2 D-02040-LR Sheet 1A Quadrant C-6 and D-02040-LR Sheet 1B Quadrant C-4 C CST nozzle -9 D-02040-LR Sheet 1A Quadrant C-6 and D-02040-LR Sheet 1B Quadrant C-4 C CST nozzle -13, D-02040-LR Sheet 1A Quadrant C-7 and D-02040-LR Sheet 1B Quadrant C-3 C CST nozzle -8 D-02040-LR Sheet 1A Quadrant C-7 and D-02040-LR Sheet 1B Quadrant C-3 C CST nozzle -14 D-02040-LR Sheet 1A Quadrant C-7 and D-02040-LR Sheet 1B Quadrant C-3 C CST nozzle -3 D-02040-LR Sheet 1A Quadrant C-7 and D-02040-LR Sheet 1B Quadrant C-3 C CST nozzle -4 D-02040-LR Sheet 1A Quadrant C-7 and D-02040-LR Sheet 1B Quadrant C-3 C CST nozzle -6 D-02040-LR Sheet 1A Quadrant C-7 and D-02040-LR Sheet 1B Quadrant C-3 Failure of the non-isolable piping connected to the above CST shell nozzles could result in a loss of the tank shell pressure-retaining function. Please provide additional information justifying the in-scope boundaries selected for the non-isolable piping connected to the above CST shell nozzles.
RAI 2.3.3.19-2 BSEP LRA Table 2.3.3-16 identifies the intended function for MWTS piping components requiring aging management review as M1 provide pressure-retaining boundary. BSEP license renewal boundary drawing D-25043-LR Sheet 1A at Quadrants F-4 and F-5 identifies a common drain header and selected connecting RWCU drain piping as in-scope for license renewal. For two RWCU drain lines, the in-scope boundary extends to piping shown on drawing D-25028-2B at Quadrants B-2 and B-6. Drawing D-25028-2B is not identified in LRA Section 2.3.3.19 as a MWST boundary drawing for license renewal. In addition this drawing was not made available for staff review. This is inconsistent with license renewal boundary drawing D-02543-LR Sheet 1A at Quadrants F-4 and F-5 which shows these piping as not in-scope. Please provide additional information to explain these inconsistencies and the basis for the boundary determinations.
RAI 2.3.3.24-1 The BSEP LRA in Section 2.3.3.24 identifies the Liquid Waste Processing System as being in scope for license renewal because it contains components that are non-safety related whose failure could prevent satisfactory accomplishment of the safety-related functions and components that are relied upon during postulated fires. LRA Table 2.3.3.3-19, Component/Commodity Groups Requiring Aging Management Review and Their Intended Functions for the Liquid Waste Processing System, identified tanks as in-scope because they provide the pressure boundary function. There are four waste neutralizer tanks and the concentrated waste tank in the liquid waste system. Drawing D-02534-LR, Sheet 1, at Locations E-3 and E-5, shows waste neutralizer tanks A and C, respectively. Drawing D-02534-LR, Sheet 2, at Locations E-4 and E-6, show waste neutralizer tanks B and D, respectively. Drawing D-02492-LR, at Location B-3, shows the Concentrated Waste Tank. Several lines identified below, enter each tank and they are not in-scope for license renewal. Failure of any of these lines would negate the pressure boundary function of the liquid waste system. Provide additional information and justify your determination to exclude the lines up to the closest isolation valve from the scope of license renewal.
A Waste Neutralizer Tank C Line 297-6-161 and valves F224A, V1379 C Line 302-3-Z-5 and valve, V14A, F231A, V1086 C Line 338-8-161 C Line 292-4-161, valve F222A C Line 337-8-161 (cross tie between A & C tanks)
C Waste Neutralizer Tank C Line 291-4-161, valve F222C C Line 296-6-161, valve F224C C Line 301-3-Z-5, valves V14C, V13C, F231C C Line 336-8-161 B Waste Neutralizer Tank C Line 299-6-161, valve F224B C Line 304-3-Z-5, valves V14B, V13B,V1087, F231B C Line 338-8-161 C Line 292-4-161, valve F222B C Line 339-8-161 (cross tie between B & D tanks)
D Waste Neutralizer Tank C Line 293-4-161, valve F222D C Line 296-6-161, valve F224D C Line 303-3-Z-5, valves V14D, V13D, F231D C Line 336-8-161 Concentrated Waste Tank Drawing C Line 997-2-162 C Line 353-11/2-162, valve F281 C Line 355-3-160 C Valve V5019 RAI 2.3.3.26-1 The BSEP UFSAR Section 9.1.3.3 states that there are non seismic drain connections located in the refueling canal between the fuel pool inner gate and the barrier that could drain the fuel pool below the top of the stored fuel if a seismic event occurred when the fuel pool gates are removed for refueling. Plugs are installed in these drain connections during refueling to prevent loss of water below the elevation of the top of the barrier after a seismic event. The BSEP LRA Section 2.3.3.26 states that components that are safety-related and are relied upon to remain functional during and following design basis events are in the scope of license renewal.
However, the drain lines in question, G41-75-1-1/2-161, G41-108-3-161, 111-1&1/2-161, 107-1&1/2-161, and 82-1-161, shown on drawings D-25049, Sheet 1B, at Location D-4 and D-02549 Sheet 1B, at Location D-4 respectively, are not identified as being in scope for license renewal.
Failure of these drain lines and associated valves could cause loss of refueling pool water during refueling preventing the fuel pool cooling system from maintaining adequate level and temperature in the spent fuel pool. Provide additional information and justify your determination to exclude these sections of drain piping from the scope of license renewal.
RAI 2.3.3.33-1 The Civil Structure Auxiliary systems are not described in the BSEP UFASR. The BSEP LRA states that Civil Structures Auxiliary Systems are in scope of license renewal because they contain either or both of the following:
- 1. Components that are safety related and are relied upon to remain functional during and following design basis events.
- 2. Components which are non-safety related whose failure could prevent satisfactory accomplishment of the safety related functions.
Table 2.3.3-24 Component Commodity Groups requiring aging management review and their intended functions identifies several components and commodity groups that are in-scope for license renewal; however there are no license renewal drawings available to determine if the list is complete. Provide additional clarifying information to allow for a determination that the appropriate Civil Structure Auxiliary systems have been included within the scope of license renewal.
RAI 2.3.4.5-1 The BSEP UFSAR states that the Feedwater System is to provide a dependable supply of feedwater to the reactor and to provide feedwater heating. Drawing D-25021-LR, Sheet 1C, Locations B-7 and C-7 and drawing D-02521-LR, Sheet 1C, Locations B-8 and C-8 have LRA flags in the middle of a section of pipe. The BSEP LRA Table 2.3.4-3 states that piping, fittings and valves are in scope. Failure of this section of pipe could have an effect on the Intended Function -1, provide pressure retaining boundary. Explain how the LRA boundary can occur in the middle of a section of pipe.
RAI 2.3.4.7-1 The BSEP UFSAR Section 3.4.2.6 states that various flood level alarms in the circulation water condenser pits warn the operator that an abnormal condition exists and that water is entering the pit. The USFAR further states that a set of three level alarms installed 9 feet above the pit floor will, when activated, automatically shut off the circulating water pumps. In light of the fact that the main condenser will not be designated to serve as a pressure-retaining boundary for license renewal, provide additional information to address whether any safety-related equipment or equipment that supports a safety function could be affected by flooding in this area.
RAI 2.3.4.11-1 The BSEP LRA Section 2.3.4.11 states that the Turbine Generator LO System is in the scope of License Renewal because it contains components which are non-safety related whose failure could prevent satisfactory accomplishment of safety related functions. The BSEP USFAR, Section 10.2.2 states that the Turbine Generator interlocks and features necessary to maintain system integrity, such as those for lube oil pressure, seal oil pressure, and back pressure are similar to those used in conventional turbine generator systems. The BSEP USFAR, section 10.2.4.b also describes the testing necessary to maintain safe operation of the Turbine Generator including tests on the lube oil system oil tank high low level alarm system. The function of the turbine generator lube oil system is to supply all the necessary lubricating oil to the main turbine and its support systems to allow the turbine to operate properly. The system is required to be in-service during startups, normal operations, shutdowns, and any time the turbine is on the turning gear. Although not a requirement, previous BWR license renewal applicants (Dresden Quad Cities SER) have highlighted those portions of the turbine generator lube oil system within scope on reference P&I drawings. Also, previous BWR applicants have identified the following component groups and their intended functions within the turbine generator lube oil system as being within the scope of license renewal and subject to and AMR:
C closure bolting (pressure boundary)
C filters/strainers (spatial interaction)
C piping and fittings (spatial interaction)
C piping and fittings (structural integrity/attached support)
C pump casings (spatial interaction)
C tanks (spatial interaction)
C valves (spatial interaction)
C valves (structural integrity/attached support)
The BSEP LRA Section 2.3.4.11 states that the Turbine Generator LO System components that are subject to AMR are addressed as civil commodities in section 2.4 with no clarifying information provided. No listing of components similar to that above was provided and no reference P&I drawings were provided. Without additional information and a more detailed description of the Brunswick turbine generator lube oil system functions, it can not be confirmed that all turbine generator lube oil system components within the scope of license renewal and subject to an AMR have been properly identified. Provide additional information and justification to confirm that all turbine generator lube oil system components within the scope of license renewal and subject to an AMR in accordance with 10 CFR 54.4 and 10 CFR 54.21(a)(1) have been identified.
Section 3.2 Engineered Safety Features Systems RAI 3.2-1 In LRA Table 3.2.2-1, carbon steel spray nozzles in the drywell and suppression chamber spray system, in a dry air/gas (internal) environment, are not identified with any aging effects. The applicant states that the basis is that Suppression pool spray is not required for design basis events. Drywell spray nozzles/piping is required but is normally isolated and not subject to plugging or fouling. Provide an explanation of why the suppression pool spray is not required for design basis events. Provide also the procedure taken to ensure that drywell spray nozzles/piping will be free from plugging. It should be noted that industry operating experience has revealed that plugging or fouling, which results in flow blockage of carbon steel spray nozzles, could occur if not properly prevented or managed.
RAI 3.2-2 In LRA Table 3.2.2-2, no aging effects are identified for glass components in a treated water (internal) environment. Provide the basis for such determination.
RAI 3.2-3 In LRA Table 3.2.2-2, for the stainless steel heat exchangers in dry air/gas (internal) environments, the applicant stated under Note 208 that Heat exchangers in this category are in scope for spatial interaction with safety related components. Therefore, only the external surfaces require aging management review. Clarify what this statement means, and explain how the aging management for the spatial interaction of the stainless steel components is to be performed.
RAI 3.2-4 In LRA Tables 3.2.2-3 and 3.2.2-5, and 3.2.2-7, carbon and stainless steel small-bore piping and fittings less than NPS 4-inch diameter, in treated water (includes steam)(internal) environments, are subject to cracking due to thermal and mechanical loading. The Section XI Inservice Inspection and Water Chemistry Programs are credited to manage the aging effects. In the subject tables, stainless steel small-bore piping less than NPS 4-inch diameter, in the same environment of treated water (includes steam )(internal), are also subject to cracking due to SCC. The same AMPs are credited to manage the aging effect. The applicant is requested to:
(1) provide the basis for the statement made under Note 226 that cracking due to thermal and mechanical loadings was evaluated and dispositioned as not applicable, and (2) clarify the statement made under Note 226 that The risk associated with cracking due to SCC is bounded by those components selected for inservice inspection as part of the Risk-informed ISI Program...
RAI 3.2-5 In LRA Table 3.2.2-3, stainless steel piping and fittings (HPCI) in treated water (includes steam)(internal) environments are subject to cracking due to SCC. The Water Chemistry and One-Time Inspection Programs are credited to manage the aging effect. The staff noted in LRA Section B.2.15 the statement made by the applicant that BSEP does not utilize the One-Time Inspection Program activity specified in NUREG-1801, for detection of cracking in small-bore Class 1 piping. Cracking of this piping will be detected and managed by the combination of the ASME Section XI, Subsection IWB, IWC and IWD Program supplemented by the Water Chemistry Program... Clarify the discrepancy found in the above statement and AMR review commitment.
RAI 3.2-6 In LRA Table 3.2.2-5, carbon steel piping and fittings (miscellaneous auxiliary and drain piping and valves) in treated water (internal) environments are subject to loss of material due to crevice, general, and pitting corrosion. The One-Time Inspection Program is credited to manage the aging effects. The applicants Note 205 states that The One-Time Inspection Program will include elements to verify the integrity of spatial interaction piping. Explain how this note is applicable to the aging effects identified. Provide the basis of using the One-Time Inspection Program alone to manage the identified aging effects without the use of the Water Chemistry Program.
RAI 3.2-7 In LRA Table 3.2.2-7, carbon steel piping (piping specialties) in treated water (internal) environments is subject to loss of material due to crevice, general, and pitting corrosion. The Preventive Maintenance (PM) Program is credited to manage the aging effects. The applicants Note 206 states that Internal inspection of the phenolic-lined carbon steel accumulator tanks is performed under the Preventive Maintenance Program. Explain the discrepancy noted in the types of components being considered in the aging management review. Provide the basis of crediting the Preventive Maintenance Program to manage the identified aging effects, in lieu of the Water Chemistry and One-Time Inspection Programs.
Section 3.4 Steam and Power Conversion Systems RAI 3.4-1 In LRA Tables 3.4.2-1 and 3.4.2-6, stainless steel piping and fittings (steam drains) and valves in treated water (includes steam) (internal) environments are subject to cracking due to SCC, and loss of material due to crevice and pitting corrosion. The Water Chemistry Program alone is credited to manage the aging effects. This is not acceptable to the staff, since for the BWR plant components in the identified environments, the AMP needs to be augmented by verifying the effectiveness of water chemistry control. The applicant is requested to reassess the aging management review for the components.
RAI 3.4-2 In LRA Table 3.4.2-2, carbon steel piping and fittings (steam drains) and valves in treated water (includes steam)(internal) environments are subject to loss of material due to general, crevice, and pitting corrosion. The One-Time Inspection Program is credited as the only AMP to manage the aging effects. A One-Time Inspection program may be appropriate only for situations where material degradation is not expected or is expected to occur at a slow rate. One-time inspections can also be used to verify the effectiveness of an AMP in its management of aging effects. Provide justification that a periodic inspection program, supplemented by the One-Time Inspection Program, is not used to manage the aging effects for the above carbon steel components. Also confirm that the piping is not a small-bore Class 1 piping, in order for the One-Time Inspection Program to be applicable for crack detection (ref. RAI 3.2-5 and LRA Section B.2.15).
RAI 3.4-3 In LRA Tables 3.4.2-3 and 3.4.2.4, stainless steel pipe and fittings (steam drains) and valves in treated water (includes steam)(internal) are subject to cracking due to SCC and loss of material due to crevice and pitting corrosion. The Water Chemistry and One-Time Inspection Programs are credited to manage the aging effects. Confirm that the piping is not a small-bore Class 1 piping, in order for the One-Time Inspection Program to be applicable for crack detection.
RAI 3.4-4 In LRA Table 3.4.2-5, titanium condensate coolers/condensers (tubes) in raw water environments are not identified with any aging effects. The same components in treated water (includes steam)(external) environments are subject to loss of material due to crevice corrosion.
Provide the basis for determining that no aging effects need to be identified for the titanium condensate coolers/condensers (tubes) in raw water environments.
3.5 Structures and Component Supports RAI 3.5-1 Refueling bellows (LRA Table 3.5.2-1) are manufactured from stainless steel, and they are protected from weather. The components protected from weather are not necessarily immune to loss of material. As the bellows are located between the refueling cavity and the drywell, they come in direct contact with water, and are subjected to sustained moist condition. In similar situations, the stainless steel bellows of some ice-condenser and Mark 1 containments (see IN 92-20) have experienced degradation and cracking. The applicant is requested to provide justification for not managing the aging of the bellows during the period of extended operation.
RAI 3.5-2 Cable trays and conduits (LRA Table 3.5.2-1) are either made of galvanized carbon steel, or stainless steel. The staff agrees that the potential for corrosion of stainless steel cable trays/conduits is remote, unless they are subjected to sustained high temperatures (> 140ºF) and the material yield strength is high (> 140 ksi). Loss of material due to galvanic corrosion is more likely for the cable trays/conduits if they are subjected to humid environment and welded to non-galvanized carbon steel supports. The applicant is requested to discuss why the BSEP cable trays and conduits and all components/commodities included within Notes 521 and 529, do not need aging management. As part of the justification, the applicant is requested to provide operating experience related to these components/commodities.
RAI 3.5-3 In the context of NUREG-1801 Item II.b2.2.21-G, related to the concrete components subjected to elevated temperatures, the applicant provided an evaluation in Note 536 and in Section 3.5.2.2.1.3. The staff does not agree with the applicants interpretation that the upper portion of the drywell subjected to sustained temperatures of approximately 170ºF can be considered as local area. However, the staff has, on a case by case, approved such temperatures without complex analysis, provided the concrete components and the load bearing items attached to such concrete components are periodically monitored. In light of the above discussion, the applicant is requested to justify why the items included in Table 3.5.2-1 and covered by Notes 536 and 513 should not be subjected to aging management during the period of extended operation.
RAI 3.5-4 Based on the evaluation provided in Section 3.5.2.2.1.3, a number of load resisting reinforced concrete structures within the drywell shell are likely to be subjected to temperatures higher than the established threshold of 150EF. The applicant is requested to provide the following information related to these structures:
- 1. Are these structures kept within the threshold temperature 150EF by a cooling system? If yes, please provide a summary of the operating experience related to the reliability of the cooling ventilation system. If no, provide the method of monitoring the temperatures of these structures.
- 2. Provide a summary of the results from the latest inspections performed on: (1)
RPV pedestal supports, (2) the foundation and floor slabs, and (3) the sacrificial shield wall under the existing Structural Monitoring Program.
RAI 3.5-5 Item hot penetration insulation, in Table 3.5.2-1, has been screened out as having no aging effects, and it does not require aging management (Note 540). As the inside sustained temperature of the containment is high (> 140ºF), and the outside is subjected to the reactor building temperature, the concrete temperatures around these penetration is likely to be high.
The applicant is requested to discuss the plant-specific operating experience related to the effectiveness of the insulation in keeping the temperatures around these penetrations (in the containment concrete) below 200ºF.
RAI 3.5-6 The staff agrees with the applicant that in general, the sump stainless steel liner is not subjected to aging management, so far as it meets the threshold criteria for stainless steel discussed in RAI 3.5-2. However, the thin sump liner needs to have some type of periodic inspection to assure that it has not bulged excessively between anchors, and not affected by the dissimilar weld details at penetrations and at the junctions of carbon steel components. The applicant is requested to discuss the plant-specific as well as the industry experience related to the condition of the stainless steel sump liners, to justify the AMR conclusion that no aging management is needed for stainless steel sump liners.
RAI 3.5-7 The staff finds confusing by the apparent contradiction in the discussion in Item No. 3.5.1-02 and in component penetrations in Table 3.5.2-1 related to aging management of penetrations (including sleeves and bellows). In Item 3.5.1-02, the applicant credits the ASME XI, IWE, and 10 CFR 50, Appendix J programs for aging management, and provides acceptable further evaluation in Section 3.5.2.2.1.7. However, in Table 3.5.2-1, the applicant asserts no aging effects, and no AMP. Note 542 reiterates the AMPs stated in Item 3.5.1-02. The applicant is requested to clarify this contradictory LRA requirements.
RAI 3.5-8 On the subject of lubrite bearings, the staff has been skeptic about the industry position that no aging management is needed, without providing acceptable technical justification. Some of the aging effects/mechanism could be loss of mechanical function because of distortion, dirt accumulation, fatigue due to vibratory and cyclic thermal loads, and gradual degradation of the lubricant used, particularly, when subjected to sustained elevated temperatures, and radiation (inside containment). Without systematic investigation of these factors, it would be difficult to accept a position that no aging management of lubrite bearings is needed (Note 524). In context of the above discussion, the applicant is requested to provide information to justify that none of the conditions cited in the aging effects/mechanism above is possible where the lubrite plates are used in BSNP.
RAI 3.5-9 In the LRA, the applicant did not specify the aging effect requiring management nor aging management program for the embedded/encased carbon steel (Tables 3.5.2.4 and 3.5.2.7) and galvanized carbon steel (Table 3.5.2.4) anchorages/embedments. In Notes Nos. 518 and 519 of LRA Table 3.5.2.4, the applicant stated that the BSEP AMR methodology concluded that carbon/low alloy steel and galvanized carbon/low alloy steel, completely encased in concrete, are not subject to aging effect. The staffs concern is that the carbon/low alloy steel and galvanized carbon/low alloy steel are likely subject to corrosion and loss of material for conditions involving cracked concrete. The applicant is requested to provide its justification for not considering aging effect on these structural elements in light of the staffs concern.
RAI 3.5-10 In LRA Table 3.5.2.4, the applicant did not specify the aging effect requiring management nor aging management program for the carbon steel piles that were driven in undisturbed soil. In Note No. 522 of LRA Table 3.5.2.4, the applicant stated that based on NUREG-1557, steel piles driven in undisturbed soils have been unaffected by corrosion; and those driven in disturbed soil experience minor to moderate corrosion to a small area of metal. Therefore, no aging effects have been concluded for steel piles. It is the staffs understanding that the conclusion of NUREG-1557 (References 16 and 17 of the LRA) is based on less than 40-year data. There are other documents (References 1 and 2 below) which indicate that significant corrosion of steel piles has been identified, even when piles were driven in undisturbed soil. Based on the information identified by the staff, the applicant is requested to provide additional information to justify the validity of its conclusion.
References
- 1. Probabilistic Model for Marine Corrosion of Steel for Structural Reliability Assessment, Journal ASCE 2003.
- 2. Corrosion Control Manual for Rail Rapid Transit, UMTA Report UMTA-DC-0152-83-1, 1983.
RAI 3.5-11 LRA Section 3.5.2.2.2.1, Aging of Structures Not Covered by Structures Monitoring Program, states that aging effects associated with aggressive chemical attack of concrete, etc., are not applicable as discussed in the plant-specific notes associated with LRA Tables 3.5.2-1 through 3.5.2.15. In LRA Tables 3.5.2.2 through 3.5.2-15, the applicant, based on the plant-specific Notes 501 and 517, did not specify the aging effect requiring management for Class I below grade concrete structures (reactor building, augmented off-gas building, diesel generator building, control building, turbine building, radwaste building, and miscellaneous structures and out buildings). Note 501 states that although no aging effects have been identified, the specified NUREG-1801 program will be assigned for management of this commodity, in accordance with the NRCs current position (ISG-03), and Note 517 states that groundwater monitoring is performed periodically to validate the assumption that the groundwater below-grade environment is not aggressive. In LRA Section 3.5.2.2.2.2, Aging Management of Inaccessible Areas, the applicant stated that the service water intake structure is the only structure with concrete elements subject to aggressive groundwater. The structure is located adjacent to the intake canal; therefore, the environmental parameters of intake water have been applied to the below grade portions of the concrete. However, no aging effect requiring management nor aging management program are identified for the service water intake structure in Table 3.5.2-7. The applicant is requested to provide its basis for not to specify aging effect requiring management and aging management program for the service water intake structure. The applicant is also requested to provide information to explain how the water chemistry is monitored including the past and current groundwater qualities (pH values and content of chlorides and sulfates),
frequency of monitoring, specific monitoring program used, and future plan for groundwater monitoring.
4.2 Neutron Irradiation Embrittlement RAI 4.2-1 Section 4.2 of the Carolina Power and Light Company (CP&L) license renewal application (LRA) for Brunswick Steam Electric Plant, Units 1 and 2 (BSEP-1/2 for Units 1 and 2, BSEP-1 for Unit 1, and BSEP-2 for Unit 2) identifies that loss of fracture toughness/neutron irradiation embrittlement assessments for the ferritic reactor vessel (RV) beltline base-metal and weld components are time-limited aging analyses (TLAAs) for the BSEP-1/2 license renewal application (LRA). LRA Table 4.2-5 for the BSEP-1 RV components and LRA Table 4.2-6 for BSEP-2 RV components include loss of fracture toughness/neutron irradiation embrittlement TLAA calculations for the N-16 A and B Instrumentation Nozzle Forgings. Confirm whether BSEP-1/2 has performed 54 EFPY TLAA assessments on upper shelf energy (USE) calculations and 1/4T RTNDT calculations for the nozzle shell welds that were used to fabricate the N-16 A and B instrumentation nozzles and, if so, whether the applicable TLAA calculations for the N-16 A and B nozzle shell welds have been included in Section 4.2 of the LRA. If CP&L does have applicable 54 EFPY TLAA data and calculations for these welds, but has not included them in the BSEP-1/2 LRA, please update Section 4.2 of the LRA to include the applicable TLAA assessments for the N-16 A and B nozzle shell welds.
RAI 4.2-2 10 CFR 54.3 provides that staffs criterion for determining whether a given plant analysis is within the scope of the definition for a TLAA. Section 5.3.3.1.3 of the BSEP-1/2 UFSAR indicates that a 40-year RV thermal shock analysis was performed on a BWR RV that is representative of the RVs at BSEP-1/2. The UFSAR section also stated that the GE analysis indicated that a single recirculation line break event could be tolerated at the end of the 40-year design life because the effects of neutron irradiation or other normal service fatigue damage are not expected to appreciably affect the single event tolerable strains. Based on the discussion in BSEP UFSAR Section 5.3.3.1.3, the staff concludes that the RV reflood thermal shock may meet the definition of a TLAA, as defined in 10 CFR 54.3. In contrast, CP&L has not identified that RV reflood thermal shock safety analysis is a TLAA for the BSEP-1/2 LRA. Provide your technical/regulatory basis for making this determination. If the BSEP RV thermal shock analysis is determined to meet the definition in 10 CFR 54.3 for TLAAs, amend the BSEP-1/2 LRA to include the RV thermal shock TLAA for BSEP-1/2, including an appropriate FSAR Supplement summary description for the analysis, as is required by 10 CFR 54.21(d).
RAI 4.2.4-1 Section A.1.2.1.3 of the BSEP-1/2 LRA provides CP&Ls FSAR Supplement summary description for the TLAA on pressure-temperature (P-T) limits. The summary description provides a sufficient basis for concluding that the P-T limits for BSEP-1/2 are a TLAA for the facilities and for stating why the applicant has developed P-T limit curves for the periods of extended operation. However, in accordance with this license amendment process, the P-T limit curves for the BSEP-1/2 extended periods of operation will require NRC review and approval prior to the expiration of the 32 EFPY P-T limit curves that are currently approved in the BSEP-1/2 Technical Specifications. The staff requests that the FSAR Supplement summary description be amended to state: (1) that the P-T limit curves for the BSEP-1/2 periods of extended operation will be submitted for NRC review and approval in accordance with the 10 CFR 50.90 license amendment process at least one year prior to expiration of the 32 EFPY P-T limit curves that are currently approved in the BSEP-1/2 Technical Specifications, and (2) as mandated in 10 CFR Part 50, Appendix G, this is required to cover P-T limit curves for the extended operating periods during both normal operations of the reactor (including heatups and cooldowns of the reactor, critical operations of the reactor, and transient operating conditions) and RV pressure test conditions.
RAI 4.2.5-1 On July 28, 1998, the NRC staff issued a Safety Evaluation Report (SER) of BWRVIP-05. In this SER, the staff concluded that the failure frequency of reactor vessel (RV) circumferential welds in boiling water reactors (BWRs) was sufficiently low to justify elimination of inservice inspection (ISI) of these welds. However, the staff also indicated that examination of the circumferential welds would need to be performed if the corresponding volumetric examinations of the RV axial welds revealed the presence of an age-related degradation mechanism. Confirm whether or not CP&Ls past volumetric examinations of the BSEP-1/2 RV axial welds have indicated the presence of cracking or other age-related degradation mechanisms in the welds.
RAI 4.2.5-2 In CP&Ls response to Generic Letter 92-01, Revision 1, Supplement 1, dated November 16, 1995, CP&L established 10EF as the official initial (unirradiated) RTNDT value for the FG circumferential welds (i.e., the weld from Heat No. 1P4218 for BSEP-1 and the weld from Heat No. 3P4000 for BSEP-2), as based on the NRC Branch Position MTEB 5-2. However, in Table 4.2-7 of BSEP-1/2 LRA, CP&L listed -50EF as the initial RTNDT value for the FG circumferential welds, as based on the NRC-approved methodology in General Electric (GE) Topical Report No.
NEDC-32399-P (refer to NRC safety evaluation [SE} dated December 16, 1994). In its letter and SE to the Boiling Water Reactor Owners Group (BWROG), the staff informed the BWROG that use of the methodology in Topical Report No. NEDC-32399-P is limited to nuclear plants that meet the following criterion:
The staff concludes that the GE RTNDT estimation method is an acceptable alternative for determining initial RTNDT values for vessel beltline materials lacking complete material test data. In future applications, licensees should still use the procedure in the ASME Code for determining initial RTNDT values. This method should only be applied to interpret incomplete old test data obtained prior to the summer of 1972.
The staff has the following requests in regard to how the set of initial Charpy-impact/drop weight test data for the FG circumferential welds conforms to this criterion, such that the GE methodology could be applied to re-establish the initial RTNDT value for these welds:
A. Clarify whether or not the set of initial Charpy-impact/drop weight test data for the FG circumferential welds conforms to the stated criterion on use of the GE methodology.
B. Explain the use of the technical data (including any and all applicable Charpy-impact, drop weight test data and curves) in applying the GE methodology to establish the initial RTNDT value as -50EF. If the new initial RTNDT value for the RV FG circumferential welds is based on a set of generic drop weight/Charpy-impact data, provide the standard deviation on the set of data used to establish the new mean initial RTNDT value (i.e., provide the I value, as defined in Position 1.1 of RG 1.99, Revision 2).
RAI 4.2.6-1 In the staffs supplemental safety evaluation report (SER) on Topical Report BWRVIP-05, dated March 7, 2000, the staff approved four Case Studies for evaluating the probability of failure analyses for beltline axial welds in boiling water reactor (BWR) reactor vessels (RVs). These Case Studies include the Clinton Nuclear Plant Case Study and three variations of the Pilgrim Nuclear Plant Case Study. These Case Studies are provided in Table 1 for reference:
Table 1: Comparison of Results from Staff and BWRVIP Initial Mean Vessel Failure Freq.
Plant RTNDT RTNDT (EF) (EF) Staff BWRVIP Clinton -30 91 2.73 E -6 1.52 E -6 Pilgrim -48 68 2.24 E -7 -------
Mod 1
- 0 116 5.51 E -6 1.55 E -6 Mod 2 ** -2 114 5.02 E -6 -------
- A variant of Pilgrim input data, with initial RTNDT = 0 EF
- A variant of Pilgrim input data, with initial RTNDT = -2 EF In regard to the background information for these Case Studies, the Pilgrim RV was fabricated by the Combustion Engineering Corporation (CE) and the Clinton RV was fabricated by Chicago Bridge and Iron Works (CB&I). In the BSEP-1/2 LRA, CP&L has opted to use the Mod 2 variant of the Pilgrim Case Study as the acceptance criterion basis for evaluating the TLAA on the RV axial weld probability of failure analyses. The BSEP-1/2 RVs were fabricated by CB&I.
Therefore, it appears to the staff that the Clinton Case Study may be the more appropriate Case Study for evaluating the beltline axial welds in the BSEP-1/2 RVs. Justify your basis for using the Mod 2 variant of the Pilgrim Case Study as the basis for evaluating this TLAA on the RV axial weld probability of failure analyses in lieu of using the Clinton Case Study.
RAI 4.2.7-1 Section 4.2.7 of the BSEP-1/2 LRA provides CP&Ls TLAA for the RV core shroud reflood thermal shock analysis. In this section of the LRA, CP&L identified that the 40-year core shroud strain analysis during a post-LOCA low pressure coolant injection (LPCI) reflood of the core shroud was a TLAA for BSEP-1/2, as defined in 10 CFR 54.3. The applicant identified that the impact of the neutron fluence on the strain analysis was one of bases that required the analysis to be within the scope of the definition for TLAAs, as defined in 10 CFR 54.3. In reviewing the information in LRA Section 4.2.7 and in BSEP UFSAR Section 3.9.2.5, the staff could not determine what acceptance criterion was being used for the maximum amount of allowable strain that could be tolerated in the core shroud during a post-LOCA LPCI reflooding event, or what neutron fluence was used to establish the maximum allowable strain criteria for core shroud welds and plates. Provide responses to the following Requests for Additional Information on this TLAA:
A. Clarify what %-elongation strain acceptance criteria are being used for the core shroud welds and plates in the TLAA assessment and what maximum limit is being established in neutron fluence level (i.e., in n/cm2, E $ 1.0 MeV) to be consistent with the %-elongation strain acceptance criteria used for the TLAA assessment. Clarify what actions would need to be taken by CP&L if the maximum limit on neutron fluence level for the core shroud is exceeded (e.g., refinement of the core shroud reflood thermal shock analysis, etc.).
B. It has been stated that the maximum tolerable amount of strain in the Type 304 stainless steel plates has been measured to be 20 %-elongation at a temperature of 290EC (554EF) and a neutron fluence of 8.0X1021 n/cm2 (E $ 1.0 MeV) and that the maximum amount of strain in Type 304 stainless steel weld metal has been measure to be 4 %-elongation at a temperature of 297EC (567EF) and a neutron fluence level of 8.0X1021 n/cm2 (E $ 1.0 MeV). Confirm whether Topical Report BWRVIP-35 provides the technical bases for these measured strain criteria, and if so, whether the topical report has been reviewed and approved by the NRC. If BWRVIP-35 does not provide the basis for these measured strain criteria, identify which technical report or analysis does provide the technical basis for these measured strain criteria.
RAI 4.2.8-1 The staff requests that the following RAIs be addressed on TLAAs for spring-loaded or bolted connections in the BSEP-1/2 core plates.
Part A. In Section 4.2.8 of the application, the applicant indicated that the analysis for installing the spring-loaded BSEP-2 core plate plugs was a TLAA for the BSEP-1/2 LRA because the amount of stress relaxation in the plugs was, in part, dependent on the accumulated neutron fluence in the plugs. However, CP&L did not reference the specific title and date of the analysis that met the criteria for this TLAA.
Reference by title and date which design basis or current licensing basis (CLB) document establishes the stress relaxation analysis for the spring loaded BSEP-2 core plate plugs as a TLAA for the BSEP-1/2 application. Clarify whether the analysis is a generic or plant-specific analysis and whether the analysis has been approved by the staff. If the analysis has been approved by the staff, reference the title and date of the staffs safety evaluation on the stress-relaxation analysis.
Part B. In BWRVIP-25, the BWRVIP established that core plate designs with rim hold down bolts would need to treat stress relaxation of the bolts as a potential TLAA. This was identified as Applicant Action Item No. 3 on BWRVIP-25. To respond to this Action Item (i.e., in Table 3 of AMP No. B.2.28 of the BSEP-1/2 LRA), CP&L stated that the potential susceptibility of the rim hold down bolts to stress relaxation was evaluated as a potential TLAA, but no TLAA was identified. This is consistent with page 3.1-51 of LRA Table 3.1-1, in which CP&L does not identify stress relaxation as an applicable aging effect requiring management for the core plate bolts. The following clarification is necessary for completion of the staffs review:
- 1. Clarify whether the core plate rim hold down bolts are within the scope of license renewal and require an aging management review (AMR). Confirm whether or not the core plate bolts referred to on page 3.1-51 of LRA Table 3.1-1 are the same components as the core plate rim hold down bolts that are referred to on page B-82 of the application.
- 2. If the core plate rim hold down bolts do require an AMR, justify your basis for concluding that stress relaxation does not require aging management and for concluding that a TLAA is not appropriate for the core plate rim hold down bolts, as is otherwise recommended in BWRVIP-25. If CP&L determines that loss of preload/stress relaxation of the core plate rim hold down bolts is an aging effect requiring management, amend LRA Table 3.1-1 to include an AMR entry on how loss of preload/stress relaxation will be managed in the components during the periods of extended operation for BSEP-1/2. If CP&L determines that a TLAA is necessary to manage loss of preload/stress relaxation in the core plate rim hold down bolts, amend Chapter 4.0 of the BSEP-1/2 LRA to include a TLAA on loss of preload/stress relaxation of the core plate rim hold down bolts.
RAI 4.2.8-2 Part A. CP&Ls FSAR Supplement summary description on the TLAA for the BSEP-2 spring-loaded core plate plugs discusses CP&Ls intent to use the Reactor Vessel and Internals Structural Integrity Program as the basis for managing loss of preload/stress relaxation in the core plate plugs. CP&L has also included this aging management strategy as a commitment in the Commitment Tracking List (CTL) for the application, which was submitted in Enclosure 1 of BSEP Serial Letter No. BSEP-04-006, dated October 18, 2004. In the CTL entry, CP&L indicated that the commitment for managing loss of preload/stress relaxation in the BSEP-2 spring-loaded core plate plugs has been incorporated into the FSAR supplement summary description for the TLAA (i.e., in Section A.1.2.1.7 of the LRA) and the FSAR supplement summary description for the Reactor Vessel and Internals Structural Integrity Program (i.e., in Section A.1.1.30 of the LRA). However, the staff has determined that the commitment on management of loss of preload/stress relaxation BSEP-2 core plate plugs has not yet been incorporated into the FSAR Supplement summary descriptions for LRA Sections A.1.2.1.7 and A.1.1.3.0. The staff requests that LRA Sections A.1.2.1.7 and A.1.1.3.0 both be amended to incorporate this commitment.
Part B. The FSAR Supplement Summary description includes the following incomplete sentence: The loss of preload may cause the plug to leak at a higher rate than the designed. The staff requests that this sentence be fixed editorially.
RAI 4.2.9-1 Part A. In Section 4.2.9 of the BSEP-1/2 LRA, CP&L identifies that a plant-specific safety assessment was conducted on the BSEP-1/2 core shroud repair designs (i.e., repair clamps) to justify installation of the repair clamps (i.e., bracket assemblies) over the H2 and H3 circumferential welds in the BSEP-1/2 core shrouds. Although the staff is aware that the safety assessment of the repair clamps was submitted to the NRC and approved by the staff, the staff has been unable to track the safety assessment and the staffs safety evaluation on the assessment in the NRCs Agencywide Documents Access and Management System (ADAMS). Identify which plant-specific BSEP evaluation/document contains the safety assessment on the BSEP core shroud repair clamps and which NRC safety evaluation was issued on the plant specific safety assessment for the clamps. Please include Serial Letter Number (if applicable),
Document Title, and the Issuance Date for the reference documents.
Part B: Confirm that the core shroud repair designs at BSEP-1/2 currently use core shroud repair clamps (bracket assemblies) and that the repair designs have not yet been upgraded to the types of tie-rod assembly designs that have been used in the repair of other U.S. BWR core shrouds.
4.3 Metal Fatigue RAI 4.3.1 Table 4.3.2 of the LRA lists reactor vessel components for which 40-year fatigue CUFs were determined in the original stress report. Some components are listed as exempted. Provide justification why these components were exempted from fatigue analysis.
RAI 4.3.2 Section 4.3.2 of the LRA states that, except for the RPV shroud support and the RPV internal brackets, no other fatigue analyses were identified for the RPV internal components.
Table 3.1.2-1 lists the jet pump assemblies, the fuel support and control rod drive assemblies as TLAAs, evaluated for cumulative damage in accordance with 10 CFR 54.21(c). Provide justification for not identifying these TLAAs in Section 4.3.2.
4.6 Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analyses RAI 4.6-1 Provide the design codes for liner plate, torus downcomer/vent header and torus attached and SRV piping.
RAI 4.6-2 State whether the liner plate/pool shell was evaluated for fatigue under the Mark I Containment Program Plant Unique Analysis. If not, provide the justification why a fatigue analysis was not required.
RAI 4.6.1-1 The estimate of the total SRV actuations to occur over the 40-year plant life was based on the number of actual SRV actuations counted through 1981. Provide a statement indicating that this estimate remains valid and conservative based on actual SRV actuations counted through 2004.
RAI 4.6.1-2 This section refers to an augmented Class 2/3 fatigue methodology that was developed to account for cyclic mechanical loads. Provide a description of this methodology, or alternatively, provide an accessible reference where this methodology may be found.