NUREG-1739

Analysis of Public 

 Comments on the

Improved License

Renewal Guidance

Documents

U.S. Nuclear Regulatory Commission

Office Nuclear Reactor Regulation

Washington, DC 20555-0001
Inside Front Cover

(NRC to supply)
 NUREG-1739

 

Analysis of Public

Comments on the 

Improved License

Renewal Guidance

Documents

Manuscript Completed: April 2001

Date Published: July 2001

Prepared by

E. A. Kleeh

Technical Coordinator

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
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April 2001 iii NUREG-1739

ABSTRACT

This report contains the staff’s analysis of the stakeholder’s comments on the license renewal

guidance documents, which are the draft Regulatory Guide DG-1104, “Standard Format and

Content for Applications to Renew Nuclear Power Plant Operating Licenses,” the draft Standard

Review Plan for License Renewal, the draft Generic Aging Lessons Learned (GALL) report, and

the Nuclear Energy Institute (NEI) document 95-10, Rev. 3, “Industry Guideline for

Implementing the Requirements of 10 CFR Part 54 – The License Renewal Rule.” The license

renewal guidance documents were issued for public comment on August 31, 2000 (65 FR

53047). The staff’s analysis is presented in a tabular format and contained in five appendices:

Appendix A addresses the participant comments from the license renewal public workshop on

September 25, 2000; Appendix B addresses the specific written comments submitted by NEI;

Appendix C addresses the written comments submitted by various stakeholders, such as the

Union of Concerned Scientists, utilities, and private citizens; Appendix D addresses five

technical reports provided by the Union of Concerned Scientists; and Appendix E addresses the

Advisory Committee on Reactor Safety consultants’ structural and electrical comments. The

April 2001 version of the license renewal guidance documents incorporated the information in

this report.
NUREG-1739 iv April 2001

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April 2001 v NUREG-1739

TABLE OF CONTENTS

Page

Abstract ............................................................................................................................ iii

List of Contributors – 1999-2001 ....................................................................................... vii

Abbreviations .................................................................................................................... xi

Executive Summary .......................................................................................................... ES-1

1 Introduction ................................................................................................................. 1-1

1.1 Background ........................................................................................................ 1-1

1.2 Organization of Report........................................................................................ 1-1

APPENDIX A: Disposition of Participant Comments from the License Renewal

Public Workshop, September 25, 2000

A.1. Introduction......................................................................................................... A-1

A.2. Participant Affiliation ........................................................................................... A-2

A.3. Evaluation and Disposition of Comments ........................................................... A-5

A.4. References......................................................................................................... A-6

APPENDIX B: Disposition of NEI Comments

B.1. Introduction......................................................................................................... B-1

B.2. Evaluation and Disposition of Comments ........................................................... B-2

B.3. Origin of NEI Comments..................................................................................... B-3

B.4. References......................................................................................................... B-4

APPENDIX C: Disposition of Written Public Comments

C.1. Introduction......................................................................................................... C-1

C.2. Evaluation and Disposition of Comments ........................................................... C-2

C.3. Origin of Comments............................................................................................ C-3

C.4. References......................................................................................................... C-4

APPENDIX D: Disposition of Five Union of Concerned Scientists Reports

D.1. Introduction......................................................................................................... D-1

D.2. Evaluation and Disposition of Comments ........................................................... D-2

D.3. References......................................................................................................... D-3

APPENDIX E: Disposition of the NRC Advisory Committee on Reactor

Safeguards (ACRS) Consultants’ Electrical and Structural

Comments

E.1. Introduction......................................................................................................... E-1

E.2. Evaluation and Disposition of Comments ........................................................... E-2

E.3. References......................................................................................................... E-3
NUREG-1739 vi April 2001

LIST OF TABLES

Page

Table A Evaluation and Disposition of Participant Comments from the

License Renewal Public Workshop, September 25, 2000 ................... A-9

Table B.2.1 Disposition of NEI Comments on Chapter II of GALL Report............... B 2.1-1

Table B.2.2 Disposition of NEI Comments on Chapter III of GALL Report ............. B 2.2-1

Table B.2.3 Disposition of NEI Comments on Chapter IV of GALL Report ............. B 2.3-1

Table B.2.4 Disposition of NEI Comments on Chapter V of GALL Report .............. B 2.4-1

Table B.2.5 Disposition of NEI Comments on Chapter VI of GALL Report ............. B 2.5-1

Table B.2.6 Disposition of NEI Comments on Chapter VII of GALL Report ........... B 2.6-1

Table B.2.7 Disposition of NEI Comments on Chapter VIII of GALL Report ........... B 2.7-1

Table B.2.8 Disposition of NEI Comments on Chapter X of GALL Report .............. B 2.8-1

Table B.2.9-1 Disposition of NEI Electrical Comments on Chapter XI

of GALL Report................................................................................... B 2.9-1

Table B.2.9-2 Disposition of NEI Mechanical Comments on Chapter XI

of GALL Report................................................................................... B 2.9-5

Table B.2.9-3 Disposition of NEI Structural Comments on Chapter XI

of GALL Report................................................................................... B 2.9-33

Table B.2.10 Disposition of NEI Comments on Chapter 1 of SRP-LR ..................... B 2.10-1

Table B.2.11 Disposition of NEI Comments on Chapter 2 of SRP-LR ...................... B 2.11-1

Table B.2.12-1 Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR.. B 2.12-1

Table B.2.12-2 Disposition of NEI Comments on Chapter 3, Section 3.2, of SRP-LR.. B 2.12-13

Table B.2.12-3 Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR.. B 2.12-21

Table B.2.12-4 Disposition of NEI Comments on Chapter 3, Section 3.4, of SRP-LR.. B 2.12-29

Table B.2.12-5 Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR.. B 2.12-31

Table B.2.13 Disposition of NEI Comments on Chapter 4 of SRP-LR ...................... B 2.13-1

Table B.2.14 Disposition of NEI Comments on Appendix A of SRP-LR ................... B 2.14-1

Table B.2.15 Disposition of Written Generic NEI Comments ................................... B 2.15-1

Table B.2.16 Disposition of NEI Comments Submitted at a Meeting

between NEI and NRC on November 8, 2000..................................... B 2.16-1

Table C Disposition of Written Public Comments.............................................. C-6

Table D Disposition of Five Union of Concerned Scientists Reports................. D-4

Table E Disposition of the NRC Advisory Committee on Reactor

Safeguards (ACRS) Consultants’ Electrical and

Structural Comments .......................................................................... E-4
April 2001 vii NUREG-1739

LIST OF CONTRIBUTORS – 1999-2001

License Renewal and Standardization Branch

Office of Nuclear Reactor Regulation

P. T. Kuo Section Chief

S. Lee Team Leader

R. Anand Technical Support

T. Bloomer Technical Coordination (on rotation)

S. Chey Clerical Support

M. Comar Technical Support (on rotation)

J. Dozier Technical Coordination

R. Franovich Technical Coordination (on rotation)

S. Green Clerical Support

S. Hoffman Technical Support

P. Kang Technical Coordination

E. Kleeh Technical Coordination (on rotation)

S. Koenick Technical Support

W. Liu Technical Support

S. K. Mitra Technical Coordination

K. Rico Technical Coordination

D. Solorio Technical Coordination

J. Strnisha Technical Coordination

O. Tabatabai-Yazdi Technical Coordination

H. Wang Technical Support

Office of Nuclear Reactor Regulation

H. Ashar Structural Engineering

G. Bagchi Technical Coordination

M. Banic Materials Engineering

C. Berlinger Technical Coordination

C. Carpenter Materials Engineering

P. Y. Chen Technical Coordination

T. Cheng Structural Engineering

S. Coffin Materials Engineering

J. Davis Materials Engineering

D. Dorman Quality Assurance

T. Eaton Plant Systems Engineering

B. Elliot Materials Engineering

J. Fair Mechanical Engineering

D. Frumkin Plant Systems Engineering

G. Galletti Quality Assurance

G. Georgiev Materials Engineering

C. Gratton Plant Systems Engineering

F. Grubelich Mechanical Engineering

M. Hartzman Mechanical Engineering

R. Hermann Materials Engineering

A. Hiser Materials Engineering

C. Holden Electrical Engineering
NUREG-1739 viii April 2001

LIST OF CONTRIBUTORS – 1999-2001 (continued)

Office of Nuclear Reactor Regulation (continued)

S. Hou Materials Engineering

N. Iqbal Plant Systems Engineering

D. Jeng Structural Engineering

K. Karwoski Materials Engineering

Y. Kim Structural Engineering

W. Koo Materials Engineering

C. Lauron Materials Engineering

A. Lee Structural Engineering

Y. Li Mechanical Engineering

J. Ma Structural Engineering

K. Manoly Structural Engineering

J. Medoff Materials Engineering

K. Parczewski Chemical Engineering

P. Patnaik Material Engineering

J. Peralta Quality Assurance

J. Rajan Mechanical Engineering

P. Shemanski Electrical Engineering

E. Sullivan Materials Engineering

J. Tatum Plant Systems Engineering

B. Thomas Plant Systems Engineering

E. Weiss Plant Systems Engineering

S. West Plant Systems Engineering

K. Wichman Materials Engineering

Office of Nuclear Regulatory Research

J. Vora Team Leader

A. Beranek Technical Editor

J. Boardman Reactor Systems Engineering

J. Costello Structural Engineering

M. Dey Reliability and Risk Analyst

O. Gormley Mechanical Engineering

H. Graves Structural Engineering

C. Hsu Mechanical Engineering

D. Jackson Materials Engineering

B. Jones Nuclear Engineering

M. Kirk Materials Engineering

R. Lloyd Reactor Systems Engineering

M. McNeil Materials Engineering

J. Muscara Metallurgical Engineering

H. Ornstein Reactor Systems Engineering

S. Pullani Reactor Systems Engineering

A. Serkiz Mechanical Engineering

K. Shaukat Mechanical Engineering

M. Wegner Reactor Systems Engineering
April 2001 ix NUREG-1739

LIST OF CONTRIBUTORS – 1999-2001 (continued)

Office of the General Counsel

J. Euchner Legal Counsel

B. Poole Legal Counsel

R. Weisman Legal Counsel

M. Young Legal Counsel

Argonne National Laboratory

Y. Y. Liu Principal Investigator

K. Brown Technical Editor

O. Chopra Materials Engineering

D. Diercks Materials Engineering

R. Fabian Quality Assurance

D. Henley Mechanical Engineering

A. Hull Materials Engineering

L. Kickels Clerical Support

D. Ma Mechanical Engineering

J. Robson Clerical Support

L. Salinas Clerical Support

K. Schroeder Clerical Support

R. Seidensticker Mechanical Engineering

W. Shack Materials Engineering

V. Skonicki Clerical Support

V. Shah Materials and Mechanical Engineering

B. Shelton Reactor and Plant Systems Engineering

S. Tam Materials Engineering

Brookhaven National Laboratory

R. Morante Principal Investigator

P. Bezler Mechanical Engineering

J. Braverman Containment Structures

G. DeGrassi Mechanical Engineering

C. Hofmayer Structural Engineering

R. Lofaro Electrical Components

S. Shteyngart Clerical Support

S. Signorelli Clerical Support

M. Subudhi Mechanical Engineering

M. Villaran Electrical Engineering

J. Xu Structural Engineering
NUREG-1739 x April 2001

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April 2001 xi NUREG-1739

ABBREVIATIONS

ACI American Concrete Institute

ACRS Advisory Committee on Reactor Safeguards

ADAMS Agencywide Document Access and Management System

AE architect engineer

AEA Atomic Energy Act

AEOD NRC Office for Analysis and Evaluation of Operational Data

AEP American Electric Power

AFWS auxiliary feedwater system

AMP aging management program

ANL Argonne National Laboratory

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

AUX auxiliary system

BNL Brookhaven National Laboratory

BWR boiling water reactor

BWRVIP Boiling Water Reactor Vessel and Internals Project

CAN Citizens Awareness Network

CASS cast austenitic stainless steel

CCCW closed-cycle cooling water

CFR Code of Federal Regulations

CLB current licensing basis

CM condition monitoring

CNS Constellation Nuclear Services

COMED Commonwealth Edison Company

CP&L Carolina Power and Light Company

CRD control rod drive

CVCS chemical and volume control system

DE NRC/NRR Division of Engineering

DET NRC/RES Division of Engineering Technology

DG Draft Regulatory Guide

DOR Division of Operating Reactors

DP Duke Power Company

DRIP NRC/NRR Division of Regulatory Improvement Programs

DSSA NRC Division of Systems Safety and Analysis

ECCS emergency core cooling system

EDG emergency diesel generator

EMCB NRC/NRR/DE Materials and Chemical Engineering Branch

EMEB NRC/NRR/DE Mechanical and Civil Engineering Branch

EOP emergency operating procedure

EPRI Electric Power Research Institute

ESF engineered safety feature

EQ environmental qualification

FPC fire pump control

FR Federal Register
NUREG-1739 xii April 2001

ABBREVIATIONS (continued)

FSAR final safety analysis report

GALL Generic Aging Lessons Learned

GDC general design criteria

GE General Electric

GEIS generic environmental impact statement

GL generic letter

GSI generic safety issue

HLW NRC/NMSS Division of High-Level Waste

I&C instrumentation and control

I&M Indiana Michigan Power

IEB IE bulletin

IEEE Institute of Electrical and Electronics Engineers

IN information notice

INEEL Idaho National Environmental and Engineering Laboratory

IPE individual plant examination

KOPEC Korea Power Engineering Company

LER licensee event report

LOCA loss of coolant accident

LR license renewal

LRA license renewal application

LR-PW license renewal public workshop

LWR light water reactor

NEI Nuclear Energy Institute

NEPA National Environmental Policy Act

NESF normal engineered safety feature

NIRS Nuclear Information and Resource Service

NMC Nuclear Management Company

NMSS NRC Office of Nuclear Material Safety and Safeguards

NNECO Northeast Nuclear Energy Company

NPAR nuclear plant aging research

NRC Nuclear Regulatory Commission

NRR NRC Office of Nuclear Reactor Regulation

NUMARC Nuclear Management and Resources Council

NUS NUS Information Services

ODSCC outside diameter stress corrosion cracking

PBPM planning, budgeting, and performance management

PC plugging criteria

PECO Philadelphia Energy Company

PRA probabilistic risk analysis

PTS pressurized thermal shock

PWR pressurized water reactor
April 2001 xiii NUREG-1739

ABBREVIATIONS (continued)

PWSCC primary water stress corrosion cracking

QA quality assurance

RII NRC Region II (Atlanta, Georgia)

RAI request for additional information

RCS reactor coolant system

RES NRC Office of Nuclear Regulatory Research

RG Regulatory Guide

RG&E Rochester Gas and Electric

RGEB NRC/NRR/DRIP Generic Issues, Environmental, Financial,

and Rulemaking Branch

RHR residual heat removal

RLSB NRC/NRR/DRIP License Renewal and Standardization Branch

RROP Revised Reactor Oversight Program

RWST refueling water storage tank

SAMG severe accident management guidelines

SCC stress corrosion cracking

SER safety evaluation report

SG steam generator

SOC statements of consideration

SNC Southern Nuclear Company

SPCS steam and power conversion system

SRM staff requirements memorandum

SRP-LR standard review plan

SRP-LR-LR standard review plan for license renewal

SS stainless steel

SSC systems, structures, and components

TLAA time-limited aging analysis

UCS Union of Concerned Scientists

UFSAR updated final safety analysis report

USAEC U.S. Atomic Energy Commission

UT ultrasonic testing

VP Virginia Power

W&S Winston & Strawn

WEPCO Wisconsin Electric Power Company

WESCO Westinghouse Electric Company
NUREG-1739 xiv April 2001

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April 2001 ES-1 NUREG-1739

EXECUTIVE SUMMARY

OVERVIEW

On August 31, 2000, the Nuclear Regulatory Commission (NRC) announced the issuance and

availability of a draft Regulatory Guide DG-1104, “Standard Format and Content for Applications

to Renew Nuclear Power Plant Operating Licenses”; a draft Standard Review Plan for License

Renewal (SRP-LR-LR), “Standard Review Plan for the Review of License Renewal Applications

for Nuclear Power Plants”; a draft Generic Aging Lessons Learned (GALL) report for public

comment (65 FR 53047); and DG-1104, which proposed to endorse NEI 95-10, Rev. 3,

“Industry Guideline for Implementing the Requirements of 10 CFR Part 54 – The License

Renewal Rule.” These improved license renewal guidance documents describe methods

acceptable to NRC staff for implementing the license renewal rule (10 CFR Part 54), as well as

techniques used by NRC staff in evaluating applications for license renewals. The staff also held

public meetings with stakeholders to discuss their comments.

The NRC has taken into consideration all comments received as a result of the solicitation

described above and incorporated their NRC dispositions into the April 2001 version of the

license renewal guidance documents.

This report provides the evaluation and disposition of all public comments received by the NRC

on the license renewal guidance documents.

NATURE AND SCOPE OF COMMENTS

In total, 1,084 comments were received and docketed from stakeholders on or before

October 16, 2000. The nuclear industry provided 860 comments, with the majority of those from

the Nuclear Energy Institute. The public, including public interest groups, provided

177 comments, with 125 of those comments coming from individuals representing themselves

and public interest groups. Those 125 general comments were concerned with the validity of the

license renewal process. The remainder of the comments (or 47 of the comments) came from

the ACRS consultants. This NUREG includes written comments from 128 commentators,which

represent comments from 101 individuals, 15 public interest groups, and 12 industry groups that

responded to the request for public comments (65 FR 53047).
NUREG-1739 ES-2 April 2001

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April 2001 1-1 NUREG-1739

1. INTRODUCTION

1.1 BACKGROUND

On August 31, 2000, the Nuclear Regulatory Commission (NRC) announced the issuance and

availability of a draft Regulatory Guide DG-1104, “Standard Format and Content for Applications

to Renew Nuclear Power Plant Operating Licenses”; a draft Standard Review Plan for License

Renewal (SRP-LR-LR), “Standard Review Plan for the Review of License Renewal Applications

for Nuclear Power Plants”; a draft Generic Aging Lessons Learned (GALL) report for public

comment (65 FR 53047); and DG-1104, which proposed to endorse NEI 95-10, Rev. 3,

“Industry Guideline for Implementing the Requirements of 10 CFR Part 54 – The License

Renewal Rule.” These improved license renewal guidance documents describe methods

acceptable to NRC staff for implementing the license renewal rule (10 CFR Part 54), as well as

techniques used by NRC staff in evaluating applications for license renewals. The NRC also

announced a public workshop that was held on September 25, 2000, to facilitate gathering

public comment on the draft documents. The NRC was especially interested in stakeholder

comments that would improve the safety, effectiveness, and efficiency of the license renewal

process. The staff also held public meetings with stakeholders to discuss their comments.

1.2 ORGANIZATION OF REPORT

This report contains the NRC assessment of the stakeholder comments. The evaluation and

dispositions are prepared in a tabular format and contained in the following five appendices:

Appendix A addresses the participant comments from the license renewal public workshop on

September 25, 2000; Appendix B addresses the specific written comments submitted by the

Nuclear Energy Institute (NEI); Appendix C addresses the written comments submitted by

various stakeholders, such as the Union of Concerned Scientists, utilities, and private citizens;

Appendix D addresses five technical reports provided by the Union of Concerned Scientists;

and Appendix E addresses the Advisory Committee on Reactor Safety (ACRS) consultant

comments on the structural and electrical components.
NUREG-1739 1-2 April 2001

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APPENDIX A

DISPOSITION OF PARTICIPANT COMMENTS

FROM THE LICENSE RENEWAL PUBLIC WORKSHOP,

SEPTEMBER 25, 2000
A-ii

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April 2001 A-1 NUREG-1739

A.1. INTRODUCTION

NRC’s September 25, 2000, license renewal public workshop (LR-PW) was the second

outreach workshop (the first was December 6, 1999) to obtain feedback from stakeholders on

the NRC development of the “Generic Aging Lessons Learned” (GALL) report and the revised

guidance for the conduct of review of license renewal applications.

The draft GALL report dated August 2000, along with the draft SRP-LR dated August 2000,

DG-1104, and NEI 95-10 Revision 2, were available for public comment on the Regulatory

Guidance website page (http://www.nrc.gov/NRC/REACTOR/LR/guidance.html). The August

2000 Draft GALL report superceded the earlier version of the report, dated December 6, 1999,

and the original NUREG/CR-6490, “Nuclear Power Plant Generic Aging Lessons Learned

(GALL),” Volumes 1 and 2, issued in December 1996.

The NRC staff made 16 presentations during the workshop that were designed to elicit

stakeholder input. The workshop discussion was based on first reviewing the agenda for any

add-on topics and then addressing the relevant documents with ten discussion topics addressed

by different speakers. The Federal Register Notice Questions (65 FR 53047) were addressed at

the end. Thirty-two individuals spoke and/or made comments, with 17 being from the NRC and

15 from other organizations. About 86 different comments were made by these 15 non-NRC

stakeholders. Sixty-seven were made by individuals representing industry groups and 19 from

individuals representing public interest groups or themselves. The focus of the majority of the

discussion seemed to be the technical details or fine points. The nature of the comments was

substantially different from that of the December 6, 1999, workshop, during which more general

recurring themes, such as credit for existing programs for license renewal, regulatory and/or

attribute creep, and adequacy of mechanisms for public review.

All comments made by stakeholders are sorted in alphabetical order by the commenter’s last

name and listed in Table A of Appendix A, along with the NRC analysis of the stakeholder

comments. Stakeholder comments have been incorporated or addressed in the license renewal

guidance documents.
NUREG-1739 A-2 April 2001

A.2. PARTICIPANT AFFILIATION

Of the 115 documented attendees attending NRC’s September 25, 1999, License Renewal

Public Workshop (LR-PW, http://www.nrc.gov/NRC/REACTOR/LR/IRG/workshop0925.html), 56

were from the NRC. At least 26 participants represented power companies, 10 were from

National Laboratories, 1 participant was from the Union of Concerned Scientists, 5 participants

represented the Nuclear Energy Institute, and 18 represented other organizations.

The participant list is shown, sorted alphabetically first by organizational affiliation and then by

name of attendee. Individuals who participated and whose comments are noted in the official

hard copy of the transcript for the NRR-License Renewal Public Workshop (LR-PW) are noted

by an asterisk (*) next to their name.

Affiliation Attendee

AEP-Cook *Kunsemiller, David

AmerenUE Bell, Patrick

Analytical Consulting Services Ely, Richard

ANL Chopra, Omesh

ANL Fabian, Ralph (Bud)

ANL Hull, Amy B.

ANL *Liu, Yung Y.

ANL Ma, David C.

ANL Shah, Vik

ANL Shelton, Brent

ANL Tam, Shiu-Wing

Bechtel Keys, Julie

Bechtel Power Corp. Smith, Wayne

BNL Lofaro, Robert

BNL Morante, Rich

CES *Chang, Ken

Constellation Nuclear Services

(CNS)

*Bowman, Marvin

CNS *Rycyna, John

CNS Sturdevant, Lee

CNS *Taormina, Ernie

CP&L Fletcher, Michael H.

Dominion Corbin, Bill

Duke Energy Robison, Greg

Enercom Services Masiero, David

Entergy Young, Garry G.

First Energy Kurtz, Gene

Entergy Operations Mosher, Natalie

First Energy Corp. Borysiak, Michael

Florida Power and Light *Menocal, Antonio G.

FPC Becker, Gary

GE Negres, Paige

Hopkins & Sutter *Danstanger, Chris (noted in

transcript but not on attendance

roster)

Hopkins & Sutter Stenger, Dan

Hopkins & Sutter Trubatch, Sheldon

NEI *Beedle, Ralph

NEI Evans, Robert
April 2001 A-3 NUREG-1739

Affiliation Attendee

NEI Marion, A.

NEI Pietrangelo, Tony

NEI *Walters, Doug

Northeast Utilities Guonest, Jay

NRC/NRR/DRIP Ader, Charles

NRC/NRR/DRIP/RLSB Anand, Raj

NRC/DE/EMCB Andruszkiewicz, Edward V.

NRR/DRIP/RGEB Auluck, Raj

NRC/NRR/DE Bagchi, Goutam

NRC Banic, Lee

NRC Bartlett, Jeff

NRC/NRR/DE Bateman, William

NRC/NRR Berlinger, Carl H.

NRC/NMSS/HLW *Bloomer, Tamara

NRC/RES/DET Boardman, John

NRC/NRR/DRIP Burton, William

NRC Chen, Pel-Ying

NRC/NRR/DE *Cheng, Thomas

NRC/NRR/DE *Davis, Jim

NRC/NRR/RLSB *Dozier, Jerry

NRC/ACRS Dudley, Noel

NRC/NRR/DE/EMCB Elliot, Barry

NRC/NRR *Elliott, Rob

NRC *Fair, John

NRC/RII *Franovich, Rani

NRC/NRR/DE Gasper, Joseph

NRC/DSSA Gratton, Chris

NRC Graves, Herman

NRC/DRIP/RLSB *Grimes, Chris

NRC/NRR/EMEB Grubelich, Francis

NRC/NRR/DE Hermann, Robert

NRC/NRR *Hiser, Allen

NRC/NRR Hoffman, Steve

NRC/NRR Hou, Shou-Nien

NRC *Hsu, Chuck

NRC Huang, Yu Sang

NRC/NRR/DE *Jeng, Dave

NRC/NRR/DRIP/RLSB Kang, Peter J.

NRC/NRR Kein, Andrew

NRC/NRR Koenick, Stephen

NRC/NRR/DRIP/RLSB *Kuo, P. T.

NRC/NRR/DE Lauron, Carolyn L.

NRC/NRR/DRIP/RLSB *Lee, Sam

NRC/NRR/SPLB Li, Chang-Yang

NRC/NRR/DE/EMEB Li, Y. C. (Renee)

NRC/NRR/DRIP/RLSB Liu, Wah C.(Winston)

NRC Mcneil, Michael

NRC/NRR/DRIP/RLSB Mitra, Sikhindra

NRC/NRR/DE Munson, Cliff

NRC/NRR *Peralta, Juan

NRC Prato, Robert J.

NRC/NRR/DE Rothman, Robert
NUREG-1739 A-4 April 2001

Affiliation Attendee

NRC/NRR/DE/EEIB *Shemanski, Paul

NRC/NRR/DRIP/RLSB Strnisha, Jim

NRC/NRR/SPLB Thomas, Brian

NRC/RES/DET *Vora, Jit

NRC/NRR/DRIP/RLSB Wang, Hai-Boh

NRC/NRR/DE Wichman, Keith

NRC/NRR/DE/EMEB Wu, Cheng-Ih

NRC *Zimmerman, Roy

NUS Info Services Willbank, Charles

NNECO Watson, Bill

PA DEP BRP Dyckman, Dennis

PECO Energy *Patel, Erach

PECO Energy Phillabaum, Jerry

PECO Energy *Polaski, Frederic W.

PENOL Ackerman, Mark

PPL Susquehanna Machalich, Gerard

Proto-Power Philpot, Lloyd E.

RG&E (Rochester Gas & Electric) Wrobel, George

Rockbestos-Surprenant Inc. Sandberg, Steve

Self Connor, Lynn

SNC Evans, William P.

SNC Ghosal, Partha

SNC *Mulvehill, Jeff

UCS *Lochbaum, Dave

WEPCO *Newton, Roger

Winston & Strawn Sutton, Kathryn
April 2001 A-5 NUREG-1739

A.3. EVALUATION AND DISPOSITION OF COMMENTS

Table A, at the end of Appendix A, contains comments provided by the participants at the

workshops. The column heading “Commenter and Affiliation” is primarily intended to provide the

source of the comment, meaning the individual and his/her affiliated organization that submitted

the comment. For example, Beedle-1, NEI, indicates that the comment was made by Mr. Beedle

of NEI and the “1” segregates this comment from all other comments made by that individual.

The abbreviations used in this appendix are listed in the front matter of this NUREG. This table

is sorted alphanumerically based on the name of the individual and the consecutive number

assigned to his/her comment.
NUREG-1739 A-6 April 2001

A.4. REFERENCES

American National Standards Institute (ANSI) Standard, B31.1 Power Piping Code.

ASME Boiler and Pressure Vessel Code, Section XI, Rules for In-Service Inspection of Nuclear

Power Plant Components, American Society of Mechanical Engineers.

Code of Federal Regulations 10 CFR, Part 2 – Rules of Practice for Domestic Licensing

Proceedings and Issuance of Orders, Subpart B – Procedure for Imposing Requirements

by Order, or for Modification, Suspension, or Revocation of a License, or for Imposing Civil

Penalties §2.206 Requests for action under this subpart.

Code of Federal Regulations 10 CFR, Part 50, – Domestic Licensing of Production and

Utilization Facilities, Appendix A General Design Criteria for Nuclear Power Plants.

Code of Federal Regulations 10 CFR, Part 50, – Domestic Licensing of Production and

Utilization Facilities – §50.21, Class 104 licenses; for medical therapy and research and

development facilities.

Code of Federal Regulations 10 CFR, Part 50, “Domestic Licensing of Production and

Utilization Facilities” – §50.49, Environmental qualification of electrical equipment important

to safety for nuclear power plants.

Code of Federal Regulations 10 CFR, Part 50, “Domestic Licensing of Production and

Utilization Facilities” – §50.54, Conditions of licenses.

Code of Federal Regulations 10 CFR, Part 50, “Domestic Licensing of Production and

Utilization Facilities” – §50.55a, Codes and Standards.

Code of Federal Regulations 10 CFR, Part 50, “Domestic Licensing of Production and

Utilization Facilities” – §50.59, Changes, tests and experiments.

Code of Federal Regulations 10 CFR, Part 50, “Domestic Licensing of Production and

Utilization Facilities” – §50.61, Fracture toughness requirements for protection against

pressurized thermal shock events.

Code of Federal Regulations 10 CFR, Part 54 - Requirements for Renewal of Operating

Licenses for Nuclear Power Plants, §54.21, Contents of application – technical information.

Code of Federal Regulations 10 CFR, Part 54 - Requirements for Renewal of Operating

Licenses for Nuclear Power Plants, §54.31, Issuance of a renewed license.

NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 – The

License Renewal Rule, Revision 2, August 2000 (http://ruleforum.llnl.gov/cgibin/downloader/rg_lib/123-0118.pdf).

NRC Draft Standard Review Plan for the Review of License Renewal Applications for Nuclear

Power Plants (SRP-LR), August 2000

(http://www.nrc.gov/NRC/REACTOR/LR/IRG/SRP/srp.html).

NRC Generic Aging Lessons Learned (GALL), Dec. 6, 1999 Draft Report, NRC/NRR

(http://www.nrc.gov/NRC/REACTOR/LR/index.html).
April 2001 A-7 NUREG-1739

NRC Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities,

November 23, 1988.

NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related

Equipment, July 18, 1989.

NRC Generic Safety Issue 190, Fatigue Evaluation of Metal Components for 60-Year Plant

Life, September 1995.

NRC Official Transcript of Proceedings, Public Meeting License Renewal Workshop.

(http://www.nrc.gov/NRC/REACTOR/LR/IRG/workshop0925.html).

NRC Organizational Abbreviations (http://www.nrc.gov/NRC/PHONE/org.html).

NRC Regulatory Guide (draft) DG-1104, “Standard Format and Content for Applications to

Renew Nuclear Power Plant Operating Licenses,” August 2000.

NRC Regulatory Guide 1.54, Rev. 1, Service Levels I, II, and III Protective Coatings Applied to

Nuclear Power Plants, U.S. Nuclear Regulatory Commission, Rockville, MD, July 2000.

NRC Regulatory Guide 1.84, Design and Fabrication Code Case Acceptability – ASME Section

III, Division 1, May 1999.

NRC Website License Renewal Section (http://www.nrc.gov/NRC/REACTOR/LR/index.html).

NRC/NRR Office Letter No. 805 “License Renewal Application Review Process.”

NUREG/CR-6490, Vols. 1 and 2, Nuclear Power Plant Generic Aging Lessons Learned

(GALL), December 1996.

NUREG-0544, NRC Collection of Abbreviations, Rev. 4

(http://www.nrc.gov/NRC/NUREGS/SR0544/R4/index.htm).

NUREG-1275, “Operating Experience Feedback Report,” U.S. Nuclear Regulatory

Commission, Air System Problems (Vol. 2) December 1987.

NUREG-1275, “Operating Experience Feedback Report,” U.S. Nuclear Regulatory

Commission, SWS Failure and Degradation in LWRs (Vol. 3) December 1987.

NUREG-1611, Aging Management of Nuclear Power Plant Containments for License Renewal,

September 1997.

NUREG-1705, Safety Evaluation Report (SER) Related to the License Renewal Application of

Calvert Cliffs Nuclear Power Plant Units 1 and 2, Prepared by David L. Solorio, March 1999

(http://www.nrc.gov/NRC/REACTOR/LR/CALVERT/SER/).

NUREG-1723, Safety Evaluation Report related to the License Renewal of Oconee Nuclear

Station, Units 1, 2 and 3, March 2000

(http://www.nrc.gov/NRC/NUREGS/SR1723/index.html).

NUREG-1801, Generic Aging Lessons Learned (GALL), U.S. Nuclear Regulatory Commission,

July 2001.
NUREG-1739 A-8 April 2001

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April 2001 A-9 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Audience participant-1, Anonymous 40 [Inaudible] I wondered what kind of results you mean. Sometimes the results, types of programs, listed in the GALL report have to be plant-specific. The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

acceptable way to for license renewareference GALL in further review by propose plant-spestaff review in its application. If therprogram that maneffect then the GAthe required progrwith an evaluation The GALL report address this comm

Audience participant-2, Anonymous 56 (Inaudible) Could NRC inspection reports be used as a reference in a license renewal application? The basis for this comment is contained in and around the denoted transcript page (T-pg). Referencing inspe

evidence of NRC may be difficult bereports generally the licensing basisrelevant NRC exppurpose and operprogram, then the adequate as a refThe GALL report result of this comm
NUREG-1739 A-10 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Beedle-1, NEI 12 It is not clear to NEI how the attributes (10 elements of a program) will be derived, what process controls will be utilized to prevent attribute creep or attribute shrink, and how stakeholder disagreements over the scope of these attributes will be resolved. The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

the attributes of emanagement progrecommends wheshould be augmeoversight will be tcontrol to prevent creep or shrink by from the NRC stachange in the GAapplicant must proeither changes fronew programs prorenewal applicatioIf disagreements program cannot bdisagreement can accordance with tbetween the NRCSteering CommittRenewal Working 9/29/00 and 12/9/is being incorporarevision of NRR O“License RenewaProcess.” The GALL report address this comm
April 2001 A-11 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Beedle-2, NEI 13 GALL evaluates the adequacy of existing programs and identifies where enhancements are needed. Since 85-90% of the programs credited in the Calvert Cliffs and Oconee applications were existing programs that did not require enhancement, NEI would expect this result to be reflected in the GALL. Thus the focus should be on program enhancements and new programs for the remaining 10-15%. This will ensure that the license renewal complements the extensive review conducted to assure compliance with the current licensing basis (CLB). The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

of structures, systand an evaluation management progreferencing the Gbounding, the NRproposed programare augmentationGALL report or nereport and SRP aindividual insights reviews of Calvert The GALL report revised to address 

Bowman-1, CNS 54 Why did NRC not adopt what is already an existing aging management program for coatings inside containment as opposed to a brand new one? The basis for this comment is contained in and around the denoted transcript page (T-pg). NRC adopted the 

Guide 1.54 becauthe original versiohas no objection tsupported in the oregulatory guide. the original versiosupporting standaThe GALL report this comment by aoriginal and curreregulatory guide t
NUREG-1739 A-12 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Bowman-2, CNS 61 Many programs in Section 11 can be considered common or generic programs. One of the difficulties is the lack of a unique identifier for each row. When I am writing up a program evaluation, and I am trying to say it applies to B1.1 and I have about 10 or 12 rows that have that, I then have to not only add that it is B1.1, I have to in some cases add that it is for carbon steel with steam and for a particular aging effect. The basis for this comment is contained in and around the denoted transcript page (T-pg). A unique identifie

conjunction with ethe GALL report in traceability when particular line item The GALL report address this commwas further subdivsubsection of a chunique, numericaparagraphs with dmatters. Bowman-3, CNS 153 The GALL report takes two approaches in regard to non-service-level one coatings. Cranes fall as one approach for coatings, whereas for service-level one, two, three, for other coatings, it takes a different approach. The approach for cranes appears more straightforward and more realistic in terms of the desired objective; i.e., protecting the substrate. Perhaps it would be better to give more credit for the existing Reg. Guide 1.54 1973 programs, and if there are deficiencies that need to be addressed to take credit for that, that would be an improvement to allow either way, either version of Reg. Guide 1.54 to be credited. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC dispositBowman-1 in this .
April 2001 A-13 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Bowman-4, CNS 155 When you get into a sub-tier of ANSI standards, ASTM standards and so forth, there are substantial differences between the two versions of the Reg. Guide, This puts the applicant in the mode of trying to reconcile and separate the aspects that are really important to service-level-one coatings and not important to other non-containment coatings. It becomes a major bookkeeping exercise with the result of ending up at the same end point – that is, that either program is probably acceptable. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Bowman-1 in this 

Bowman-5, CNS 163 Sometimes credit may be mis- assigned (such as crediting the chemistry program for doing things that the chemistry program really doesn’t do). In GALL, the chemistry program includes a one-time inspection element. The plant chemistry people own the chemistry program, but they don’t own the inspection program; at plants, it’s hard to get people to think across their borders. In the SRP-Appendix A, four different types of aging management activities are presented (prevention, mitigation, condition monitoring, and performance monitoring). There are cases where, when you look through GALL, you find yourself trying to shoehorn all 10 elements around a particular activity, where some of those elements really don’t apply. So, for example, for a chemistry program, The basis for this comment is contained in and around the denoted transcript page (T-pg). Appendix A of the 

acceptable AMP telements. An appexception to one oelements of a proand provide justifiapplication. In somreport, more than required to managmechanism in a sthose cases, each other, and the comsingular program the SRP. The NRthere is any added classifying each pcategories identifiSRP since the ten typically describe characteristics of categories.
NUREG-1739 A-14 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Bowman-5, CNS (cont.) I think if you characterize the program as the type of program that it is, that would be helpful, identify the chemistry program, this is a mitigation program, and these other – and also think about what of those 10 attributes really are essential for certain of these types of programs and aren’t essential for certain of these types of programs. For example, the trending – for a preventive program, trending really isn’t very meaningful, whereas for a condition-monitoring program, it is very meaningful. The GALL report 

existing AMPs annecessary. Consisit was determined and one-time inspseparate aging mThe GALL report to address this issfor this comment. Chang-1, CES 43 In this process of preparing the GALL report and soliciting comments, were any efforts made by the NRC to have foreign utilities review and comment on it [inaudible]? The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC did not GALL and SRP frbecause typically licensing periods Some countries reevery ten years, tnot have materialbeen considerable development of thshared it with mancolleagues but did international publidocuments. The GALL report address this comm
April 2001 A-15 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Chang-2, CES 94 For those plants that apply for license renewal, most of them have already been operated 20, 25 years, so that’s one of the main reasons they apply for it. In those 20, 25 years, they have monitoring programs, they have cycle counting, so they know exactly what happens in the past 25 years (and probably different from the design trending conditions). For license renewal, is the applicant supposed to evaluate the fatigue impact on their plants, based on a combined operating for the past, design for the future, or should the applicant evaluate operating in the past and extrapolate for the future? What exactly are the monitoring requirements for a plant to comply with the GALL report? The basis for this comment is contained in and around the denoted transcript page (T-pg). Fatigue is to be a

as a time-limited aaccordance with 1license renewal, tmaintaining the cufor the fatigue usa10 CFR 54.21(c)(1. The current TLAextended operatioconservative estimcycles. Compare number of cycles component’s oper2. Project the usabased on operatinthe operating histo3. Monitor the usaactual and design extended period abasis to determine be adequately madiscussed in Chapreport. The GALL report address this comm

Chang-3, CES 95 Can the three ways listed in 10 CFR 54.21(c)(1) be used to handle the fatigue part of the license renewal? Do you need to revise the design transient documents or type in specifications on them, or do you just say this demonstrates operability for 60 years? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

2 in this Table A.
NUREG-1739 A-16 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Chang-4, CES 96 At many plants, there is no fatigue design basis in the licensing basis because they are 31.1 plants. Do you have extra requirements for those plants that are 31.1 plants? For critical locations, what are the requirements in regard to fatigue? The basis for this comment is contained in and around the denoted transcript page (T-pg). Plants licensed pr

are not required to but must still meecriteria for bendinthe 7000 thermal An applicant shouSafety Issue (GSIenvironmental efffatigue critical locThe GALL report address this comm

Chang-5, CES 97 Regarding the 7,000 cycles you mentioned, those are based on the test results and so on and so forth. Now, if I have a transient that only has 200 cycles, can I increase the number of allowable cycles, or can I increase the allowable stress, since there are fewer cycles? The basis for this comment is contained in and around the denoted transcript page (T-pg). The allowable stre

stress in ANSI B37,000 thermal cychundred actual thduring the current extrapolation woucycles would not byears. The GALL report address this comm
April 2001 A-17 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Chang-6, CES 180 The code editions and addenda are beyond the GALL report. The code edition addendum is a generic issue, and should be considered by ASME to any application or by ACI by any application. GALL should describe a general methodology defining conditions or situations where codes of different edition and addenda can be used to replace the GALL-based code base or the plant design basis code base. If you meet those criteria, then we do not object to a different code edition or addenda. For instance, in the ASME code itself, early codes don’t have that high-cycle fatigue. So, for all those infinite cycles, for those flow-induced vibrations, you cannot evaluate. Old plants are designed to one code. You have to use ASME code for doing any fatigue evaluation or assessment. The NRC Reg. Guide 1.84, issued periodically – always tells you what code edition and addenda and code case are approved by the NRC. Those are the basis of using different code base edition, addenda for any evaluation, and the GALL report, GALL evaluation should not be different from that. The basis for this comment is contained in and around the denoted transcript page (T-pg). The intent in the G

a particular code, section, and proviallow an excerpt orequirement to starevision of the codtaken from. An apthe latest revision with the excerpt ocomparison providto determine if the report is still bounthe latest code revThe Commission endorse the ASMthe GALL report wfuture editions of tapproved by the Nperform an evaluarevisions as part orulemaking. This determine the adewith respect to the evaluation describThe GALL report address this comm

Danstanger-1, Hopkins & Sutter 127 How will the new risk-informed Part 50 be incorporated into license renewal? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

in Table C of this 
NUREG-1739 A-18 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Kunsemiller-1, AEP 47 How does the GALL report differentiate in its applicability and treatment of plants constructed before and after the General Design Criteria of 10 CFR 50, Appendix A was invoked? The basis for this comment is contained in and around the denoted transcript page (T-pg). GALL was drafted 

management of Senvironments irreof a plant. For insof older plants maparticular SSCs ncould be done, fothat, per CLB, parintended functions if aging effects wecontrolled. The GALL report address this comm

Lochbaum-1, UCS 15 Does the draft GALL report provide sufficient credit for existing aging management programs? Is the adequacy of existing programs being ensured? The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

of existing AMPs recommends augprograms to adeqaging effects. An credit in his applicexisting programs only limited review must demonstrate assurance” that naugmented prograevaluated in the Geffective in managstructures and coof extended operaThe GALL report address this comm
April 2001 A-19 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-2, UCS 16 There are clearly times when one-time inspections are warranted. However, the adequacy of these one-time inspections will be in question for some time into the future until some of them are actually implemented. The basis for this comment is contained in and around the denoted transcript page (T-pg). Both Calvert Cliffs 

one-time inspectioplants had rigorouprograms, the onedesigned to examsusceptible to creand to confirm the chemistry control aging. A one-time to verify if an aginadequately managaction to take wheuncertainty about progression of the The GALL report address this comm

Lochbaum-3, UCS 17 There seem to be mechanisms for shrinking the level of effort in the GALL report, but not mechanisms for increasing its scope. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Lochbaum-1 in thdemonstrated adereview of applicanSee NRC disposit1 in this Table A oensure integrity of The GALL report address this comm
NUREG-1739 A-20 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-4, UCS 17 Are the efforts of the group formerly known as AEOD (NRC Office for Analysis and Evaluation of Operational Data) factored back into the GALL report? Is there another group that continues the efforts of AEOD or some other means to factor in lessons learned from plant operation into the license renewal effort? The basis for this comment is contained in and around the denoted transcript page (T-pg). Significant safety 

issues of the AEOlong-lived passive structures have bGALL report. 1. The majority of safety and generic system operations components. Few with the aging asppassive compone2. The significant generic issues idehave been addrescommunications, The generic commreviewed by ANL, GALL report. 3. Many former Ain the RES review They are either auor are aware of Arelevant to their sThey have factorereports into their rthe AEOD ReportSWS Failure and was addressed in one of the authors 96-02, Assessme

was assigned to rChapter VII spent Ornstein, the authVol. 2, Air System the GALL report csection.
April 2001 A-21 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-4, UCS (cont.) The Office of NRC 

monitor operating and will continue tlicense renewal areport was not revcomment. Lochbaum-5, UCS 17 The actual feedback on implementation of aging programs will not occur until plants begin operation in the extended period. Will preliminary feedback be factored in from renewal applications approved to date, Calvert Cliffs and Oconee, which are not real road tests of success of the license renewal process, to decrease the scope of the GALL report or to make it less conservative? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Lochbaum-1 in thpurpose of the GAThe staff positions reviewed have beinto the GALL repto make the GALL conservative. Aftelicense for extendwill be subject to toversight as undeThe GALL report address this comm
NUREG-1739 A-22 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-6, UCS 18 The license renewal applications submitted to date do not seem to provide adequate information for the ten elements in every case as required by the SRP, Appendix A for the aging management programs. The basis for this comment is contained in and around the denoted transcript page (T-pg). Current experienc

elements are founbut sometimes theelement does not program, Chapter identifies it. The tepresent in an effeindividual programnot have all ten elsynergy between applicant should icombination of ageffective so as to assurance that agadequately manaIn addition, the SRbut a guidance doinformation to facThe GALL report this issue, but not comment, by modevaluations in Chreport as appropradequate informa

Lochbaum-7, UCS 19 The NRC staff stated previously in written correspondence that IPE submittals for GL 88-20 are obsolete or out of date. However, page 2.1-3 of the SRP still requires their review as part of NRC staff review of scoping and screening methodology of an application. The basis for this comment is contained in and around the denoted transcript page (T-pg). IPE submittals for 

considered only oare reviewed to hunderstand the fusystems, structurescoping purposesThe GALL report address this comm
April 2001 A-23 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-8, UCS 43 Will the guidance documents - the GALL report, SRP, and draft Reg. Guide - be the vehicles for communication to the public or will something else be provided that is more easily understood by the general public? The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC envision

documents as beiof communicating license renewal pform, these docummore for practitionconsidering whethsummary form of general public as activities. The license renewwere not revised tcomment.
NUREG-1739 A-24 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-9, UCS 71 The guidance documents submitted for formal review and made available to all stakeholders were modified during the review period without communicating to all stakeholders (“bait and switch”) either in the Federal Register or other means the reasons for and types of changes being made. The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC has refo

report to make it eand use. The subinformation providexpected to changreformatting. If the comments on infochanged, the NRC comments would changes. The tabwere reformatted information in coluComponent” and a column titled “SComponent” and Effect” and “Aging column “Aging Effaddition, the staff information in colu“Evaluation and TChapter XI under management progreferences in tablprograms. The GALL report address this comm
April 2001 A-25 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-10, UCS 73 Only one hour of the September 25, 2000, agenda is focused on the Federal Register notice that the public has to comment on. The bulk of the meeting concerns topics that aren’t officially out for public comment. The basis for this comment is contained in and around the denoted transcript page (T-pg). Guidance docume

were officially madpublic with no concomments that cospecifically asked Notice for input on important to the cconfidence in thesThis NRC workshwere open to the tried to be very opcommunications tThe GALL report address this comm

Lochbaum-11, UCS 125 There is a move afoot to move towards a risk-informed regulation, and 50.49 is one of the target regulations. Assuming that move continues on and makes some progress and things actually happen, is the implication to have two GALL reports? A GALL report for the risk-uninformed plants, and something like a “GALL-lite” for the risk-informed plants? How do you foresee handling that situation? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC dispos

in Table C of this 
NUREG-1739 A-26 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-12, UCS 140 NRC did not refer to or address in this workshop the petition for rulemaking submitted by UCS. What is the current status of that petition for rulemaking? The basis for this comment is contained in and around the denoted transcript page (T-pg). The request for ac

10 CFR 2.206 waof the Edwin Hatcits design and licegaseous radioacticopy of the Final D00-05, ADAMS asML003758416) in was filed with the October 18, 2000 25 days from that November 22, 200The GALL report address this comm

Lochbaum-13, UCS 155 If an applicant submits an application, relies on GALL and meets all 10 attributes without exception or variation, the NRC approves the license and the SER cites reliance on meeting GALL. Does NRC view that, then, as a licensing commitment that requires prior approval, review and approval, if any changes are made by the licensee to how they do aging management in that area? The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC views it 

as part of the licenrule requires a suprograms in the Fchange in this liceCFR 50.59 procesIf a license conditchanges to it requNRC. The GALL report address this comm

Lochbaum-14, UCS 156 If the applicant later changes the procedure for addressing aging management, is it necessary to return to NRC for further evaluation? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Lochbaum-13 in t
April 2001 A-27 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Lochbaum-15, UCS 185 Since in the single-page format adopted, the reference column was deleted altogether, would not any discussion about references become a moot point? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Lochbaum-9 in thThe reference colversion contains rthat is already concolumns in the GAinformation was na more central locreport. Therefore, was deleted in the GALL report. A citation to a codapplicable is in thManagement ProChapter XI of the actual references for a specific AMP end of each AMPThe GALL report address this comm

Menocal-1, Florida Power and Light 63 The latest version of the draft GALL included a new section for carbon steel external surfaces for steam and power conversion, aux systems normal engineered safety feature (NESF), yet it looked like in some cases external surfaces were also addressed within the body of the sections. Was the intent to have that new section address all the external surfaces for each section of the GALL? The basis for this comment is contained in and around the denoted transcript page (T-pg). The intent of the l

Chapters IV, V, Vcarbon steel extercover all carbon sthose respective cwas done to compcarbon steel exterlisting each compfurther evaluationThe GALL report address this comm
NUREG-1739 A-28 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Menocal-2, Florida Power and Light 118 Is crevice corrosion one of the mechanisms that are of concern with respect to adequacy of existing chemistry programs and can it be detected and verified by one-time inspection in accordance with GALL? Is a corrective action program with root cause identification a suitable substitute for a one-time inspection? The basis for this comment is contained in and around the denoted transcript page (T-pg). Crevice corrosion 

of concern in certsystems, and comenvironments. Onprogram to controaging effects as pchemistry program one-time inspectioinspection, conduof the current liceeither the presenccorrosion and is imnondestructive evAny corrosion detcorrective actions necessary. Any pverifies that corrosnot can be creditealternative. The GALL report address this comm
April 2001 A-29 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Menocal-3, Florida Power and Light 119 Will the absence of symptoms of aging mechanisms such as crevice corrosion, based on a one-time inspection, appropriately permit the conclusion that a problem does not exist? Certain other aging effects may be found other than the specific effects for which the inspections were initiated. The basis for this comment is contained in and around the denoted transcript page (T-pg). The one-time insp

confirm either the slow progression an innocuous effecorrosion detecteacceptance criterialone aging manaprimary aging mawhich the one-timvalidate as perforstill be in effect evdetected to ensurmanagement of thAn applicant woullook for as many aeffects/mechanismapplicable in a spinspection. The GALL report address this comm
NUREG-1739 A-30 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Mulvehill-1, Southern Nuclear 126 Can an applicant just select the more economical option three, 10 CFR 54.21(c)(1)(iii), or will he have to update the EQ calculation? The basis for this comment is contained in and around the denoted transcript page (T-pg). An applicant is all

option listed in 10 which means the the ability to manathe electrical comrenewal period unprogram. This allodelay the decision update the EQ cathose components renewal period in qualification underenewal period. The GALL report address this comm

Newton-1, WEPCO 100 For the reactor vessel, could a program like the Master Curve Approach be included in the GALL report, and how can programs like that be recognized in the GALL report as acceptable? The basis for this comment is contained in and around the denoted transcript page (T-pg). Any program like 

Approach can be GALL report if deenature and if apprSpecifically, for thApproach, a rule cbe needed. To usApproach instead in the pressurized rule in 10 CFR 50be granted in the long term, there wchange in the 10 The GALL report address this comm
April 2001 A-31 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Newton-2, WEPCO 102 What if a utility came in, and in their application, referenced specifically planned future use of the Master Curve. How would that be reviewed and assessed as an acceptable aging management program? The basis for this comment is contained in and around the denoted transcript page (T-pg). The Master Curve 

licensing renewal would have to me10 CFR 50.21(c)(have to show that technology, the scbasis for the PTS met. The staff wothe Master Curve used and how it worder to review it aging. The GALL report address this comm

Newton-3, WEPCO 103 If existing rules were used and a reactor vessel only meets the screening criteria for some arbitrary number (say 55 years) and the applicant intends to apply the Master Curve Approach, before that time period expires; -- how would that program be reviewed and accepted? The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC would n

license to require adequate reactor 55 years. The GALL report address this comm

Newton-4, WEPCO 104 The NRC has accepted TLAAs where the analysis was not valid for the entire 60 years for license renewal applications already granted. So why would the NRC not accept a TLAA for the reactor vessel if the analysis similarly was either not valid for or had not been projected to the end of the period of extended operation? The basis for this comment is contained in and around the denoted transcript page (T-pg). If an analysis is n

for the entire 60 yrequire reasonableffects are being the entire extendeanalysis is updatethe burden under to demonstrate thThe GALL report address this comm
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Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Newton-5, WEPCO 109 One vision of the future with respect to reactor vessel internals is that applicants can learn from each other’s inspections, and show their applicability to similar plants. Is that vision shared by the NRC? The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC looks fo

the staff’s review relies on generic eefficiency of that ropen to increasing GALL based on thinspection and resperformed by appplants with renewparticipating in indworkshops to shaexperiences. The result of these indapplicants and holicenses will propoprograms and posGALL report. With mechanisms and unclear when they regard to impedinNRC’s experience programs, inspectinsights will providThe GALL report address this comm
April 2001 A-33 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Newton-6, WEPCO 142 Is it correct that the SRP causes an examination of what is not in the scope? Is it clear that the applicant knows what NRC staff is looking for during site visits when NRC staff want to confirm what’s in and what’s out of scope in the SRP? The basis for this comment is contained in and around the denoted transcript page (T-pg). The rule requires 

a screening and sthat will ultimately that are and are nvisits the site to uapplicant’s scopinprocess and makiconsistent with thrule. The NRC firsthe applicant’s mereviews the SSCs as being in scope methodology. The guidance for the sapplicant’s methoresults. The SRP was not comment.
NUREG-1739 A-34 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Newton-7, WEPCO 182 Codes and standards very seldom make up the entire 10 set of attributes that we use in a program; they could be used for an inspection technique, scope definition, etc. So, when the NRC looks at what we’ve referenced from a code or standards standpoint, they really look at what attribute it’s trying to satisfy in a program. Once you’ve accepted that code and standard in that program, we can then use that as a guide to say we are equivalent or better to that. I anticipate that you’re going to look at the standard and say, for this attribute, it’s all right in that one, then we can use that in the future, and once you’ve blessed it for that, we can use that as the process by which it gets approved. The basis for this comment is contained in and around the denoted transcript page (T-pg). Usually, the NRC 

standards for cert– scope, method, features of an agiprogram. The objemaximize the efficdefining an attributo give maximum SRP in Appendix elements (attributmanagement progtypically only the mattributes require established from a up to the staff to dassigned to each regard to managinand mechanisms. The GALL report address this comm

Newton-8, WEPCO 187 If the applicant does not justify, in its application, the omission of any aging effects identified in the GALL report, that the applicant has determined not to be applicable will the applicant get an RAI (Request for Additional Information) asking it anyway? The basis for this comment is contained in and around the denoted transcript page (T-pg). If an applicant doe

applications instabounding, the stafreview on those aobjective is to alloprograms that adeeffects. If that stanshould be issued fully understand thprograms proposeThe GALL report address this comm
April 2001 A-35 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Patel-1, PECO Energy 32 How will the GALL report be used in the future? Is NRC planning to revise the GALL as more plants apply for license renewal? The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

on experience; futwould address the experience. The Nopportunities to foon unique aspects efforts to increase review. The staff plicense renewal gcapture additionafuture reviews and However, the schnot determined. The GALL report address this comm
NUREG-1739 A-36 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Patel-2, PECO Energy 46 There seems to be some inconsistency in guidelines in different sections of the SRP corresponding to the GALL report – is the intent to include the 10 attribute table or is it just a three line or a four line statement? The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

an applicant can mapplication to focuevaluation of planexceptions to the referencing the Gbounding, the appvolume of the apptime of the staff. Tany exceptions to be in tables, footnseparate section iof the application. would include only AMPs that are eitspecific as the casapplication with thsupporting informapplication, boundauditable form at Safety Analysis Rsupplement that is application may tafor both componemanagement progChapter 3 of the Sthose components those in the GALL components are aapplicant must, as denote somewherinclusion of those The GALL report address this comm
April 2001 A-37 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Patel-3, PECO Energy 50 When the word “program” is used, many plants don’t necessarily have what could be considered a full-fledged program in all cases. For example, the mechanism a plant uses to meet the intent of GL 89-13 (Service Water System Problems Affecting Safety-Related Equipment) may be a series of activities. One of the NEI’s previous comments was to call these “aging management activities” rather than “aging management programs.” Clarify what is considered an aging management program. The basis for this comment is contained in and around the denoted transcript page (T-pg). There is no distinc

“program” and “acreport. A program elements as stateSection A.1.2.2. aGALL report, and must be justified bevaluated by the s“existing programmultiple purposes of program used hmanaging aging eThe GALL report address this comm

Patel-4, PECO Energy 63 The 2-pg format in the August 2000 draft of GALL had the effect of sometimes carrying over an extensive write-up of the 10 elements for the AMPs. This would be displaced to a location in the table that would be two pages away (leaving the left side of the page blank when there was no change in line item). This made the tables sometimes difficult to read. The basis for this comment is contained in and around the denoted transcript page (T-pg). The tables in vario

now refer to the aprograms in Chapreport. Thus, this descriptions extenwas eliminated. The GALL report this comment by pChapter XI of the the various line ite(Chapters 2 throuManagement Prothose AMPs.
NUREG-1739 A-38 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Patel-5, PECO Energy 75 When NRC said ‘scoping questions’ does this focus only on systems and components or does this also include aging effects? If I don’t have an aging effect, then I don’t need to manage it. Do I need to explain it in my application? The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

independent of thGALL report is a gaging managemecomponents in spThe inclusion or eGALL does not dibe included or excapplication. Thus, effect or mechanissimilarly. The GALL report address this comm

Patel-6, PECO Energy 76 If the GALL report calls out an aging effect or an aging mechanism for a certain material and component, and an applicant determines that this is not relevant to the plant, is it necessary to explain why it is not applicable? The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

of aging managemnot a scoping docrequired to identifcomponents that athe 10 CFR 50.54 For the GALL repprograms for partidentified and justThe GALL report address this comm
April 2001 A-39 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Patel-7, PECO Energy 108 If the applicant has the BWR VIP program with an SER for license renewal, will this be recognized in GALL Chapter XI “Aging Management Programs?” If a relevant AMP is included in GALL Chapter XI, then aging effects considered by the BWRVIP, will be covered. At present, this information is absent. The basis for this comment is contained in and around the denoted transcript page (T-pg). All aging manage

placed in GALL Cpresent this guidaprovides a user-fran easier format tXI, Sections M1 (AInservice InspectiIWC, and IWD), XAttachment WeldsCorrosion CrackinHead Penetration(BWR Vessel InteBWRVIP guidancA new AMP, XI.MInternals), was draGALL, Chapter XIManagement Proreferences the BoVessel Internals PThe GALL report this comment and comments by placmanagement progbasing several agprograms in part o
NUREG-1739 A-40 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Patel-8, PECO Energy 185 The GALL report provides too much detail on ASME Section XI in the evaluation basis, right down to the category level; with the new codes coming out, with the new editions coming out, those categories would change. The Gall report still lists references down to the category level for the ‘89 version of that code. Some plants have already switched to the ‘95 version and some categories have changed. So, even though we meet the intent of the GALL and meet all the attributes, we still cannot say we meet all of the requirements of the GALL, because the categories have changed. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

6 in this Table A iGALL report for nrevisions. Polaski-1, PECO Energy 51 From a license renewal perspective, many plants that have plant-unique configurations may be placed at a disadvantage. It would be better if the GALL report does not become so overly-prescriptive that it does not allow for existing plant-specific exceptions for those programs that have been in place at plants for years. The basis for this comment is contained in and around the denoted transcript page (T-pg). If a program was conformance to a position, standardexceptions noted) in that plant’s CLB evaluated by the Nshould make a stathe application. If other than the excrenewal, the staff impact of the exceThe NRC staff maexceptions to progdetermine the apprenewal. The GALL report address this comm
April 2001 A-41 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Polaski-2, PECO Energy 87 Containment and inspections – Is there any reason that an applicant couldn’t just cite his inspections that he does in accordance with IWE, IWL, which are mandated by regulations and acceptable programs? But when the NRC promulgated that rule, they found that it was an acceptable aging management program for current-term and the renewal term. So the question is, why do we need to do more than what’s currently mandated by regulation for renewal term? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Walters-8 in this T

Polaski-3, PECO Energy 88 The NRC, for licensing renewal, requires inspections in inaccessible areas with no presence of corrosion in accessible areas. This seems counter to some current regulations. The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC, in conju

has proposed accaddressing inacceExceeding the critdenote the preseninaccessible areaacceptance criteriinspection of thoswill be performedThe GALL report this comment by iXI.S1 (ASME SecIWE) and XI.S2 (ASubsection IWL) iacceptance criteri
NUREG-1739 A-42 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Polaski-4, PECO Energy 148 What is the significance about the maintenance rule for scoping mentioned earlier in the public workshop? It ought to be fairly easy and straightforward to take the maintenance rule answers which were developed under regulation and just apply them to license renewal. The basis for this comment is contained in and around the denoted transcript page (T-pg). The intents of the 

and the maintenathat they both veraging on functionaadequately manahas determined thrule should credit maintenance rule scoping for most SThis is in accordaprinciple of licensreliance on the cuto protect the pubexcept for age-relissues. Thereforeexercise credit for SSCs and programaintenance rule compliance with tto the extent possguidelines of licenThe GALL report address this comm
April 2001 A-43 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Polaski-5, PECO Energy 157 A general concern is that the plants that are going through license renewal right now are some of the original plants that were licensed, and a lot of the programs that are credited in GALL are written from the viewpoint of latest, best industry standards that would be suitable to a fairly recent plant, like a Watts Bar or a plant like that, but have no applicability at all to the earlier plants; and so, some of the earlier plants are going to expend a great effort to try to use GALL to the extent that was hoped it would be. Part of the challenge will be to adapt GALL so that it reflects, justifiably, earlier applications for older plants which were accepted despite some disagreements with the presentation and aging management programs in the GALL report. The reason being is not to have subsequent plants of a similar vintage to submit applications and to have to revisit issues and concerns that were previously accepted by the NRC in some respect anyway. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

in this Table A.
NUREG-1739 A-44 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Polaski-6, PECO Energy 159 It is not clear that we will have the immediate increase in efficiency that some people hoped we would have, where it would have been. If I’m putting in an application two years from now for a plant that was built and the license will expire in 2012, I ought to be able to go right down the list and match up. I think you’re going to find there’s going to be some disparity. Maybe 10 years from now, when you’re talking about a Watts Bar and some of the latest plants, it should be very clear-cut that that process will go real easy. The basis for this comment is contained in and around the denoted transcript page (T-pg). If industry represe

applicants think thlimited in scope in presented, or in ththe evaluations of only to newer planinformed of such. this issue, but the envelope all plantbecause it would evaluation of aginprograms that apppresent and justify The GALL report address this comm

Robinson-1, Duke Energy 111 During the Oconee work, one-time inspections played a very important role for us, in that there were certain areas where we could not characterize the aging that was going on. We proposed one-time inspections as an opportunity to go in, look at the hardware, characterize what may be going on, and then determine if follow-up and more perpetual aging management programs were required. Could you address the characterization of aging, versus proving that an aging management program is effective? The basis for this comment is contained in and around the denoted transcript page (T-pg). NRC presented th

report that a one-tverification of an eprobably was adeaging effect, and tprograms or modiprogram, based otime inspections, question, but were The GALL report address this comm
April 2001 A-45 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Robinson-2, Duke Energy 112 The one-time inspections at Oconee were aimed at areas where no program existed or the aging mechanisms occurring could not be characterized. Using the water chemistry program as an example, after over 20-25 years of operating nuclear power plants with chemistry programs, if corrosion was going to occur in the systems in which chemistry is controlled then evidence of that would have been apparent by now. One-time inspections can be very valuable in helping you characterize things where knowledge of what prevailing synergistic effects are going to do to hardware is not available. But be careful when you’re including well established, and well run programs, like a chemistry program, for which additional sampling is not required, based on operating experience, into the bin of programs to be verified by one-time inspections. The basis for this comment is contained in and around the denoted transcript page (T-pg). One-time inspecti

“verify” that an agadequately manaprograms, if it is pslow-acting aging progress or no agobserved. Howevabout possibly lonlack of evidence aCorrective action operating experiebe used to initiate program. The GAneed for a one-timby-case basis. The GALL report address this comm
NUREG-1739 A-46 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Robinson-3, Duke Energy 146 The whole scoping methodology exercise seems to be evolving to the point of looking at what’s not in scope. There seems to still be a disconnect between the scoping phase and the aging management review phase of renewal. My first comment is that it seems there could be a more efficient way to get through that. The second comment is that we focus a lot of scoping on structures and systems. There’s the other aspect of commodity reviews that we do, sort of super-set reviews that we do at the aging management review level. The basis for this comment is contained in and around the denoted transcript page (T-pg). The reviews of an 

and screening mebecome more effiapplications are pknows what questexpedite the reviereasonable assuraeffects are being The GALL report address this comm

Robinson-4, Duke Energy 161 The write-up in the SRP and GALL on the words to be used in an applicant’s FSAR supplement may cause future applicants some concern. For Oconee we have included our FSAR supplement in our FSAR, and are trying to make sure we have procedures in place to maintain those words into the future. Reasonably specific information in a FSAR will be required in order to give guidance to future generations. Some of the words in the GALL and SRP are not specific and strong enough about their intent or meaning to prevent an applicant from changing the words in his FSAR at a later date to something that is less specific than originally intended. The basis for this comment is contained in and around the denoted transcript page (T-pg). The write-up in th

the FSAR supplemminimum informatpropose to include helps in maintainicommitment for its welcome any sugduring or subsequcomment period oguidance documeapplicants in the ftheir FSAR’s contsuggestions would order for the staff and make the necGALL report and tof the FSAR suppThe GALL report address this comm
April 2001 A-47 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Robinson-5, Duke Energy 173 If we meet some information in GALL, then we should take credit for it. A code or standard does not manage aging, but it’s the actions under the program that manages aging. A code or guidance document gives us some help in setting up that program, but we still have to do the program in-house. If our code or standard is a later version than the one referenced in GALL then we have to make sure that we’re doing the appropriate aging management task in-house. Referencing a code like 50.55(a) means nothing, it’s the program actions themselves that we have to justify so that you can make a judgment on them not the codes and standards. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

6 in this Table A..

Robinson-6, DukeEnergy

175 There are really two issues. One is

how you measure up to GALL andwhat happens if you want to use acode that’s outside of the particularrev that’s been described in GALL.That’s sort of an administrativeprocess you have to go through. Theother question is, once you’ve signedup for a program that has certainelements to it that will help youmanage aging, how do you, in asystematic way, begin to progress andmature beyond that?

The basis for this comment iscontained in and around thedenoted transcript page (T-pg).

See NRC disposit6 in this Table A freferences in the applicant’s applicato granting a reneThe process to chstandard after grarenewed license iprocess.The GALL report address this comm
NUREG-1739 A-48 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Robinson-7, Duke Energy 176 Being clear with what’s written in GALL, whether I agree with it or I want to take a deviation from it, you’ve got to be specific. You can’t just say an in-service inspection, but if you call out a particular type of volumetric inspection or a particular technique that you believe works or that you’ve seen in industry practice that works and you want to report that in GALL and I want to deviate from it, you have to be specific enough so I can know how to deviate. The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

of aging managemspecific materials environments. Thdescribes one accaging effects. An from any program reasonable assurof his program to also applies to the on which an aging is based. The NRcomments during comment period oGALL report to mevaluated them inadditional commeshould identify whlacks specificity. The GALL report this comment and comments by modGALL report.
April 2001 A-49 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Robinson-8, Duke Energy 191 When aging effects are identified in GALL, they should not be just someone’s perspective or experiences that can not be substantiated by operating experience or a legitimate reference document. An assertion based on some laboratory experience in graduate school but with no operating experience should not be allowed since there is really nothing for an objective reviewer to follow up on. A word search should be done to avoid using phrasing such as “based on staff experience, these effects occur.” The basis for this comment is contained in and around the denoted transcript page (T-pg). One of the eleme

programs is operaSRP, Appendix AGALL report, chapevidence why theprograms. The NRoperating experieGALL report objecsubjective viewpodeveloped a particsearch produced aging programs wsupported. In addany operating expquestioned based submitted. The GALL report address this comm

Rycyna-1, CNS 160 What are the expectations of those plants that have programs similar to those in the GALL report but for which it’s more effort to justify similarity with the GALL than to do the 10-point review and just ignore the GALL? The basis for this comment is contained in and around the denoted transcript page (T-pg). If the GALL report 

applicant can merreport. If not, an areasonable assuraa new or augmenparticular applicatThe GALL report address this comm
NUREG-1739 A-50 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Taormina-1, CNS 188 Can an applicant identify in GALL the appropriately corresponding system, components, with the same materials and environments and make the conclusion that it has the same aging effects and put that in his application? Is it acceptable to use the GALL as a basis for the aging effects requiring management for a particular system? I don’t feel I should have to address an aging effect that’s in the GALL if my own analysis shows I don’t require to manage that, unless you can let me use the GALL to draw those conclusions, in which case, if I need to dispute the finding in the GALL, I’d like to see those technical bases for those conclusions that are in the GALL. The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

document, and an reference it when bounding. The apresponsibility for ddefending what apand mechanisms plant. The inclusioSSC in the GALL that an SSC will bin the application. aging effect or metreated similarly. Fbe aging effects ospecific operating not be included in The GALL report address this comm

Taormina-2, CNS 190 It was our understanding that the GALL was really intended to describe how programs are adequate to manage aging effects for those particular systems and structures, not necessarily to describe which aging effects require management. We were just curious where the basis for those aging effects requiring management came from. The basis for this comment is contained in and around the denoted transcript page (T-pg). GALL is a generic 

management progmaterials in certaibasis for the descrequiring manageoriginal GALL repThis was a compraging effects basereview of operatinstudies. The GALL report address this comm
April 2001 A-51 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Walters-1, NEI 31 Implicit in many of the topics addressed today is how the Regional inspection process or program will be applied. If not already targeted as being addressed today, can you place it on the agenda for today? The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC anticipa

guidance documeinspection procedrefined slightly as processed. Preseare developed froreviews of scopinmethodology and programs, includinlicense renewal pof the extended panother inspection verify the status ocommitments or liidentified by applirenewal process. could evolve to a than the procedurproblem areas deexperience or stafinspections will foevidence for scopaging managemeauditable form at pursued, along wiunder the guidancheadquarters. The comments of a mthe inspection prorenewal contained chapters 2515 anThe GALL report address this comm
NUREG-1739 A-52 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

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Walters-2, NEI 66 How is the distinction between structures/components (one column in the August 2000 draft version of GALL) and regions of interest (adjacent column in the August 2000 draft version of GALL) handled in the revised 1-page format where the region of interest column is eliminated? The basis for this comment is contained in and around the denoted transcript page (T-pg). The GALL report 

into a single-page distinction betweecomponent” and “having a single coheading is “structuThe immediate enfor each line item component of conon that same line regions of interestThe GALL report this comment as s

Walters-3, NEI 67 Has the NRC ever considered adding a column for function? (If the purpose of the rule is to manage aging to ensure functionality, it is not clear how programs can be evaluated without considering function.) The basis for this comment is contained in and around the denoted transcript page (T-pg). The NRC has not 

“intended functionseveral reasons. Fseveral intended feffect and mechaeach. Listing all thwould unnecessaof the GALL reporfunctions are planincluded, would fugeneric nature of The GALL report address this comm
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Walters-4, NEI 68 Has the NRC considered an approach that would start with the program first, specifically those where no further evaluation was required? The components would be defined for each program and then the GALL- type of format would be utilized for those programs that require further evaluation. This approach might be a more expedient way for the applicant to go through the process. The basis for this comment is contained in and around the denoted transcript page (T-pg). Generally, an app

determine what Sthe licensing renedetermines that, tpresents an undedetermining the efor a SSC and the applicant can follopresent his own. Isummary tables fosystems provide, the association beeffect/mechanismtype. Chapter XI oprovides a compilmanagement progThe GALL report address this comm

Walters-5, NEI 70 At this date, has it been determined that the final version of GALL will be reformatted or are you considering this and looking for input? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Lockbaum-9 in thThe GALL report to address this issfor this comment. Walters-6, NEI 77 The SRP seems to describe a methodology of how to evaluate scoping and it really focuses on proving the negative. The licensee has to defend why something wasn’t in the scope. Although separate from GALL, it seems to be a logical extension that the staff reviewer may ask why wasn’t something in scope that was included in the GALL report? The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC dispositin this Table A.
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Walters-7, NEI 81 By structural monitoring program, is it implied that an applicant can take credit for a similar program implemented under the maintenance rule? The basis for this comment is contained in and around the denoted transcript page (T-pg). An applicant can t

program meant fomaintenance rule reasonable assuris also applicable aging effects for tten elements presSRP, Appendix Astaff would review meets the criteria management progThe GALL report address this comm

Walters-8, NEI 90 The issue seems to be that the Agency looked at the 50.55(a) rulemaking to endorse IWE and IWL for containment inservice inspections, specifically with an eye to license renewal. I believe the statements of consideration indicate that they did that, and that they found it acceptable for the period of extended operation. On this issue, we’ve just been in quandary why, if that’s what the intent of the rulemaking was, is there now an exception to that to do something different? The basis for this comment is contained in and around the denoted transcript page (T-pg). The Statements o

(60 FR 22461; Ma50.55a rulemakinfor containment inThe Commission did not limit aging for containment foIWE and IWL. Agactivities including adequately manathey should be authat goal. The GAwith the 50.55a ruaging managemethat are not coverThe GALL report address this comm
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Walters-9, NEI 116 If a one-time inspection is performed for an area, as agreed in GALL, is it possible that this inspection could be done at a more opportune time (such as during an outage) either before or during the preparation of an application? Would this still qualify as satisfying that particular need? The basis for this comment is contained in and around the denoted transcript page (T-pg). A one-time inspec

the absence or prof corrosion. It maanytime in accordreport, Chapter Xit is before the expoperating period. inspection should the original licensThe GALL report address this comm

Walters-10, NEI 132 Do we have, collectively, any operating experience that shows that inaccessible cables are being degraded? Do we have any experience that suggests that those cables, the buried cables, in particular, are degrading? I guess the question is how aggressive do we have to be in going to look for this aging? An issue with the original rule was we shouldn’t have to speculate on what might occur. We ought to deal with what we know. The basis for this comment is contained in and around the denoted transcript page (T-pg). The concern is wi

the license renewenvironmental effand water), that csafe operation aftcables can be moand there is recenwith degradation wcables. The GALL report address this comm
NUREG-1739 A-56 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Walters-11, NEI 136 For EQ equipment, is there anything that precludes the staff from accepting an original analysis that shows that the equipment is good for 80 years or 100 years so that additional evaluation is not required every 20- year licensing renewal interval? The basis for this comment is contained in and around the denoted transcript page (T-pg). Environmental qu

license renewal rulimited aging analthree methods to adequate under thin 10 CFR 54.21(cmay show the origtime span exceedand one or more rSecond, the origininclude at least onoperation. Third, tthat the aging effecontrolled during toperation. Proceemethod to the last levels of evaluatiothe part of the staapplicant. Equipmfor more than one time, but an applicand the staff’s revas many renewal the TLAA evaluatThe GALL report address this comm
April 2001 A-57 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Walters-12, NEI 143 As a follow-up to the question about looking at what is not in scope, does the NRC actually approve the methodology? Unless you’re doing that review to somehow verify that I implemented an approved methodology satisfactorily, in which case I wonder why do you need to do that? The basis for this comment is contained in and around the denoted transcript page (T-pg). The rule requires 

a scoping and scrNRC approval. Thmethodology and if all within scope included. On-site to verify, on a samimplementation of methodology by psupporting documthe basis for his cin regard to scopiThe GALL report address this comm

Walters-13, NEI 167 The staff’s evaluation of an applicant’s program based on the required ten elements appears rather robust. The content of the programs in the GALL report does not seem to agree with that of the actual programs in the field. How do we come to closure on this issue about increasing the agreement between these two program descriptions? The basis for this comment is contained in and around the denoted transcript page (T-pg). See the NRC disp

Bowman-5 in TabIn addition, the NRcomments on the aging managemerevised the GALL However, each agprogram in the GAevaluated using thSRP, Appendix AThe GALL report address this comm

Walters-14, NEI 168 If the old program is okay and there is a new program that’s okay, shouldn’t we capture both in GALL, because there is a probability that a certain percentage of licensees will use the old program? Have you thought about that, to the extent that it provides The basis for this comment is contained in and around the denoted transcript page (T-pg). The staff focuses 

aspects in an appgeneric efforts boreport. The NRC igeneric aspects obased on the staffapplicant’s inspec
NUREG-1739 A-58 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Walters-14, NEI (cont.) sufficient credit? There’s probably other situations like that, where there’s a percentage of licensees who use a certain version or revision of a particular Reg. Guide or code. Older programs may be in place and may be just as acceptable as a newer program, and should we capture those in GALL? activities and whe

code or standard on an existing procase, the GALL reexpanded to incluold programs supor standard revisiadequately manaaging effects. Conexceptions to a Rposition, standardwith a plant’s CLB NRC document, sapplication, but onshould be revieweGALL report looks experience; future issued) would addexperience. The Nits research progrindustry insights wguidance as to whthe GALL report nThe GALL report to address this coreviews of other sdirectly as a resulDispositions of othprograms are prov
April 2001 A-59 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Walters-15, NEI 173 I think for the codes and standards that are not endorsed by 50.55(a), certainly you could evaluate those in GALL, and I believe that the applicant, certainly if they implement the version that was evaluated in GALL, has a straightforward job. If they’ve got a different revision that they’re using, then perhaps what they need to do is evaluate the differences and provide that in the application. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

6 in this Table A iincorporation of cthe GALL report oThe NRC has revCode Edition throagainst the ten eleAMPS where the Chapter XI of GALthe NRC has identhose items that aCode Edition throAddendum from tEdition in Chapter Any future revisiowill be evaluated described above. different version othan the one referreport, the applicadifferences and pin the application. The GALL report address this comm
NUREG-1739 A-60 April 2001 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Walters-16, NEI 178 There are two issues of concern. (1) If there are two acceptable existing programs, you ought to consider putting both of those in the 8/00 version of GALL. I’ll tell you where I differ, and you’re going to pass judgement on that and you’re going to give me a renewed license. (2) What happens if the ACI standard is upgraded or there’s a new ACI standard. I’ve got to go back and say have I changed anything between what the NRC approved for renewal and what this does, and I would probably argue that even on 50.55(a), the fact that you endorse it by regulation, I’m not sure I just go off and say I’m going to implement that version. Certainly if I took credit for it as an AMP, regardless of code edition, I don’t believe I’m going to be able to use that unless I go through the process of evaluating that new edition against what you approved in my LR application. If we’re aware of another program that’s older, that’s acceptable, we shouldn’t impose or make GALL appear to impose something newer merely because that’s what’s in place at the time. The basis for this comment is contained in and around the denoted transcript page (T-pg). See NRC disposit

Bowman-1 in this first issue in the cSee NRC dispositLochbaum-13 in tthe second issue 
April 2001 A-61 NUREG-1739 Table A: Disposition of Participant Comments from the License Renewal Public Workshop, September 25, 2000 (c

Commenter and Affiliation T-pg Comment Basis for Comment NRC 

Walters-17, NEI 192 It’s not clear why the process can’t work by reviewing what the applicant describes as their methodology for scoping and then also for determining which aging effects require management. If the agency looks at that methodology and applies it however they think they would apply it and they think that a structure or component was omitted or an aging effect was omitted, then ask that question. For the applicant to be requested to provide information about everything that is not included, is very hard. The burden is on the applicant, but I always thought that the burden was to provide your process for how you come up with what’s in the basket. If the agency thinks there is a problem with that, then the question ought to go back to the applicant with a basis for why the staff believes, based on their review of the methodology, a certain aging effect or a certain structure or component should have been included, I’m not sure that’s the way that we’re headed. The basis for this comment is contained in and around the denoted transcript page (T-pg). Industry is looking 

the amount of inforequired to put in same time, the staoptimum level of imake reliance on evaluation basis cthe NRC does not everything, but exchallenges to speknowledge, experAt the same time, reference GALL, adifferences, shoulregarding how the incorporated. The improve the effortbehind questions guidance provides detail in applicatioto review the applassess the effectimanagement progThe GALL report address this comm
NUREG-1739 A-62 April 2001 This Page Intentionally Left Blank
APPENDIX B

DISPOSITION OF NEI COMMENTS
B-ii

This Page Intentionally Left Blank
April 2001 B-1 NUREG-1739

B.1. INTRODUCTION

In response to the NRC Request for Public Comments on the Draft Guidance Documents for

License Renewal (65 FR 53047, August 31, 2000), the Nuclear Energy Institute reviewed the

documents and provided written comments on October 13, 2000 (see Section B.4, References)

on the draft guidance documents and for the specific questions posed in the Federal Register

notice. In addition, NEI provided additional comments on October 26, 2000 (see Section B.4,

References) and November 08, 2000 (see Section B.4, References) on the same documents.

Comments were made on the draft Standard Review Plan, the GALL report, and the draft

Regulatory Guide. Changes were identified that were necessary to NEI 95-10, “Industry

Guideline for Implementing the Requirements of 10 CFR Part 54 – The License Renewal Rule,”

Revision 2. About 723 written comments were received from NEI.
NUREG-1739 B-2 April 2001

B.2. EVALUATION AND DISPOSITION OF COMMENTS

The tables B.2.1 through B.2.16, at end of Appendix B, contain comments received from NEI in

accordance with the references provided in Section B.4.

The column heading, “Comment Number,” is primarily intended to provide the source of the

comment, meaning the letter or meeting from which the comment was obtained (see

Section B.4, References), and to indicate whether the comment was originally numbered when

submitted. For example, NEI-1 indicates that the comment was made by NEI and the “1”

distinguishes this comment from all other NEI comments; however, the “NEI” in front of the

number indicates that this comment was not originally numbered when submitted by NEI. A

comment number prefixed by either a “G” or “S” indicates that the comment is on the GALL

report or Standard Review Plan for License Renewal ( SRP-LR), respectively. For example:

• G-IVD1-6 indicates a comment on the GALL report, Chapter IV, Section D1.

• G-XI-M5-1 indicates a comment on the GALL report, Chapter XI, Aging Management

Program M5.

• S3.4-2 indicates a comment on the SRP-LR, Section 3.4.

• SA.1-3 indicates a comment on the SRP-LR, Appendix A, Section A.1.

• NEI-1 indicates a comment for which NEI did not actually supply a comment number.

NRC numbered the NEI comments consecutively. This applies to comments NEI-1

through NEI-19.

• A single number (1 through 7) indicates a NEI comment on NEI 95-10 for which NEI did

supply a comment number, which is shown as the single digit.

The abbreviations used in this appendix are listed in the front matter of this NUREG. All

comment numbers use original NEI comment numbers if provided. Traceability between the

comments in this Appendix B and the references in Section B.4 is indicated in Section B.3 and

is established for all comments. In Tables B.2.8, B.2.10, B.2.12-5, B.2.15, and B.2.16, under the

column heading “Item Number,” the numbers on the first line for a line item are those from

Section B.3 to establish traceability since the origins at comments in these tables are less direct

than those in other tables. For example B.3.2 would indicate that Section B.3, item 2, is the

source of that comment, and B.3.2 would appear on the first line under the column heading

“Item Number.” The items on the second or subsequent lines for each line item under this

column heading relate to the section of the document on which the listed comment was made.

The references in Section B.4 provide the sources of all comments. For the tables B.2.1 through

B.2.13, the comments are in alphanumerical order both for each appendix and for this overall

appendix. However, Tables B.2.14 through B.2.16 are only in alphanumerical order within each

appendix. This is based on the combination of letters and numbers of each comment number as

you move from left to right.
April 2001 B-3 NUREG-1739

B.3. ORIGIN OF NEI COMMENTS

1. All NEI Comments besides those described below

See Section B.4, Reference 1, Enclosure 3

2. Comments NEI-1 through NEI-5 in Table B.2.15

See Section B.4, Reference 1, Enclosure 2, pages 1 through 3

3. Comments NEI-6 through NEI-8 in Table B.2.15

See Section B.4, Reference 1, Enclosure 1, pages 1 through 3

4. Comments NEI-9 in Table B.2.15

See Section B.4, Reference 1, Enclosure 4, page 1

5. Comments NEI-10 through NEI-13 in Table B.2.15

See Section B.4, Reference 1, Enclosure 5, page 1

6. Comments G X-1, G XM1-1, G X.S1-1, and G X.S1-2 in Table B.2.8

See Section B.4, Reference 2

7. Comments S-1-1 through S-1-5; S-2-1 in Table B.2.10

See Section B.4, Reference 1, Enclosure 3, SRP-LR Comments on Chapters 1 and 2,

page 1

8. Comments S-3.5-1 through S-3.5-27 in Table B.2.12-5

See Section B.4, Reference 1, Enclosure 3, SRP-LR Comments on Chapter 3, pages 20

through 27

9. Comments 1 through 7 in Table B.2.15

See Section B.4, Reference 1, for Enclosure 5, pages 1 and 2)

10. Comments NEI-14 through NEI-19 in Table B.2.16

See Section B.4, Reference 3
NUREG-1739 B-4 April 2001

B.4. REFERENCES

Letter from Alex Marion, Director, Licensing and Programs, Nuclear Generation, Nuclear Energy

Institute, to Annette Vietti-Cook, Secretary of the Commission, U.S. Nuclear Regulatory

Commission, concerning NRC Request for Public Comments on the Draft Guidance

Documents for License Renewal (65 FR 53047, August 31, 2000), October 13, 2000.

Letter from Alex Marion, Director, Licensing and Programs, Nuclear Generation, Nuclear Energy

Institute, to Annette Vietti-Cook, Secretary of the Commission, U.S. Nuclear Regulatory

Commission, concerning NRC Request for Public Comments on the Draft Guidance

Documents for License Renewal (65 FR 53047, August 31, 2000), October 26, 2000.

Meeting between NRC staff and NEI representatives on industry’s comments on Chapters 2, 4,

and 11 of the GALL report based on the NRC Request for Public Comments on the Draft

Guidance Documents for License Renewal (65 FR 53047, August 31, 2000), November 8,

2000.
APPENDIX B, TABLE B.2.1

DISPOSITION OF NEI COMMENTS

ON CHAPTER II OF GALL REPORT
B-2.1-ii

This Page Intentionally Left Blank
April 2001 B.2.1-1 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-1 A1.1 Page II A1-5 Leaching of Calcium Hydroxide Page II A1-7 Aggressive Chemical Attack Page II A1-7 Corrosion of Embedded Steel A1.2 Page II A1-11 Corrosion There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(viii)(E) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” The GALL rep

rulemaking. It acceptable to management clarify the GAmanagement the staff has dcriteria that cainaccessible aFor the “Aggreand “Corrosioaging mechanmanagement inaccessible asatisfied if the that the belownot aggressivecriteria presenChapter II. For the “LeachHydroxide” agmanagement inaccessible asatisfied if the that this aging significant, in presented in rFor corrosion areas of contaconcern is thasteel liners or that are embefloor slab are 
NUREG-1739 B.2.1-2 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-1 (cont.) degradation fr

(i.e., water on seeping throuconcrete floor sealants). Spebased on a prNEI on 12/4/0address inacccontainmentsIf any of these satisfied, a plamanagement recommended mechanism foGALL Chapteto incorporate in all applicabGALL, Chapteaddress this c

G-IIA1-2 A1.1 Page II A1-5 Leaching of Calcium Hydroxide Page II A1-7 Aggressive Chemical Attack Page II A1-7 Corrosion of Embedded Steel Apply the findings given in Section III.A.1 for the Class I concrete structures to the “Evaluation and Technical Basis” and “Further Evaluation” columns for concrete components identified. The technical basis for the Class I concrete structures and the concrete containment (which also is a Class 1 structure) should be consistent. This was prev

XI.S2 in a “NoAcceptance Cimprove clarityinformation in added to GALGALL Chapteaddress this c
April 2001 B.2.1-3 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-3 A1.1 Page II A1-6 Corrosion of Embedded Steel Add the reference EPRI TR- 103842. Change the Environment column to “Exposure to Aggressive Environment” to be consistent with Item IIIA1.1 on page III A1-6. A review of the applicable references (EPRI TR-103842, Section 4.1.5, NUREG/CP-0100, Page 85, NUREG- 1611, Table 1, Items 04 and 013) concluded that the discussions on “Corrosion of Embedded Steel” refers to the environment within the concrete directly surrounding the rebar. In order to manage embedment corrosion, the surrounding environment must be managed. As long as the surrounding environment does not present an “Aggressive Chemical Attack” to the cover concrete, the concrete environment surrounding the embedment is maintained. The acceptance criteria for the Aggressive Chemical Attack by soil or groundwater (or atmospheric conditions) are: pH>5.5, Chlorides <500 ppm, Sulfates < 1,500 ppm (Reference TR-103842, Section 4.1.3.3). NUREG/CP-0100 also recommends Groundwater Tests for pH, chlorides and sulfates. The first propo

longer relevancolumn was retables. The second pincorporated iprovide consisChapter III. The technical the justificatiouse of acceptasurrounding eacceptance crconcrete envirconcurs with tfollowing sentthe Evaluation for aging effeccorrosion of e“Alternatively, surrounding thaggressive (pppm, sulfates of embedded GALL Chapteaddress this c

G-IIA1-4 A1.1 Page IIA1-6 Reaction with Aggregates Aging effect should be cracking The aging effect is cracking. Expansion would lead to cracking. The aging effe

identified as cCracking” has “Cracking.” GALL Chapteaddress this c
NUREG-1739 B.2.1-4 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-5 A1.1 Page IIA1-8 Settlement Region of interest is Dome, wall and basemat. Provided as clarification. To be consiste

in the GALL rebeen replaced Basemat, RinGALL Chapteaddress this c

G-IIA1-6 A1.1 Page II A1-8 Elevated Temperature ‘10 CFR 50.55a ASME Sect. XI, Subsection IWL’ should be deleted from Reference column. The implementation of 10 CFR 50.55a ASME Sect. XI, Subsection IWL would not be able to identify the loss of strength and modulus due to elevated temperature. This has been rightfully stated in the next page. The proposed 

relevant becacolumn was rereport. GALL Chapteaddress this c

G-IIA1-7 A1.1 Page II A1-8 Elevated Temperature The following sentence should be added at the end of the existing paragraph: “Higher temperatures than given above may be allowed in the concrete if tests and/or calculations are provided to evaluate the reduction in strength and this reduction is applied to the design allowables.” ASME Section III, Division 2 should be properly quoted. As because aging management of this issue is impractical, option of accepting the elevated temperature with calculation should be available to utilities. The proposed 

requirements Division 2, Suhas been incoChapter II. Evaluation of areas has also GALL Chapteaddress this c

G-IIA1-8 A1.1 Page IIA1-9 Elevated temp Evaluation and technical basis: Change second sentence to read: Thus, for any portions of concrete containment that exceed specified temperature limits, as referenced in this section, further evaluations are warranted. The addition of “as referenced in this section” clarifies that it is only the items mentioned in the region of interest column that are evaluated. The phrase “a

section” is not It is understooapplies only to proposed seninstead of clarGALL Chapteaddress this c
April 2001 B.2.1-5 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-9 A1.2 Page II A1-10 Corrosion Delete “Structural Steel” from the Region of Interest column. Containment structural steel is not managed by IWE, rather it is managed by the Structures Monitoring Program per item A4.2 on page III A4- 6. Reference to s

inappropriate. been replaced Attachments” Integral attachcontainment swithin the scoGALL Chapteaddress this c

G-IIA1-10 A1.2 Page II A1-10 Corrosion The discussion of Appendix J and Coatings Programs should be deleted. Subsection IWE is acceptable as a stand alone program. In the package which was generated in support of the final rulemaking to incorporate by reference into 10 CFR 50.55a ASME Section XI Subsection IWE, it was stated that the inspection criteria of IWE is incorporated to assure that the critical areas of containment are periodically inspected to detect and take corrective actions for defects that could compromise a containment’s structural integrity. The leak tight

function of con54.4(a)(1)(iii)] the ISI requireMeasurement leak rate woulassessment omay be due to loss of materiachange in matConsequentlysupplements tdetecting agin1992 and 199reference Appcertain examincomprehensivof 10 CFR Paaddition, the 1IWE no longerate testing. With respect tProgram, the defines a techto the staff for 
NUREG-1739 B.2.1-6 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-10 (cont.) and maintena

coatings progmanaging loss corrosion duriterm, then the recommends continued durextended opethis is a relief inspections baprotective coacorrosion. The Chapter II of tapplicable locthe protective GALL Chapteaddress this c

G-IIA1-11 A1.2 Page II A1-12 Corrosion of Tendons Delete reference NUREG-1522. NUREG-1522 is not a mandated program and should be deleted from the Reference column. The proposed 

relevant becacolumn was rereport. GALL Chapteaddress this c

G-IIA1-12 A1.2 Page II A1-12 Relaxation Add reference ACI 318-95. Other methods such as ACI-318-95 may be more accurate, appropriate or current. The proposed 

relevant becacolumn was rereport. Also ACI 318-TLAA for loss GALL Chapteaddress this c
April 2001 B.2.1-7 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA1-13 A1.3 Page IIA1-13 Corrosion of tendons Delete the paragraph under evaluation and technical basis that discusses the tendon gallery. The environment of the tendon gallery is similar to the external dome environment. Both environments subject the tendon anchorage to moisture, humidity, etc. Therefore, the tendon gallery environment is not unique and should not be singled out. In addition, the tendon anchorages are protected from the moist, humid environment by the tendon caps and grease which is within the cap. The tendon anchorages are evaluated by Subsection IWL regardless of where they are located. Tendon anchorage within the tendon gallery would be evaluated by Subsection IWL. The discussio

gallery was foindicate that mand environmgallery is a prudegradation ocomponents lonot impose anmanagement gallery becausgallery does nfunction, in accriteria of 10 Cparagraph in qessential part deleted from Gapplicable locGALL Chapteaddress this c

G-IIA2-1 A2.1 Page IIA2-5 Corrosion Delete Appendix J and Coatings Program from AMP and evaluation and Technical Basis. Subsection IWE is acceptable as a stand alone program. In the package which was generated in support of the final rulemaking to incorporate by reference into 10 CFR 50.55a ASME Section XI Subsection IWE, it was stated that the inspection criteria of IWE is incorporated to assure that the critical areas of containment are periodically inspected to detect and take corrective actions for defects that could compromise a containment’s structural integrity. See NRC Disp

Comment G-IAppendix B, T.
NUREG-1739 B.2.1-8 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA2-3 A2.1 Page IIA2-5 Corrosion A2.2 Page IIA2-7 Leaching of Calcium Hydroxide Page IIA2-7 Aggressive Chemical Attack Page IIA2-9 Corrosion of Embedded Steel There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T
April 2001 B.2.1-9 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA2-4 A2.2 Pages II A2-6 & II A2-7 Freeze/Thaw, Leaching of Calcium Hydroxide, Aggressive Chemical Attack Pages II A2-8 & II A2-9 Reaction of Aggregate and Corrosion of Embedded Steel Pages IIA2-10 & IIA2-11 Elevated Temperature In lieu of ASME XI, IWL, licensees should be able to credit the Maintenance Rule 10CFR50.65, Regulatory Guide 1.160 Rev.2, and NUMARC 93-01. Add these references to the reference column. Add “or Structures Monitoring Program” in the AMP column and add statement “See Chapter XI.S6” in the Evaluation & Technical Basis column. In lieu of ASME XI, IWL, licensees should be able to credit the Maintenance Rule 10CFR50.65, Regulatory Guide 1.160 Rev.2, and NUMARC 93-01. BASIS: These programs are particularly effective for structures and supports, which are not currently under the scope of ASME XI-IWL. The structural monitoring programs developed under MR have been mandated since 1996 and therefore provide operating experience and effectiveness demonstration. NEI submitted a paper to the NRC dated 3/26/99, regarding structural monitoring programs, with a request to declare the structural monitoring program an effective aging management program for structures on a generic basis. The first propo

longer relevancolumn was rereport. The second pcredit the StruProgram (XI.Sis inappropriatMonitoring Proconcrete not w

applicant cannStructures Moaging managewithin the IWL GALL Chapteaddress this c

G-IIA2-5 A2.2 Page IIA2-11 Elevated temp Evaluation and technical basis: Change second sentence to read: Thus, for any portions of concrete containment that exceed specified temperature limits, as referenced in this section, further evaluations are warranted. The addition of “as referenced in this section” clarifies that it is only the items mentioned in the region of interest column that are evaluated. See NRC Disp

Comment G-IAppendix B, T
NUREG-1739 B.2.1-10 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA3-1 A3.1 Page II A3-4 Corrosion Delete the dissimilar metal welds from the Material column. 10 CFR 50.55a(b)(x)(C) states that the examination of these items is optional. 10 CFR 50.55

examination ois optional. 10 IWE Examinawhich is a surdissimilar metpenetrant inspExamination Care also applicwelds and are 50.55a. Based at the 1/30/01 II was revised locations to inExamination CGALL Chapteaddress this c

G-IIA3-2 A3.1 Page IIA3-5 Penetration sleeves Delete coatings program. ASME Subsection IWE and Appendix J tests are adequate without the coatings program. See NRC Disp

Comment G-IAppendix B, T.

G-IIA3-3 A.3.1

Page II A3-6Fatigue

Delete the dissimilar metal weldsfrom the Material column.

10 CFR 50.55a(b)(x)(C) states thatthe examination of this item isoptional.

Fatigue is a Taddressed by GALL Chapteaddress this c

G-IIA3-4 A.3.1

Page II A3-6 & IIA3-7SCC, CyclicLoading

Delete the dissimilar metal weldsfrom the Material column andEvaluation and Technical Basiscolumn.

10 CFR 50.55a(b)(x)(C) states thatthe examination of this item isoptional.

See NRC DispComment G-IAppendix B, T
April 2001 B.2.1-11 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIA3-5 A.3.1 Page II A3-7 SCC, Cyclic Loading Delete the comment “( one option may be to perform VT-1 visual inspections)” from attribute (4). VT-1 is not an effective examination for fine cracks such as fatigue. Additionally, most of the metal surfaces are coated. A more effective method is the leak test of Appendix J for non-fatigue CLB plants. Visual inspect

The phrase “(perform VT-1 been deleted Chapters II anapplicant shouspecific approcracks in its aGALL Chapteaddress this c

G-IIA3-6 A3.2 Page IIA3-9 Airlock Delete coatings program. ASME Subsection IWE and Appendix J tests are adequate without the coatings program. See NRC Disp

Comment G-IAppendix B, T

G-IIA3-7 A3.2 Page II A3-10 Mechanical Wear of Locks Reword the Aging Mechanism column to read as follows: “Mechanical Wear of Locks, Hinges and Closure Mechanisms required to maintain the airlock/hatch in the closed position.” Should only evaluate the components required to maintain the hatch in the closed position to support the intended function (essentially leak tight barrier). A passive inte

the criteria of for locks, hingmechanisms oand hatches dIt is to maintaiairlocks and hthe closed poswording in GArevised to be coriginal commthat these itemscope. The stspecify that agaccomplished leak rate testinTechnical Speaugmentation needed. GALL Chapteaddress this c
NUREG-1739 B.2.1-12 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB1-1 B1.1.1 Page II B1-5 Corrosion There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T

G-IIB1-2 B1.1.1 Page II B1-5 Corrosion The discussion of Appendix J and Coatings Programs should be deleted. IWE is acceptable as a stand-alone program. See NRC Disp

Comment G-IAppendix B, T

G-IIB1-3 B.1.1 Page II B1-7 Steel Elements Cyclic Loading Delete the comment “( one option may be to perform VT-1 visual inspections)” from attribute (4). VT-1 is not an effective examination for fine cracks such as fatigue. Additionally, most of the metal surfaces are coated. A more effective method is the leak test of Appendix J for non-fatigue CLB plants. See NRC Disp

Comment G-IAppendix B, T

G-IIB2-1 B2.1.1 Page II B2-5 Corrosion There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T
April 2001 B.2.1-13 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB2-2 B2.1.1 Page II B2-7 Steel Elements Cyclic Loads Delete the comment “( one option may be to perform VT-1 visual inspections)” from attribute (4). VT-1 is not an effective examination for tight cracks such as fatigue. Additionally, most of the metal surfaces are coated. A more effective method is the leak test of Appendix J for non-fatigue CLB plants. See NRC Disp

Comment G-IAppendix B, T

G-IIB2-3 B2.2.1 Page II B2-9 Concrete Elements Leaching Delete the “Yes” and the description from the Further Evaluation column and replace with “No”. The leaching of Calcium Hydroxide requires the free flow of water across the concrete section (i.e. via through- wall cracks). If both sides of the concrete are not accessible, no flow can occur. If one side is accessible (exposed) then indication of degradation is evident and the concern does not apply. See NRC Disp

Comment G-IAppendix B, T

G-IIB2-4 B2.2.1 Page II B2-9 Leaching of Calcium Hydroxide Page II B2-9 Aggressive Chemical Attack Page II B2-11 Corrosion of Embedded Steel There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T
NUREG-1739 B.2.1-14 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB2-5 B2.2.1 Page II B2-9 Concrete Elements In the “Evaluation and Technical Basis” and “Further Evaluation” columns for the Mark 2 and 3 concrete components for Leaching of Calcium Hydroxide, Aggressive Chemical Attack, Reaction with Aggregates and Corrosion of Embedded Steel aging mechanisms, apply the findings given in Section III.A.1 for the Class I concrete structures. The technical basis for the Class I concrete structures and the concrete containment (which also is a Class 1 structure) should be consistent. This comment also applies to the PWR concrete containment, Section IIA for the same aging mechanisms. See NRC Disp

Comment G-IAppendix B, T

G-IIB2-6 B2.2.2 Page II B2-15 Corrosion There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T

G-IIB3-1 B3.1.1 Page II B3-5 Corrosion There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T
April 2001 B.2.1-15 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB3-2 B3.1.2 Page II B3-7 Leaching of Calcium Hydroxide Page II B3-9 Aggressive Chemical Attack Page II B3-9 Corrosion of Embedded Steel There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T

G-IIB3-3 B3.2.1 Pages II B3-13 & II B3-15 Concrete Elements In the “Evaluation and Technical Basis” and “Further Evaluation” columns for the Mark 2 and 3 concrete components for Leaching of Calcium Hydroxide, Aggressive Chemical Attack, Reaction with Aggregates and Corrosion of Embedded Steel aging mechanisms, apply the findings given in Section III.A.1 for the Class I concrete structures. The technical basis for the Class I concrete structures and the concrete containment (which also is a Class 1 structure) should be consistent. See NRC Disp

Comment G-IAppendix B, T
NUREG-1739 B.2.1-16 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB3-4 B3.2.1 Page II B3-13 Leaching of Calcium Hydroxide Page II B3-13 Aggressive Chemical Attack Page II B3-15 Corrosion of Embedded Steel There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T

G-IIB3-5 B3.2.2 Page II B3-19 Corrosion There are additional requirements for inspection of inaccessible areas when there are no indications of degradation for (adjacent, nearby) accessible areas. This requirement should be removed from Evaluation and Technical Basis and Further Evaluation. Imposing such requirements is tantamount to additional rulemaking over and above 10 CFR 50.55a without adhering to the rulemaking process. Section (b)(2)(ix)(A) of 10 CFR 50.55a says “the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.” See NRC Disp

Comment G-IAppendix B, T

G-IIB4-1 B.4.1 Page II B4-4 Corrosion Delete the dissimilar metal welds from the Material column. 10 CFR 50.55a(b)(x)(C) states that the examination of this item is optional. See NRC Disp

Comment G-IAppendix B, T

G-IIB4-2 B.4.1 Page II B4-6 Fatigue Delete the dissimilar metal welds from the Material column. 10 CFR 50.55a(b)(x)(C) states that the examination of this item is optional. See NRC Disp

Comment G-IAppendix B, T
April 2001 B.2.1-17 NUREG-1739 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB4-3 B4.1 Page II B4-6 Cyclic Loading Cracking due to cyclic loading is a TLAA and should be addressed similar to Item B4.1 Fatigue. Cyclic loading only applies to some penetrations and torus-attached piping, which are required to have a fatigue analysis under the Containment Loads Program. If a CLB fatigu

this is covered aging mechanLoading” aginintended to adcyclic loading fatigue analysGALL IIB4 and clarify this distGALL Chapteaddress this c
NUREG-1739 B.2.1-18 April 2001 Table B.2.1: Disposition of NEI Comments on Chapter II of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIB4-4 B.4.1 Page II B4-7 SSC, Cyclic Loading Delete reference to augmented VT-1 examinations of bellows and dissimilar metal welds. Fatigue and SCC cracks cannot be detected by VT-1 or by any surface examination. The Type B local leak test per Appendix J is the most effective method, particularly for two- ply bellows, which are normally pressurized between the plies. With respect t

NRC DispositIIA3-5 in this AWith respect tnotes that prolocal leak rate have been deIN 92 20; this an applicant’s In the EvaluatBasis, Attribut“augmented Vhas been delesentence revisperiod of exteExamination Cand additional examinations bellows assemmetal welds athis issue.” This revision hthroughout GAapplicable. GALL Chapteaddress this c
APPENDIX B, TABLE B.2.2

DISPOSITION OF NEI COMMENTS

ON CHAPTER III OF GALL REPORT
B.2.2-ii

This Page Intentionally Left Blank
April 2001 B.2.2-1 NUREG-1739 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIA1-1 III A1.1, aggressive chemical, page III A1-7 Evaluation and technical basis should include the information from the preceding item on the aggressive environment limits. Further evaluation should be changed to yes, if exceed aggressive chemical limits. Limits have been previously documented and should be included here to be consistent. The only conc

degradation of is restricted to below-grade aenvironment, wchemical attaccorrosion of emSpecific criteriaggressive beenvironment hGALL IIIA. In taggressive beenvironment, a management and must be drenewal applicGALL IIIA was this comment. G-IIIA1-2 IIIA1.1, Concrete degradation There appears to be a mix-up in several table entries between Below Grade/Exterior and Above Grade/Interior. The criteria for aggressive chemical attack are for aggressive groundwater (below grade), not for above grade/interior surfaces. See NRC disp

Comment G-IIAppendix B, T

G-IIIA1-3 III A1.1, erosion of porous concrete, page IIIA1-8 Delete sections on porous concrete throughout the document. Including III A2.1, page IIIA2-8; IIIA3.1, page IIIA3-8; IIIA5.1, page IIIA5-8; IIIA6.1, page IIIA6-8; IIIA7.1, page IIIA7-8; IIIA8.1, page IIIa8-8. This is not a generic aging effect. Erosion of porous concrete is a current licensing issue being handled on a site-specific basis and as such should not be included in this document. Many entries i

effects that do to all NPPs. It include it, so taddress it for toperation. GALL IIIA was address this c
NUREG-1739 B.2.2-2 April 2001 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-III.A1-4 III A1.1, Erosion of Porous Conc, page III A1-8 If the previous comment is not incorporated, then change Material from “Reinforced Concrete” to “Porous Concrete”. Provides a more accurate description. The concern is 

cracking and dof the foundatreinforced concompletenessrevised to add “porous concrcomponent anrespectively. GALL IIIA was this comment. G-IIIA1-5 III A1.2, corrosion, page IIIA1-9 Delete the statement on protective coatings under evaluation and technical basis. Including IIIA4.2, page IIIA4-7 IIIA5.2, page IIIA5-9 IIIA6.2, page IIIA6-9 IIIA7.2, page IIIa7-9 The Structures Monitoring Program is adequate as a stand-alone program without the coatings program. Clarified the aprotective coafollows: “If prorelied upon to aging, the struprogram must to address promonitoring and GALL IIIA was this comment. G-IIIA1-6 III A1.2, corrosion, page IIIA1-9 Delete requirement on inaccessible areas. Including IIIA3.2, page IIIA3-9 IIA5.2, page IIIA5-9 IIIA7.2, page IIIA7-9 IIIA8.2, page IIIA8-9 Requirements on inaccessible areas are not required by the Code on containment. Therefore, group 1 structures should not be more restrictive than Code requirements for containment. There is no geto aging of inasteel in Class proposed deleimplemented. GALL IIIA was this comment.
April 2001 B.2.2-3 NUREG-1739 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIA1-7 III.A1.3, page IIIA1-9 Masonry Walls Revise the AMP column to “Structures Monitoring Program or Masonry Wall Program” and add referral to Chapter XI-S6 to Evaluation column. Either program may be used. Guidance on t

XI.S6 “StructuProgram” for amasonry walls ‘Program DesAMP for masothe XI.S6 “StruProgram” or thWall ProgramAMP XI.S5 wathis comment. G-IIIA2-1 III.A2.3, page IIIA2-9 Masonry Walls Revise the AMP column to “Structures Monitoring Program or Masonry Wall Program” and add referral to Chapter XI-S6 to Evaluation column. Either program may be used. See NRC dispComment G-IIAppendix B, T

G-IIIA3-1 III.A3.3, page IIIA3-9 Masonry Walls Revise the AMP column to “Structures Monitoring Program or Masonry Wall Program” and add referral to Chapter XI-S6 to Evaluation column. Either program may be used. See NRC disp

Comment G-IIAppendix B, T
NUREG-1739 B.2.2-4 April 2001 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIA5-1 A5.2, liners, page IIIA5-9 On Page IIIA5-9, delete the discussion in the Evaluation and Technical Basis column and insert the Water Chemistry Program as the applicable AMP and add referral to ChapterXI-M11. The water chemistry program precludes aging effects by maintaining the spent fuel pool parameters such that degradation would not occur. The Water Ch

XI.M2) has beapplicable AMaddition to the Program, the mfuel pool watenecessary, beon control of wnot manage pfrom the concfuel pool liner. occurred at onGALL IIIA was this comment. G-IIIA5-2 III.A5.3, page IIIA5-9 Revise the AMP column to “Structures Monitoring Program or Masonry Wall Program” and add referral to Chapter XI-S6 to Evaluation column. Either program may be used. See NRC dispComment G-IIAppendix B, T

G-IIIA6-1 III.A6.3, page IIIA6-9 Revise the AMP column to “Structures Monitoring Program or Masonry Wall Program” and add referral to Chapter XI-S6 to Evaluation column. Either program may be used. See NRC disp

Comment G-IIAppendix B, T

G-IIIA8-1 III.A8.1, page IIIA8-7 Corrosion of Embedded Steel and Aggressive Chemical Attack Evaluation and technical basis should provide the limits below which no aging management is required similar to those on page III A1-7. See NRC disp

Comment G-IIAppendix B, T
April 2001 B.2.2-5 NUREG-1739 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIA8-2 IIIA8.2, stainless steel tank liners Delete the item entirely. Aging of the internal surfaces of steel tanks is addressed with the applicable mechanical system and does not belong in the structural section. Stainless stee

appropriately apart of the strueffect addressnot been dupliof GALL. GALL IIIA was address this c

G-IIIB1-1 IIIB1.1 page IIIB1-4 to IIIB1-17 For section B1, change header at top of page from B1.3 to B1. Also, delete “MC” from the heading text. Editorial Class MC is for containment vessels, not piping and component supports. To improve cla

was changed Piping and Cotitle of IIIB1.3 w“Supports for AComponents.” by IIIB1.3 are containment cdowncomers, GALL IIIB was this comment. G-IIIB1-2 IIIB1.1.1, page IIIB1-4; IIIB1.1.3, page IIIB1-8 IIIB1.1.4, page IIIB1-8; IIIB1.2.1, page IIIB1-10; IIIB1.3.1, page IIIB1-14; IIIB1.3.3, page IIIB1-16; IIIB2.3, page IIIB2-6; IIIB3.2, Vibration and cyclic induced cracking is not a license renewal aging effect and should be deleted. Cracking due to vibratory loads and cyclic loading is not an aging effect requiring management for the period of extended operation. For components that may be subjected to vibratory or cyclic loading, proper design eliminates or compensates for vibration and cyclic loading. In addition, vibration characteristically leads to cracking in a short period of time, on the order of hours to days of operation. For example, a component with 1 Hertz vibratory load will be subject to 107 Cracks in stee

component suvibratory stresmaterial endurdevelop in a mThis time framwith the requirRenewal Ruleaging processextended operThe potential fby other cyclic thermal cycling system, is imp
NUREG-1739 B.2.2-6 April 2001 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIB1-2 (cont.) page IIIB3-4; IIIB4.3, page IIIB4-6; IIIB5.2, page IIIB5-4 cycles in four months of service, so that failure, should it occur, is probable early in life for vibratory stresses above the endurance limit. Because this time period is short when compared to the overall plant operational life, any cracking will be identified and corrected to prevent recurrence long before the period of extended operation. This type of degradation is limited to a small set of components and is corrected as discovered with inspections of similar locations and configurations to ensure the event is location specific or a one-time event. structural stee

specification oallowable stresminimum of 10

However, concexpansion, unanchors for cosusceptible to service-inducesupports. This reduced capacanchorage and of the anchorabasis event (eMaintaining soconcrete aroucritical to the isupport and remanagement. GALL IIIB waaging managesurrounding exand embeddeStructures Moidentified as thAt the 1/30/01 staff again revexperience antesting of concwhen cracking concluded thasignificant for and grouted a
April 2001 B.2.2-7 NUREG-1739 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIB1-2 (cont.) cast-in-place a

anchors. GALreflect this conGALL IIIB was this comment.

G-IIIB1-3 IIIB1.1.2, Bolting, SCC, page III B1-6 Program should be Subsection IWF, not Bolting Integrity Program. The components listed in “Class I Piping and Component Supports” are within the scope of IWF, which has been found to be acceptable for managing this aging effect in NUREG-1723. Cracking due 

adequately maonly requires a inspection of mCracking of boonly be detectdeveloped spepurpose. Bolti(XI.M18) was consideration cracking (SCCbolting associasupports. For additional special inspecNRC DispositiG-V-E-7 in this Table B.2.4. GALL IIIB was XI.M18 was recomment.
NUREG-1739 B.2.2-8 April 2001 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIB1-4 B1.1.2 SCC page III B1-6 Under the material column for stress corrosion cracking, change “tensile strength > 150ksi” to “yield strength > 150ksi.” Per NUREG-1339 and EPRI NP- 5769, the 150ksi is related to yield strength when discussing whether SCC is an applicable aging effect. “Yield strength

terminology noAs noted in NUksi criterion is yield strength, specified” yield GALL IIIB was this comment. G-IIIB1-5 IIIB1.1.1, fatigue, page IIIB1-7 For fatigue throughout this section, evaluation and technical basis should be changed to “Fatigue may be a time-limited....” Further evaluation should say “Yes, TLAA if applicable.” Including Sections B1.2.1, page IIIB1-13 and B1.3.1, page IIIB1-15 Editorial comment. The three tablapplicable if a exists, which bGALL IIIB was address this c
April 2001 B.2.2-9 NUREG-1739 Table B.2.2: Disposition of NEI Comments on Chapter III of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IIIB1-6 III.B1.1.1, Cracking, page III B1-5 III.B1.2.1, Cracking, page III B1-11 III.B1.3.1, Cracking, page III B1-15 In this section and throughout the document, the adequacy of visual VT-3 examination is called into question for the detection of cracking. In particular, Section III.B1.1.1 determine that VT- 3 is inadequate for detection of cracking in Class 1 piping and component supports, and Section III.B1.2.1 finds this to be true for Class 2 and 3 piping and component supports as well. VT-1 is recommended. The conclusions reached in this section go beyond what is current in the code. Licensee should not have to go beyond Code requirements without justification. VT-3 should be found to be adequate for detection of “crack like indications” in at least three circumstances: When the structure or component can tolerate “mature cracks.” This should be the case for Class 1, 2, and 3 component supports, where mature cracks are needed to jeopardize the load-carrying function of the component support. When pressure-containing component is subject to both visual examinations and pressure testing capable of detecting localized, small capacity leakage. This should be the case for bellows sleeves and penetration subjected to Appendix J Type B and C tests. Situations where proximity to the component or structure surface is not an issue, so that visual acuity, lighting and character recognition is essentially identical for VT-1 and VT-3. See NRC Disp

Comment G-IIAppendix B, T

G-IIIB2-1 IIIB2.1, cyclic loading, page IIIB2-6 Cyclic loading should be deleted for cable trays, etc. Cyclic loading is not applicable to supports for cable trays, conduit, instruments, etc. See NRC Disp

Comment G-IIAppendix B, T

G-IIIB2-2 IIIB2.2, page IIIB2-6 Thermal cycling/ vibration should be deleted for cable trays, etc. Cyclic loading is not applicable to supports for cable trays, conduit, instruments, etc. See NRC Disp

Comment G-IIAppendix B, T
NUREG-1739 B.2.2-10 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.3

DISPOSITION OF NEI COMMENTS

ON CHAPTER IV OF GALL REPORT
B.2.3-ii

This Page Intentionally Left Blank
April 2001 B.2.3-1 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-1a General comments (a) Further evaluation should not be required where existing programs manage applicable aging effects. The meaning of the “Further Evaluation Recommended” column is not clear. What is meant by “Further Evaluation Recommended?” Every entry has a yes in this column implying that every item requires an evaluation. If the GALL report is to be a useful document, credit for existing programs that are found to be sufficient should be given without the requirement for further evaluation. The column “F

identifies one elements of thneed augmenfurther evaluaprograms maneffects and no required then column. This crequesting claThe GALL repaddress this c

G-IV-1b General comments (b)The table should be arranged by common RCS components as follows: reactor vessel (BWR & PWR), vessel internals (BWR & PWR), RCS piping and valves (BWR&PWR), RCS Pumps (BWR&PWR), and steam generators (PWR). The arrangem

is generally foreport. Making for pumps doevalue since ththe pumps is oboundary. Theadvantage to bsuggested refoThe GALL repaddress this c
NUREG-1739 B.2.3-2 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-1c General comments (c) In addition, it is not clear that aging effects for which ISI is done today will be required for the period of extended operation. For example, cracking at vessel welds (e.g., pressurizer, RV, and primary side of OTSGs), nozzle welds, and piping welds is not addressed anywhere, thus implying that Examination Categories B-A, B-B, B-D, and B-J may be discontinued for license renewal. This conclusion is not consistent with the NRC’s findings in BAW-2243A, BAW-2244A, BAW- 2251A, and the Oconee License Renewal Application. The GALL rep

existing aging programs (AMto satisfy the r10 CFR 54. Th10 CFR 50.55current and licThe requireme10 CFR 50.55must be satisfrenewal term. Cracking at veviewed to be a by NRC and ththe GALL repoThe GALL repaddress this c

G-IV-2 B2.1.1, B2.1.4, B2.1.7+ for W internals B3.1.1, B3.1.3+ for CE internals B4.1.1, B4.1.5+ for B&W internals No BWR items at this time The GALL report states that “The reactor vessel internals receive a visual inspection (VT-3) according to Category B-N-3 of Subsection IWB, ASME Section XI. This inspection is not sufficient to detect the effects of changes in dimension due to void swelling.” While the VT-3 examination is capable of detecting significant changes in dimension. At issue is the ability to visually detect loss in ductility. Therefore, the GALL and the SRP-LR should be revised to read “This inspection is capable of detecting significant changes in The GALL and the SRP-LR should recognize the capability of visual examination to detect significant changes in dimension caused by void swelling, with significant defined to be a dimensional change of 5 % or more. The likely outcome of the industry programs will be to recommend examination of the most affected internals locations, such as baffle/former assemblies (Items B2.4.1 and B2.4.2) in Westinghouse plants. The GALL document would be greatly simplified, and the most affected locations would continue to The NEI comm

and will not be reactor vessel programs resoissue. For addGALL based osee NRC dispcomment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-3 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-2 (cont.) dimension, but is not sufficient to detect loss of ductility directly.” Too many components are called out in the GALL report. Only the most affected locations should be listed in the GALL report, such as baffle/former assemblies (Items B2.4.1 and B2.4.2) in Westinghouse plants. be adequately covered by these changes. G-IV-3 C1.1.13 (BWR), C2.1.5 (PWR) The GALL report should be changed so that, for PWR Class 1 small-bore piping, SCC and Unanticipated Thermal and Mechanical Loading are separated. The column labeled Aging Mechanism for one of these will be stress corrosion cracking (SCC) and the other will be Unanticipated Thermal and Mechanical Loading. Separating these two aging mechanisms permits the industry to comment on two separate GALL entries. The industry considers that Unanticipated Thermal and Mechanical Loading is not a valid aging effect, but rather a design consideration. The industry does not agree that SCC of Class 1 small-bore piping is an issue that should be addressed for license renewal. The combination of material selection, reactor coolant chemistry control, ASME Code Section XI surface and visual examinations, and plant leak detection monitoring systems, are sufficient to address SCC for Class 1 small-bore piping. The report recommends that “A plant-specific destructive examination or a nondestructive examination (NDE) that permits inspection of the inside surfaces of It is not neces

stress corrosiounanticipated mechanical loeffect can be sOperating expthat small-bore effect that reqextended termthat a plant-spexamination oexamination (Ninspection of tthe piping neeFor Class 1 pismaller than n(NPS) 4 inch, the one-time inperformed to cinitiation and gcorrosion cracloading is occtime inspectioeffectiveness program.
NUREG-1739 B.2.3-4 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-3 (cont.) the piping” be performed “to ensure that cracking has not occurred and the component intended function will be maintained during the extended period.” This should not be necessary when reactor coolant chemistry programs and plant detection systems are in place. The GALL rep

address this c

G-IV-4 A2.3.1, A2.3.3 The GALL report extends the concern for irradiation embrittlement to reactor vessel inlet and outlet nozzles, and to safety injection nozzles, for PWR plants. GALL should add the following sentences in the column labeled “Evaluation and Technical Basis:” (1) The applicant may choose to demonstrate that the materials in the inlet, outlet, and safety injection nozzles are not controlling for the TLAA evaluations. The applicant may choose to demonstrate that the materials in the inlet, outlet, and safety injection nozzles are not controlling, so that such materials need not be added to the material surveillance program for the license renewal term. (2) The GALL report also states that “Appendix H to 10 CFR Part 50 requires the reactor vessel materials surveillance program to meet the License renewal applicants have been able to demonstrate that, while nozzle course materials may exceed the neutron fluence threshold of 1017 n/cm2 (E>1 MeV), these materials are not controlling (i.e., traditional beltline base metal and weld materials control PTS limits, pressure-temperature limits, LUST limits, and material surveillance capsule requirements). Other license renewal applicants should have the same opportunity to provide the same type of demonstration. This comment 

other commensuggesting thabe raised to 10address these following was The threshold should not be NEI commenteof data to suppthreshold. The recommendatsusceptible locmonitored and not necessary locations excevessel, the thr10E17 to be c10 CFR 50 ApSee NRC dispcomment GIVAppendix B, Twas revised bof an enhance
April 2001 B.2.3-5 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-4 (cont.) American Society for Testing and Materials (ASTM) E 185 Standard. However, the surveillance program in ASTM E 185 is based on plant operation during the current license term, and additional surveillance capsules may be needed for the period of extended operation.” detect tight cra

applications. Tevaluation will components. TSCC/IASCC aembrittlement“Further Evaluchanged to “nSpecifically, a chapter XI waarticulate this program includof the inservicaccordance wSociety of Mec(ASME) CodeSubsection IW(1995 edition taddenda, or laapproved in 10 certain suscepcomponents o(b) monitoring coolant water accordance wguidelines in Tthe long-term operation of preactor (PWR) components. AASME Section enhanced visunon-bolted comdemonstrated for bolted com
NUREG-1739 B.2.3-6 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-4 (cont.) inspection me

components mthe NRC staff the license renThe program imanaging the initiation and gcorrosion cracirradiation asscracking (IASCfracture toughirradiation embswelling. The preventive meSCC or IASCCeffects of cracfunction of the repair and/or rneeded to maperform the inof fracture touconsequence Cracking is exthe surface andetectable by inspection. Thguidelines to aintegrity of the reactor pressucomponents, bbolted componconsists of the (a) identify the limiting items, appropriate inpermit detectio
April 2001 B.2.3-7 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-4 (cont.) of the feature 

and demonstrof the propose(c) implement the license renbolted componrecommends eexaminations. components, trecommends oacceptable insthese methods for the NRC stof the license comment was 25th meeting thuse the enhanexample. GALcontain enhanexample. Specifically foapplicable for reactor vessel addressed. (a) The first seto TLAA situatthe first row (AGALL). In NURsentence “The choose to demmaterials in thsafety injection controlling for was incorpora
NUREG-1739 B.2.3-8 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-4 (cont.) line items A1.3

designation A(earlier design(b) The seconapplies to the A2-15 (AugusGALL). In NURAMP XI.M31 “Surveillance” tapplicant may demonstrate tthe inlet, outlenozzles are nosuch materials the material sufor the license added as item description. The GALL repaddress this c

G-IV-5 A2.2.1, A2.7.1, A2.7.2, C2.5.6, C2.5.10 Chapter IV of the GALL report should be revised to eliminate the augmented program requirements for bottom head instrumentation tubes (Item A2.7.1), the vessel head vent pipe (Item A2.7.2), pressurizer instrument penetrations (Item C2.5.4), and pressurizer heater sheaths and sleeves (Item C2.5.6). The justification for the adequacy of existing activity for Ni-Fe-Cr CRDM nozzles is based on the following information from the GALL report: The program includes inservice inspection (ISI) in accordance with ASME Subsection IWB, Table IWB 2500-1 or, for susceptible components and locations, implementation of an integrated, long-term inspection program based on the guidelines of NRC Generic Letter (GL) 97-01 to detect cracks or coolant leakage. The AMP for I

Rod Drive Heasufficient for ItA2.7.3. For bottom hetubes (Item A2instrument penC2.5.6) and psheaths and scredit is given Inspection for and Water Chapplicant prov
April 2001 B.2.3-9 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-5 (cont.) Preventive measures are in accordance with EPRI guidelines in TR-105714 to mitigate primary water stress corrosion cracking (PWSCC). Control of halogens, sulfates, and oxygen in the primary water to less than 0.05, 0.05, and 0.005 ppm, respectively, during operation, and monitoring and control of water chemistry during shut down, mitigate potential of PWSCC. The applicant performs a susceptibility assessment in accordance with the most current industry susceptibility model and inspection results, to define the most susceptible components and locations to be included in a periodic inspection program. The susceptibility assessment is performed in accordance with the guidelines of GL 97-01, in order to determine the need for an augmented inspection program of nozzle welds, including a combination of surface and volumetric examination. However, several of these same justifications are apparently insufficient for bottom head instrumentation tubes (Item A2.7.1), the vessel head vent pipe (Item A2.7.2), pressurizer instrument penetrations (Item C2.5.4), and AMP or partici

programs to dAMP for PWSwelds.The GALL repaddress this cthe need for a(plant specific vessel closure such as vesseA2.7.2) and otpenetration (nadded) becauby GL 97-01.
NUREG-1739 B.2.3-10 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-5 (cont.) pressurizer heater sheaths and sleeves (Item C2.5.6). This should not be the case. Insufficient credit is given for the reactor coolant water chemistry program and its combination with ASME Code Section XI Examination Category B-P visual (VT-2) inspections. It would appear that some form of susceptibility evaluation is required, along with the water chemistry program and an inservice inspection program, in order for adequacy to be demonstrated. Considering that the CRDM nozzles are lead indicators of potential PWSCC, and considering the lower level of risk associated with leakage from Ni-Fe- Cr components other than the CRDM nozzles, the combination of water chemistry control and Examination Category B-P inspections should be found to be adequate. G-IV-6 B2.1.3, B2.1.7, B2.4.2, B2.5.5, B2.5.7, W Plants B3.2.2, B3.4.2, B3.4.3, CE Plants SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation could occur in PWR reactor vessel internal bolts and screws of B&W design. The SRP-LR references the GALL report for recommendations for inservice inspection activities to manage loss of preload. No justification is provided in the GALL report for determining that existing aging management activities for Items B3.4.2 and B3.4.3 for CE plants, and Item B4.3.4 for B&W plants require augmentation. The GALL report says that “However, VT–3 inspection may not be adequate to detect the loss of mechanical The wording fo

Item B2.1.3 anin Section B2 stress relaxatipreload) have follows: For items B2.1acceptable AMevaluation inc
April 2001 B.2.3-11 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-6 (cont.) B4.3.4 B&W Plants Other items in B&W plants: B4.9.2, B4.5.2, B4.5.3, B4.5.5, B4.6.3, B4.6.7, B4.7.2 However, the GALL report is not consistent on the evaluation of aging management activities. Items B2.1.3, B2.1.7, B2.5.5, and B2.5.7 for W plants and Item B3.2.2 for CE plants are consistently evaluated. For the W plant items, the GALL report states that: “Visual inspection (VT–3) is performed according to Category B– N–3 of Subsection IWB, ASME Section XI to monitor the relevant conditions of degradation, and loose part monitoring and/or neutron noise monitoring (excore detectors) to detect core barrel motion.” However, the GALL report should be changed so that the aging management activities for Items B3.4.2 and B3.4.3 for CE plants, and Item B4.3.4 for B&W plants require no further evaluation. closure integrity in components. An augmented inspection program to determine critical locations and appropriate monitoring and inspection techniques may be necessary.” This statement could also be made about Items B2.1.3, for example, but the finding by the NRC staff was that the existing activities were adequate. The GALL report also says, “Because VT–3 inspection can only detect degradation that occurs after the loss of preload, in some cases, enhanced inspection may be required.” While this may be so, the NRC staff has made findings elsewhere that are not consistent with requiring enhanced inspection. Generally, the finding of adequacy in spite of detection of loss of preload is based on redundancy. Therefore, the enhanced inspection requirements for baffle/former bolts are understandable. Other enhanced inspection requirements are not justified. performed acc

B-N-3 of SubsSection XI, anmonitoring or to detect relevdegradation. Fother than bafand B4.5.5), arequiring no fuincludes visuaaccording to CSubsection IWand loose part relevant condiThe GALL repItems B3.4.2 aplants). For thevaluation is nmisprint. Regarding Item items in B&W item B4.9.2, thmisprint), ISI iSection XI, Suneeds to be audisposition is binformation fro(pp. 3-120, 3-1Duke is participrograms to instress relaxatiaging mechanresults of thesbe developing 
NUREG-1739 B.2.3-12 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-6 (cont.) program for th

recommends monitoring. The GALL repaddress this cabove. G-IV-7 A2.2.2, B2.1.2, B2.5.3, B2.5.4, W Plants B3.2.1, B3.5.4, CE Plants B4.3.2, B4.4.3, B4.4.4, B&W Plants B1.4.8, B1.5.1, C1.1.6 to C1.1.11, C1.2.1, C1.3.1, C1.3.2, BWR Plants C2.1.1 to C2.1.3, C2.2.7, C2.3.1, C2.4.1, (a) Chapter IV and Chapter XI of the GALL report should be changed to find ASME Code Section XI periodic inservice inspection requirements (Examination Category B-N-3) for CASS internals components adequate for managing the effects of thermal aging embrittlement. (b) Chapter IV and XI should be revised to recognize that the limiting base metal for CASS piping thermal aging embrittlement effects may be the 0.5-inch of base metal on either side of welds inspected in accordance with the ASME Code Section XI Examination Category B-J. (c) The 25 % limit on delta ferrite for which the comparison of SAW crack growth resistance is comparable to thermally aged CASS should be reassessed. (d) The SRP-LR and the GALL report accept the industry screening criteria (i.e., casting method, Mo content, delta ferrite content) for susceptibility of CASS components The existing ASME Code Section XI inservice inspection activities are adequate to manage the loss of fracture toughness in CASS components caused by thermal aging embrittlement. This adequacy determination applies not only to the Examination Category B-N-3 inspections for internals components, but also to the base metal for reactor coolant system piping components subject to Examination category B-J requirements. Almost all of the ASME Code Section XI inservice inspection activities have been found to be acceptable, with the exception of three items. First, the visual (VT-3) examinations for reactor internals have been found to be inadequate, and supplemental (e.g., VT-1 or enhanced VT-1) examinations are required. Second, the Examination Category B-J inspections for piping welds have been found to be inadequate, with supplemental volumetric inspections of limiting (a) Examinatio

inspections (Vnot detect cracsteel componeneeds to be authe effects of tembrittlement(b) CASS pipinembrittlement by AMP XI.M1Embrittlement Stainless SteeVol. 2). As me“Detection of Ainspection muto a distance othickness or 0greater, on boc) The data of curves for CF->25% ferrite cfracture toughthermally embbelow the J-R evaluation proacceptance crapplicable to p
April 2001 B.2.3-13 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-7 (cont.) C2.5.3, C2.5.4, PWR Plants to thermal aging embrittlement, with one minor exception. The exception concerns the comparison of SAW/SMAW crack growth resistance curves with thermally aged CASS crack growth resistance curves. base metal locations required. This item might be acceptable to the industry, since it is demonstrably likely that the limiting base metal locations can be shown to be within the 0.5-inch zone on either side the welds being examined under the current Examination category B-J procedures. Third, the acceptability of the existing Saw/SMAW flaw acceptance criteria for CAS components has been found to be limited to 25% delta ferrite. The industry finds that the available data, while sparse, shows good comparison out to delta ferrite of 40 %. that are made 

level less than GALL report e25% ferrite. The GALL repflaw evaluation >25% ferrite is case-by-case fracture toughthe applicant. data indicate tfracture toughaged CASS mferrite is similawith up to 20% Intl. J. Pres. V44, 1997). Frafor CASS matferrite are avapapers: 1. Jayet-GendBalladon, Fon1994. 2. Jayet-GendMeylogan, Nu3-11, 1998. 3. Jayet-GendMeylogan, PV1996. These results fracture toughCASS materiaare lower than 
NUREG-1739 B.2.3-14 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-7 (cont.) NEI commente

XI should be rthat the limitinCASS piping tembrittlement 0.5-inch of basof welds inspewith the ASME Examination CGALL report redescribed in thto Walters, LicNo. 98-0030, MAMP recommelimiting base mcomponents. Fembrittlement susceptible pipprovides for voof the base methe inspection determined to standpoint of aoperating timeconditions. Foembrittlement components, tsupplemental portions of the components dlimiting from ththermal aging ferrite and mocasting procestemperature), cracking susce
April 2001 B.2.3-15 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-7 (cont.) stress, operati

environmental applicant has demonstrate tbase metal on welds is limitind) See NRC dcomment G-IVAppendix B, TThe GALL repaddress this cproposed chan

G-IV-8 Fatigue TLAA (a) SRP-LR Section 4.3.2.1 describes the TLAA options for Class 1 components. For example, 10 CFR 54.21(c)(1)(I) stipulates that the existing CUF calculations remain valid because the number of assumed transients would not be exceeded during the period of extended operation. 10 CFR 54.21(c)(1)(ii) stipulates that the CUF calculations be re-evaluated based on an increased number of assumed transients to bound the period of extended operation. The resulting CUF must remain less than unity as required by the Code during the period of extended operation. The discussion for 10 CFR 54.21(c)(1)(iii) refers to the GALL report, Chapter X, and implies that the NRC staff accepts only fatigue monitoring programs as the basis There is no ASME Code requirement that a CUF less than 1.0 must be maintained throughout the operating life of a Class 1 component. The CUF< 1.0 requirement is a design requirement, intended to demonstrate confidence that a Class 1 component can be safely put into service. The requirements for continued service are contained in the ASME Code Section XI. These requirements include demonstration of continued serviceability through periodic inservice inspection and testing. Detection of indications or conditions exceeding acceptance requirements could lead to supplementary examinations, engineering evaluations, or repair/replacement. This Section XI (a) Fatigue ca

inspection procan justify it caeffects. Under inspection can be reviewed obasis because approved procnot referenced of outstanding against it that Further staff reif an applicant Appendix L. b) Resolution that GALL muenvironmental rationale is thaeffects are not does not agrerecommendat
NUREG-1739 B.2.3-16 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-8 (cont.) for managing fatigue effects. The SRP-LR states that “staff has evaluated a program that monitors and tracks the number of critical thermal and pressure transients for the selected reactor coolant system components. The staff has determined that it is an acceptable aging management program to address metal fatigue of the reactor coolant system components according to 10 CFR 54.21(c)(1)(iii).” (b) Finally, the TLAA discussion describes Generic Safety Issue 190, including a statement that “Based on the results of probabilistic analyses, along with the sensitivity studies performed, the interactions with the industry (NEI and EPRI), and different approaches available to the licensees to manage the effects of aging, it was concluded that no generic regulatory action is required, and that GSI-190 is resolved.” The SRP-LR goes on to state that “However, the calculations supporting resolution of this issue, which included consideration of environmental effects, and the nature of age-related degradation indicate the potential for an increase in the frequency of pipe leaks as plants continue to operate. Thus, activity should also be acceptable to the NRC staff. Other activities, such as the use of non-mandatory flaw tolerance methods combined with periodic inservice examination, should be acceptable to the NRC staff as the basis for managing the effects of fatigue. References to augmented TLAA evaluations that include reactor water environmental effects should be eliminated from the SRP-LR and the GALL report. The GALL report should recognize only that the two completed license renewal applications were required to address GSI 190, which was an open issue at the time, and that GSI 190 is now closed. It is the intent of the industry to provide a generic demonstration of the effects of reactor water environments on fatigue life. This generic demonstration has already been submitted, in large measure, to the NRC staff for review. The industry intends to complete this generic demonstration and submit the final set of reports to the NRC staff for review and acceptance, thus avoiding the need for individual license renewal applicant submittals concerns relat

the fatigue calTLAA. The issseparated. The GALL repaddress this c
April 2001 B.2.3-17 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IV-8 (cont.) the staff concluded that licensees must address the effects of coolant environment on component fatigue life as aging management programs are formulated in support of license renewal.” in this regard. G-IV-9 GALL Every place the “aging effect” is identified as “cumulative fatigue damage” should be revised to “cracking.” Fatigue damage will eventually manifest itself as a crack. That is the effect to be managed. Usage is mon

cracking direcdirectly monitothe cumulative prevent crackidamage is the effect and termThe GALL repaddress this c

G-IVA1-1 IV-A1.1.1, A1.1.2, A1.2.7, A1.4.1, A1.4.5, A1.5.1 through A1.5.6 In every location where the GALL refers to BWRVIP-29 (TR-103515), replace the reference with “EPRI TR-103515, Rev. 2 (BWRVIP-79) or later approved version of TR103515. The EPRI document referred to has been updated as of March 2000. The latest issue is TR-103515, Rev.2. NRC staff in EMCB has the document. This document is updated periodically to identify the latest enhancements to the water chemistry programs. As such, the GALL ought to recognize such. EPRI TR-1035

29) or later apacceptable. BWreplaced by BWgeneric review not been requhas not been The GALL repaddress this c
NUREG-1739 B.2.3-18 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA1-2 IV-A1.1.4 Under the AMP column and in the Evaluation and Technical Basis column, delete the reference to GE RICSIL 055. While the RICSIL is a tool that can be used by an owner to manage cracking, it is not necessary. The Code examinations are adequate to manage aging effect of cracking. The reference

documents su455, 462, or 4While the RICbe used by an cracking, it is nThe staff will rdescription to the RICSIL. The GALL repaddress this c

G-IVA1-3 IV-A1.2.4 and A1.2.6 In the first occurrence of this item the following changes should be made in the Evaluation and Technical Basis column. In the sentence that begins with “ In accordance with approved BWRVIP-74”, after the “a)” the words “and axial reactor vessel welds” need to be deleted. In the same sentence, delete item “d)” in its entirety. Examination of RPV axial welds is already required by ASME Section XI. Therefore, there is no reason to evaluate the need for examining this group of welds. The CLB, in conjunction with the requirements of 10CFR50 Appendix G and H is more than adequate to manage the effects of neutron embrittlement. There is neither basis for requiring an owner to assess failure probability of these welds nor any other component to manage loss of fracture toughness. (1) The words 

vessel welds” “a).” (2) The item dapproach specdated May 7, 2referenced. The GALL repaddress this c
April 2001 B.2.3-19 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA1-4 IV-A1.3.2 Revise the last 3 lines of the AMP column to read: “NUREG-0619 and NRC Generic Letter 81-11 or alternative recommendation of GE NE-523- A71-0594. The GE document is an approved alternative to NUREG-0619 and GL 81-11 not an additional requirement. The appropria

Feedwater NoVol. 2) include(ISI) in conformrequirements Society of Mec(ASME) CodeSubsection IW(1995 edition taddenda, or laapproved in 10 revised by the NUREG-0619Regulatory CoGeneric Letter alternative recGeneral Elect0594. The GE approved alte0619 and GL 8The GALL repaddress this c

G-IVA1-5 IV-A1.3.2 and A1.3.3 Change the “Further Evaluation” column to read “No, fatigue is managed through an inspection program.” Also, change the aging effect to “cracking.” As noted for the same item where the effect to be managed is cracking due to cyclic loading (read fatigue), there is an acceptable inspection program to assure the aging effect is managed. This approved required program assumes the component is cracked and requires a conservative inspection program to assure a postulated flaw would not exceed code allowable limits. The approved alternative program assumes the component is cracked, calculates a There are app

feedwater and However, desfor these nozzneed to be extTherefore (for A1.3-d, items the fatigue evaa TLAA and th“Further Evalucommented th“aging effect” “cumulative fa
NUREG-1739 B.2.3-20 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA1-5 (cont.) remaining life and then specifies an inspection frequency. All of this is done to manage the effect of cracking caused by fatigue. Every time the component is examined and confirmed to be crack free, the time to failure assumed in the evaluation is reset, thus this is not a TLAA. Since this program assumes cracking has occurred (i.e. fatigue has initiated a crack) and conservatively specifies an inspection frequency based on this assumption, it is obvious that the effects of fatigue are being managed by inspection and nothing else is required. should be revi

staff believes monitored to pdirectly. The Amonitor crackicumulative uscracking. Cumdamage is the effect and termGALL report waddress this c

G-IVA1-6 IV-A1.4.1 and A1.4.5 Delete the reference to the BWRVIP-03 internals examination guidelines. BWRVIP-03 is applicable to components inside the RPV, not to safe-ends outside the vessel. The aging effe

ends are man“BWR Stress Cand XI.M2 “W(NUREG-1801XI.M7 referencinternals examThe GALL repaddress this cthe reference because safe-in the BWRVIP
April 2001 B.2.3-21 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA1-7 IV-A1.4.3 a) Change the “Further Evaluation” column to read “No.” b) Also, change the aging effect to “cracking.” This is not a generic issue. There are only 2 BWRs that have not cut and capped the CRDRL nozzle. Further, for those 2 plants, the aging effect of cracking due to fatigue is managed by NUREG-0619 inspections. Thus fatigue is managed via inspection. a) The safe-en

a TLAA. NUREG-0619 Section XI, ExB-D, which incwelded nozzlethe nozzle saf(b) NEI commin GALL the “aidentified as “cdamage”, it sh“cracking.” Thusage is monicracking direcdirectly monitothe cumulative prevent crackidamage is the effect and termThe GALL repaddress this c
NUREG-1739 B.2.3-22 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA1-8 IV-A1.5.1 through A1.5.6 Revise the last sentence in the “Preventive Action” statement to read: Also, hydrogen water chemistry may be used as a means to enhance IGSCC mitigation. Use of HWC is an option an owner may want to use. However, control of water chemistry by implementing TR-103515 is sufficient and HWC is not required. The staff has approved the BWRVIP Program documents for license renewal use based on normal water chemistry that remains within the parameters of EPRI TR- 103515. The aging effe

vessel penetraAMPs XI.M8 “Penetrations” Chemistry” (NVIP-62 referenthe GALL repohydrogen wateVIP-62 and VIreferences. (Vinspection proThe GALL repaddress this c

G-IVA2-1 A2.1.1 Add cracking at welded joints (growth of fabrication flaws) due to service loadings. See EPRI NP- 1406-SR for justification. Dome welds examined in accordance with Section XI, Examination Category B-A. If this not an aging effect then why are welds examined each inspection interval. If not in the GALL then assume examinations may be discontinued in the period of extended operation. See BAW-2251A and associated NRC SER. GALL is not consistent with approved B&WOG topical reports. See NRC disp

Comment G-IVAppendix B, TThe GALL repaddress this c
April 2001 B.2.3-23 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-2 A2.1.1, A2.1.3 Remove all references to ISI for managing Boric Acid Corrosion. See justification for comment on item XI.M5. The Boric Acid 

the GALL repoimplementatioLetter 88-05, pprogram for insteel structureevidence of bocorrosion. ASMinspections (ISduring the perand hydrostatfrom BAC progindependent oThe GALL repaddress this c
NUREG-1739 B.2.3-24 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-3 A2.1.3 Remove references to RG 1.65 in program element (2). Design requirements are not part of aging management program preventive actions. The words “de

were deleted fPreventive AcEvaluation and discussion. Threquirements were removed they are not comanagement preventive-maare a CLB reqcontinue into tRG 1.65 preveas the use of atreatments anpresented in Gmitigation meaoption for redufor the AMP to The GALL repaddress this c

G-IVA2-4 A2.1.3 For “wear” in closure head studs, include replacement along with repair in (7) Corrective Action. Repair or replacement should be jointly used for corrective action descriptions, as in the item for SCC directly above. Element (7) of 

Technical Basrevised as sugcomment to inreplacement foThe GALL repaddress this c
April 2001 B.2.3-25 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-5 A2.1.4 Delete vessel flange leak detection line. Line is considered as piping at B&W operating plants and was not shipped with the vessel. This compone

vessel report (vessel flange the LR functioboundary in sobeen included applications. Ecomponent masome plants, tshould be genaccommodate have this comThe GALL repaddress this c

G-IVA2-6 A2.1.4 Delete the leak detection line. The line is piping and is not part of a vessel. In addition, for some plants, the line is not subject to aging management review. See NRC disp

comment G-IVAppendix B, T

G-IVA2-7 A2.2 Add flange bolting. Missing items. See BAW-2251A description of flange bolting and nut ring. New item A2.2

was added to item is describThe aging effeloss of preload relaxation, cra(BAW-2251 domechanism foof material becThe GALL repaddress this c
NUREG-1739 B.2.3-26 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-8 A2.2.1 CRDM nozzles are SB-167 at B&W- designed plants. The CRDM nozzle material is SB- 167 as described in BAW-2251A. SB-167 was a

SB-166 to the (These are bodifferent prodususceptibilities The GALL repaddress this c

G-IVA2-9 A2.2.1 Remove reference in program element (10) to SS. This requirement has been removed from the latest revision of SRP-LR Chapter 4.2 and does not apply. Removed refe

element 10. The GALL reprevised to add

G-IVA2-10 A2.2.1 Change name of Structure and Component to CRD Head Penetration. The CRD part of concern is the piece which penetrates the upper head. Replaced the 

with “Head Pe“Structures ancolumn.” The GALL repaddress this c
April 2001 B.2.3-27 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G–IVA2-11 A2.2.1 Modify the wording under “Aging Management Program” to The program includes inservice inspection in accordance with ASME Subsection IWB, Table IWB 2500-1 or for susceptible components and locations an industry wide, integrated, long-term inspection program based on the industry responses to NRC Generic Letter (GL) 97-01 contained in NEI letter Dec, 11, 1998, Dave Modeen to Gus Lainas, “Response to NRC RAIs on GL 97-01” and individual plant responses. Primary water chemistry is monitored and maintained in accordance with EPRI guidelines in TR-105414 (Rev. 3 or later revisions or update) to minimize the potential of crack initiation or growth. “Integrated” has always been intended to mean “industry wide,” yet here it could be construed to be confined to the individual unit and mean something else, like “covering ALL head penetrations,” or something else. It is difficult to say that NRC GL97- 01 contains “guidelines” of any sort. The appropriate inspection for a given unit may be NEVER, depending on conditions. The descriptio

revised as reccomment. The GALL repaddress this c
NUREG-1739 B.2.3-28 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-12 A2.2.1 Modify the (1) Scope of Program to: The program includes inservice inspection (ISI) in accordance with ASME Subsection IWB, Table IWB 2500-1, or for susceptible components and locations an industry wide, integrated, long-term inspection program based on the industry responses to NRC Generic (GL) 97-01 contained in NEI letter Dec, 11, 1998, Dave Modeen to Gus Lainas, “Response to NRC RAIs on GL 97-01” and individual plant responses. Preventive measures are in accordance with EPRI guidelines in TR-105714 to mitigate primary water stress corrosion cracking (PWSCC). An integrated cracking susceptibility assessment in accordance with industry susceptibility models and inspection results was performed in response to GL 97-01, to define the most susceptible plants and rank them in accordance with their susceptibility. This information is used by each plant to determine the proper timing of vessel head penetration examinations, either during the current license period or the period of license renewal, if necessary. Significant changes in the industry models as future plants inspect may require reassessment. The assessment referred to was performed in response to GL 97-01 and subsequent RAIs, and would not be expected to significantly change (other than accumulation of time-at-temperature) unless inspection results from lead plants indicate significant deficiencies in the models used by the industry to perform the assessments and plant rankings. The models were used to define the most susceptible “plants,” not necessarily the most susceptible “components.” The requirements for any “periodic inspections has yet to be established. The Evaluatio

discussion warecommended change in worNEI recommeThe GALL repaddress this c
April 2001 B.2.3-29 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-13 A2.2.1 Modify (3) Parameters Monitored / Inspected to: The AMP monitors the effects of PWSCC on the intended function of the CRD head penetrations by detection and sizing of cracks and coolant leakage by ISI. Susceptibility assessment was performed in response to GL 97-01 utilizing the most current industry susceptibility models that were based on material and operating parameters and inspection results to date, to rank plants in accordance with their susceptibility. This information is used to develop a plant-specific long-term inspection program, including schedule, scope and determination whether an augmented inspection program of nozzle penetrations, including a combination of surface and volumetric examination, is necessary. Significant changes in industry models may require re- assessment. The assessment is not performed in response to license renewal. Do not refer to the “mechanism.” The Evaluatio

discussion in trevised to addThe GALL repaddress this c
NUREG-1739 B.2.3-30 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-14 A2.2.1 Clarification to (4) (4) Detection of Aging Effects: Aging degradation of the CRD head penetration cannot occur without crack initiation and growth. Based on GL 97-01, the applicant should review the scope and schedule of inspection, including leakage detection system, to assure detection of cracks before the loss of intended function of the components. Should not refer to “mechanism.” The word “me

deleted from ttechnical basis The GALL repaddress this c

G-IVA2-15 A2.2.1 Typo in (5) Monitoring and Trending: change “provides” to “provide.” Typo. Typo was corr

element (5) MTrending. The GALL repaddress this c
April 2001 B.2.3-31 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-16 A2.2.1 Modify wording in (6) Acceptance Criteria: Any SCC degradation is evaluated in accordance with IWB-3000 by comparing ISI results with the acceptance standards of IWB-3400 and IWB-3500. However, if there have been significant changes since the applicants response to GL 97-01 and the RAIs to it, then the applicant should either provide updated information on crack initiation and crack growth models and the data used to validate these models (or references to appropriate industry model revisions) to verify adequacy of the inspection program and acceptance criteria. The information requested was provided in the responses to GL- 97091 and the RAI responses, primarily through references. Applicants should not have to provide it again unless something changes significantly. The Evaluatio

discussion warecommendedsentence has element 6: To the long-term and acceptanchave been sigthe applicants and the RAIs tshould either pappropriate inor provide updcrack initiation data and modThe GALL repaddress this c

G-IVA2-17 A2.3.1 to A2.3.3 Assessment of fracture toughness changes due to neutron irradiation in accordance with 10CFR50, Appendix G for the reactor vessel inlet and outlet nozzles can not be accomplished. Note that Generic Letter 92-01, Revision 1, Supplement 1 did not address the nozzle materials. It appears that GALL intends to backfit these vessel beltline requirements to the nozzles. Assessment of fracture toughness changes due to neutron irradiation in accordance with 10CFR50, Appendix H for the reactor vessel inlet and outlet nozzles can not be accomplished because the surveillance program adopted for the beltline materials is already in place and can not be changed to include specimens from the nozzles. It does not need to be accomplished for the nozzles because empirical and analytical tools are available to perform the Appendix G analysis. The Evaluatio

discussion waincorporate thNEI Comment Appendix B, TThe GALL repaddress this c
NUREG-1739 B.2.3-32 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-18 A2.3.1, A2.3.3 Delete fluence threshold of 1.0E17 n/cm2. Nozzles are not limiting materials in accordance with BAW-2251A. Reduction of fracture toughness is not an applicable aging effect. 10 CFR 50.60 and 50.61 calculations apply to beltline items. Nozzles not in beltline for period of extended operation. See NRC disp

Comment G-IVTable B.2.3. Tfluence threshThe GALL repaddress this c

G-IVA2-19 A2.3.1, A2.3.3 See Comment 31 regarding cracking. Examination Category B-D manages cracking at welded joints at cracking at nozzle IR. NRC SER of BAW-2251A. See NRC disp

Comment G-IVAppendix B, TNote the followcomment: ComNEI comment Appendix B, TThe GALL repaddress this c

G-IVA2-20 A2.3.1, A2.3.3, A2.5.1, A2.5.2 Remove last sentence of Evaluation and Technical Basis, “Applicants are to determine...etc.” This requirement has been removed from the latest revision of SRP-LR Chapter 4.2 and does not apply. The last sente

Technical Basthat the GALL with SRP-LR. The GALL repaddress this c

G-IVA2-21 A2.4.1, A2.4.3 Remove “Cyclic Loading” from Aging Mechanism entry. SCC is adequate to describe Mechanism. Cyclic Loading is duplicative of Fatigue entry. Growth of SCC cracks can result from loading other than cyclic. Cyclic loading 

“Aging Mechabottom row on The GALL repaddress this c
April 2001 B.2.3-33 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-22 A2.4.1, A2.4.3 For Nozzle Safe Ends, Crack Initiation and Growth is attributed to SCC and Cyclic Loading. Cyclic loading is generally associated with fatigue and is classified as a TLAA. Explain the relation between the identified program elements and cyclic loading. New application for existing program requires justification. Cyclic loading 

“Aging Mechabottom row on The GALL repaddress this c

G-IVA2-23 A2.5 Add bottom head. Missing items. Bottom head w

additional comShell. Fatigue aging mechanfatigue as an aThere is no otthis componeninservice inspecomponent walicense renewby 10 CFR 50The GALL repaddress this c
NUREG-1739 B.2.3-34 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-24 A2.5.1, A2.5.2 Vessel Shell—missing cracking at welded joints and intergranular separations of SA 508 Class 2 forgings clad using a high heat input welding process. Exam. Cat. B-A requires volumetric inspections of vessel welds. NRC SER of BAW-2251A. Earlier comme

1c) on crackinmechanism alat weld joint. Intergranular sClass 2 forginheat input weladdressed in titem was addefor SA 508 Clamechanism is aging effect is a TLAA. TLAA SRP-LR (p. 4.line item for cradded. The GALL repaddress this c

G-IVA2-25 A2.5.3 The topic is Loss of Material due to Wear on the Vessel Flange. The Evaluation and Technical Basis discussion is for Core Support Pads. Revise to made the discussion applicable to the Vessel Flange. Discussion should be applicable to the component being discussed. The Evaluatio

discussion waappropriate cosuggested. Modescription of XI minimizes tthe GALL repoThe GALL repaddress this c
April 2001 B.2.3-35 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-26 A2.6 Add parenthetical (interior attachments). Core guide lugs for B&W plants. In he “Structur

column, “core retained and “added. The GALL repaddress this c

G-IVA2-27 A2.6 Aging mechanism should be PWSCC. Appropriate AMP is ASME Section XI, Examination Category B-N-2. NRC SER of BAW-2251A. PWSCC is an 

PWR alloy 600 exposed to reacorresponding program is plarecommended G-IVA2-28 in tTable B.2.3) bgeneric alloy-6by NRC excephead penetratThe NEI recomappropriate AMSection XI, ExB-N-2 is inconcomment G-IVproposed a plaThe GALL reppartially addreidentifying PWmechanism as 
NUREG-1739 B.2.3-36 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-28 A2.6 For Core Support Lugs, crack initiation and growth, a plant-specific program is to be evaluated. Change the “further evaluation” text from “Yes, No AMP” to “Yes, Plant- Specific AMP.” Consistency with previous format. See NRC disp

Comment G-IVAppendix B, TThe GALL repaddress this cthe AMP to be 

G-IVA2-29 A2.6 The topic is Loss of Material due to Wear on the Core Support Lugs. The (2) Preventive Actions refers to “attrition” due to wear. Make the words consistent as “loss of material.” Descriptive wording should be consistent throughout. Word “Attrition

“loss of matermade throughThe GALL repaddress this c

G-IVA2-30 A2.7 Change parenthetical to (bottom head and/or closure head). Missing instrumentation penetrations in closure heat at 2 B&W operating plants. Instrument tub

closure head (as separate coA2.7.3). They instrument tubbottom head bmanagement different. AMP specified for towhereas plantspecified for bpenetrations. The GALL repaddress this c
April 2001 B.2.3-37 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVA2-31 A2.7.1, A2.7.2 Change the “further evaluation” text from “Yes, No AMP” to “Yes, Plant- specific AMP.” Consistency with previous format. For A2.7.1, the 

Evaluation” co“Yes, Plant-spFor A2.7.2, the as the one for rod drive head A2.2.1). The GALL repaddress this c

G-IVA2-32 A2.5.3 Remove “Design requirements” from element (2) of the Wear/Loss of material Evaluation and Technical Basis. Design requirements are not an aging management activity. The words “de

were removed Additional chamentioned in tNEI Comment Appendix B, TThe GALL repaddress this c

G-IVA2-33 A2.6 Remove entry for Wear/Loss of Material. There is insufficient relative motion between the pad and adjacent parts to generate degradation. The entry provides no reference or operating experience to justify this mechanism. There is insuff

between the cadjacent parts degradation. Wfor this compoThe GALL repaddress this cthe aging effecmaterial” for th
NUREG-1739 B.2.3-38 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB1-1 IV-B.1.1.1, B1.1.2, B1.1.3, B1.1.4, B1.1.5, B1.1.6, B1.1.7, B1.2, B1.3.1 through B1.3.4, B1.4.1 through B1.4.8, B1.5.2, B1.6.1 through B1.6.3 Delete the second and third sentence of the “Preventive Action “ statement. If the NRC staff insists on retaining a statement related to hydrogen water chemistry it should be revised to read: It is also possible to use hydrogen additions to enhance the inhibition of IGSCC. Hydrogen addition is very effective in reducing the electrochemical potential in recirculation system piping and to a lesser degree, in the core region. Noble metal additions through a catalytic action increase the effectiveness of hydrogen additions in the core region. Use of HWC is an option an owner may want to use. However, control of water chemistry by implementing TR-103515 is sufficient and HWC is not required. The staff has approved the BWRVIP Program documents for license renewal use based on normal water chemistry that remains within the parameters of EPRI TR- 103515. See NRC disp

comment G-IVAppendix B, TThe GALL repaddress this cacknowledging chemistry may to enhance IG.

G-IVB1-2 IV-B.1.1.1,

B1.1.2, B1.1.3,B1.1.4, B1.1.5,B1.1.6, B1.1.7,B1.2,B1.3.1 throughB1.3.4,B1.4.1 throughB1.4.8, B1.5.2,B1.6.1 throughB1.6.3

In every location where the GALLrefers to BWRVIP-29 (TR-103515),replace the reference with “EPRITR-103515, Rev. 2 (BWRVIP-79) orlater approved version ofTR103515.

The EPRI document referred to hasbeen updated as of March 2000.The latest issue is TR-103515,Rev.2. NRC staff in EMCB has thedocument. This document isupdated periodically to identify thelatest enhancements to the waterchemistry programs. As such, theGALL ought to recognize such.

EPRI TR-103529) or later apacceptable. BWreplaced by BWBWRVIP 79 hgenerically revThe GALL repaddress this c
April 2001 B.2.3-39 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB1-3 IV-B1.1.2, IV-B1.3.1 through B1.3.4, B1.4.1 through B1.4.8, B1.5.1 For the aging effect of cumulative fatigue damage, change the “Further Evaluation” column to read “No.” For fatigue of 

components, trevised to statfor which a fatbeen performeperiod, fatigue aging analysis evaluated for toperation. Thibe added for PThe GALL repaddress this c

G-IVB1-4 IVB-B1.1.2 and B1.1.3 Delete the reference to VT-3 and ASME Section XI. Reword first sentence of “AMP” column to read: Visual and ultrasonic examinations are performed in accordance with the guidelines of BWRVIP-03 for reactor pressure vessel internals. This component is not a “welded core support structure” and is thus not subject to the requirements of ASME Section XI. The BWRVIP requirements are sufficient to manage aging effects. Inspections ar

according to Ban expanded and ASME SeThe GALL repaddress this c

G-IVB1-5 IV-B1.1.5 Add an asterisk to the statement in the “Further Evaluation” column. Add a footnote at the bottom of the table that reads: “The staff is currently reviewing this program. If the program is approved, no further evaluation will be required.” This is similar to B1.1.1. The BWRVIP program, once approved by the staff will be adequate to manage aging effects. The BWR VIP 

no further evarecommendedThe GALL repaddress this c
NUREG-1739 B.2.3-40 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB1-6 IV-B1.1.6 Delete this item. The NRC approved BWRVIP documents show that the standby liquid control (SLC) line inside the reactor vessel is not necessary and as such no inspections are necessary to manage aging. BWRVIP-27 does have inspection provisions for the SLC lines outside the reactor vessel. Those inspection should be in another section of the GALL and not in the internals portion. Item B1.1.6 w

the SLC line inno license renfunction. Howeof the vessel icovered in item program XI.M9 Internals” was BWRVIP-27 to The GALL repaddress this c

G-IVB1-7 IV-B1.2 Delete the reference to VT-3 and ASME Section XI. Reword first sentence of “AMP” column to read: Visual and ultrasonic examinations are performed in accordance with the guidelines of BWRVIP-03 for reactor pressure vessel internals. This component is not a “welded core support structure” and is thus not subject to the requirements of ASME Section XI. The BWRVIP requirements are sufficient to manage aging effects. Inspections ar

according to BReference to VSection XI waThe GALL repaddress this c

G-IVB1-8 IV-B1.5.1 Delete this item from the GALL. The approved BWRVIP documents show that management of aging effects is not required for the orificed fuel support casting (BWRVIP-06, etc.). This line item 

SCC of OFS winsignificant in The GALL repaddress this c

G-IVB1-9 IV-B1.6.1 through B1.6.3 Delete this item from the GALL. The instrument penetrations are addressed in BWRVIP-49 and should be discussed in the RPV section. The housing inside the vessel is not safety related and does not require an aging management program. This item was 

GALL report. Tinstrumentatiohas been deleThe existing Ainternals progplenum. The GALL repaddress this c
April 2001 B.2.3-41 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB1-10 IV-B1.7 Delete this item from the GALL. This item is not safety related and not subject to an aging management program. The correct na

component is bracket attachThe susceptibattachment weto the vessel wsafety related. in the GALL reA1.2.7, “AttachThe GALL repaddress this c

G-IVB2-1 All Delete void swelling from all items except B2.4.1. For the Evaluation and Technical Basis entry for void swelling, delete “The applicant should address loss of ductility associated with swelling.” (STH/FPL) Wording under the Aging Management Program column appears to be acceptable. The Westinghouse position on this issue is that void swelling is only applicable to the baffle/former plates. Additionally, the change in material properties, if any, will not affect the ability of the baffle/former plates to perform their intended functions (core support and flow distribution). From Calvert C

of concern is tof dimension dthe ability of thfunction. Indusdecide whethesignificant issu“The applicant of ductility asshas been delestatement has AMP column fdimensions du“The applicant specific AMP oindustry prograging effects aappropriate AMapplicant provconcluding thaan issue for thThe GALL repaddress this c
NUREG-1739 B.2.3-42 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-2 All SCC and IASCC have been combined in the latest revision. The only internals parts subject to IASCC per Westinghouse topical are Item Numbers B2.3.1, B2.3.4, B2.4.1, B2.4.2, B2.5.1, B2.5.2, B2.5.4, and B2.5.5. SCC and IASCC should be segregated again and IASCC indicated for the above item numbers only. (STH/FPL) The Westinghouse position is that only internals parts subject to fluences greater than 1 x 1021 have the potential for IASCC. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB2-3 All The only internals parts subject to irradiation embrittlement are Item Numbers B2.3.1, B2.3.4, B2.4.1, B2.4.2, B2.5.1, B2.5.2, B2.5.4, and B2.5.5. It should be indicated as a mechanism for these item numbers only. (STH/FPL) The Westinghouse position is that only internals parts subject to fluences greater than 1 x 1021 have the potential for irradiation embrittlement. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB2-4 All Reference to ASME Section XI should be deleted from the References, Existing AMP, and Evaluation and Technical Basis columns for all SCC entries. (STH/FPL) The effects of SCC on PWR austenitic stainless steel are precluded by material selection (e.g., Reg. Guide 1.43) and control of chemistry (oxygen and other debilitating constituents) in the reactor coolant. Material selec

water chemistSCC. See NRC dispcomment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-43 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-5 B2.1.1, B2.1.4, B2.1.7 For SCC/IASCC in the RV upper internals, item (10) Operating Experience refers to cracking in SS baffle former bolts and states that the mechanism of this particular cracking has not yet been resolved. Delete this reference to bolts in (10). The location and geometry of the bolts is not consistent with the upper internals components being described. The fact that the cracking mechanism has not been identified makes this an inappropriate piece of information. GALL was refo

AMPs to a ceChapter XI of new AMP XI.Mreflects the coin its element Experience. The GALL repaddress this c

G-IVB2-6 B2.1.1, B2.1.4, B2.1.7 For the aging effect of “changes in dimension due to void swelling” the AMP column identifies the fact that the RV Internals receive a visual inspection per ASME Section XI, implying that this inspection is intended to manage void swelling. This is not correct since void swelling is not recognized as a mechanism, which requires management. An “acceptable” alternate AMP is described in this column. Move the description of an acceptable program to the Technical Basis column. The requirement to address loss of ductility associated with void swelling is included in the Technical Basis. It should be deleted. Current programs are not intended to detect the effects of void swelling. Since the Technical Basis column identifies what is required of an applicant, it should also describe what is acceptable.If loss of ductility is a valid effect of swelling, then it should be included explicitly in the aging effects column. In line items o

toughness, voas a mechanisneutron irradiaNo other chanAMP column fSimilar changethroughout GASections IV B2The GALL repaddress this c
NUREG-1739 B.2.3-44 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-7 B2.1.1, B2.1.4, B2.1.7 B2.1.2 B2.1.3, B2.1.5, B2.1.6 B2.2.1, B2.2.2, B2.2.3, B2.3.1, B2.3.4, B2.4.1, B2.4.2, B2.5.2, B2.5.6 to end Program cited is Section XI and (4) Detection of Aging Effects describes inspections that are not part of Section XI – the description of detection in addition to B-N-3 should be modified to reflect ongoing industry initiatives and not recommend specific inspections. A statement such as “participation in industry programs to investigate aging effects and determine appropriate inspections, with reports to the NRC on a periodic basis.” This applies to void swelling, IASCC, SCC, reduction in fracture toughness due to irradiation embrittlement and thermal embrittlement, and loss of closure integrity due to stress relaxation. NUREG 1733, Safety Evaluation Report Related to the License Renewal of Oconee Nuclear Station, Units 1,2 and 3. There are significant industry efforts under way to determine appropriate inspections for RV internals as referenced on ONS SER. The response 

follows: (a) Void swellidispositions to G-IVB2-1 & GAppendix B, T(b) IASCC/SCtoughness: a paugmentation Subsection IWenhanced visubolting compodemonstrated methods for bResponse in “column was chto a “No.” Similar changeSections IV B2The GALL repaddress this c

G-IVB2-8 B2.1.2 For “Loss of Fracture Toughness due to Thermal Aging and Neutron Irradiation Embrittlement” the environment includes a Neutron Fluence of greater than 10E17 n/cm2 (E > 1 MeV). Identify the basis for this threshold value for irradiation embrittlement in CASS. The 10E17 fluence value for irradiation embrittlement is valid for low alloy steels such as the reactor pressure vessel. There is no basis for also assigning it to stainless steel material. –W- expects the threshold to be at least 10E21 n/cm2 (E > 1 MeV). See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-45 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-9 B2.1.2 Delete reference to CASS and associated thermal embrittlement for this item. Per previous comment, Westinghouse plants do not have CASS in the upper support columns. Some plants do have mixing vane devices made of CASS, however these do not perform any intended function. The comment 

plants do have made of cast asteel (CASS), a mixing vane function. SectiRev. 1 of WCAhistory of vane RCCA spiderstravel inhibited Although thesthemselves pefunction within to prevent satiaccomplishmeby another syscomponent placontext of liceaccordance wand hence agbe provided foThe GALL repaddress this c
NUREG-1739 B.2.3-46 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-10 B2.1.7 Loose parts monitoring and neutron noise monitoring (excore detectors were added to the Aging Management Program column. These entries should be deleted. Visual inspections of the reactor vessel internals performed in accordance ASME Section XI provide an adequate aging management program for portions of the internals outside the fuel assembly region. SRP-LR Appendix A.1.2.3.10 states that operating experience should provide objective evidence to support that the effects of aging will be adequately managed so that the structure and component intended function(s) will be maintained during the period of extended operation. In fact the operating experience provided indicates that there is no need for loose parts monitoring or neutron noise monitoring to manage aging effects associated with the reactor vessel internals. For items B2.1

AMP column wthat the AMP part monitorinmonitoring in aSection XI insWCAP 14577 for keeping bomonitoring and states (4th par

“The use of nemonitoring (excombination wtool to track/obvibrations. A cabove monitorprevent relaxaspring and clebecoming a sirenewal issueThe GALL repaddress this c
April 2001 B.2.3-47 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-11 B2.1.7 Delete this item completely. For the –W- design, the hold-down spring does not perform any intended function, and does not require an aging management review The hold-down 

the functions (Section 2.2 of WCAP-14577support and osupport, oriencontrol rod assprovide a passguidance and instrumentatio2.6.5 of the toinstances in wdegradation ooccurred early development oindicative that component coissue. The GALL repaddress this c

G-IVB2-12 B2.2.1, B2.3.2 Delete wear as an aging effect for these items. Measurements have shown this effect to be not significant, or insignificant relative motion to result in wear. The wear of th

is not significaconfirmed in Witem for wear oGALL will be rcomment. The GALL repaddress this c

G-IVB2-13 B2.3.1 thru B2.3.4 GALL now has a fluence threshold specified in the Environment column and examination category B-N-2/B- N-3 was added. However, the effect should only be listed for item B2.3.1, the core barrel. The core barrel is the only item that is exposed to neutron fluences in excess of the embrittlement threshold. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-48 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-14 B2.4.1 Category B-N-2 needs to be added with each entry of B-N-3. Use of the B-N-2 / B-N-3 pairing is not consistently applied to components in this section. GALL sections 

were revised afollowing reasCategory B-N-interior attachmCategory B-N-“removable cogerally all othecomponents. FIV-B2, B3 and should be the cases. The GALL repaddress this c

G-IVB2-15 B2.5.1, B2.5.6, B2.5.7 Of this grouping, IASCC should only apply to item number B2.5.1 (Lower Core Plate). The lower core plate is the only item that is exposed to neutron fluences in excess of the embrittlement threshold. See NRC disp

comment G-IVTable B.2.3. This line item crack initiation be caused by components IAThe GALL repaddress this c
April 2001 B.2.3-49 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-16 B2.5.2, B2.5.5, B2.5.7 Of this grouping, IASCC should only apply to item number B2.5.2 (Fuel Pins). The fuel alignment pin is the only item that is exposed to neutron fluences in excess of the embrittlement threshold. See NRC disp

comment G-IVTable B.2.3. This line item crack initiation be caused by components IAThe GALL repaddress this c

G-IVB2-17 B2.5.2, B2.5.5 Of this grouping, reduction in fracture toughness due to irradiation embrittlement should only apply to item number B2.5.2 (Fuel Pins). The fuel pin is the only item that is exposed to neutron fluences in excess of the embrittlement threshold. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB2-18 B2.5.3, B2.5.4 IASCC should not apply to these items. Neither of these is expected to be exposed to neutron fluences in excess of the embrittlement threshold. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB2-19 B2.5.3, B2.5.4 Reduction in fracture toughness due to irradiation embrittlement should not apply to these items. Neither of these is expected to be exposed to neutron fluences in excess of the embrittlement threshold. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-50 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-20 B2.6.2 For wear, the Reference column should include I&E Bulletin 88-09, existing program material should be replaced with “utility response to Bulletin 88-09”, and Technical Basis column should reflect Bulletin 88-09 requirements. B 88-09 is the basis for the current programs. NRC BL 88-09 

included in the utility responscited in the AMin accordance comment. In aSection XI inswere included The GALL repaddress this c

G-IVB2-21 B2.2.1, B2.4.2 References to the Code were deleted for items B2.2.1 (wear) and B2.4.2 (stress relaxation), and references to the Tech Specs were deleted for item B2.4.2 (SCC/IASCC). Need to confirm if this is an issue. NEI confirmed 

2000, meeting issue. The GALL repaddress this c

G-IVB2-22 B2.2.1 Delete rod drop time testing to detect wear of the guide tube cards. Rod drop time testing will not detect wear of the RCA Guide tube during operation. This test is done prior to startup and if the rods do not meet the rod drop time specified; action must be taken prior to startup. The wear wou

This was conf14577. The GALL repaddress this c

G-IVB2-23 Page IVB2-25 The rows on page IVB2-25 are not aligned with their corresponding items on Page IVB2-24. It appears that the last row should be at the top of the page. Correct the alignment. Editorial. Alignment of r

corrected. The GALL repaddress this c
April 2001 B.2.3-51 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB2-24 B2.6.2 Loss of Material due to Wear on the Flux Thimbles is described as “same as” wear on the upper core plate alignment pins. Delete this and replace with reference to I&E Bulletin 88-09. Program should be “utility response to Bulletin 88-09.” Technical basis should reflect 88-09 requirements. The type of wearing action is substantially different between the flux thimble and the core plate alignment pins. Utility action was required in response to 88-09. NRC GL 88-09 

included in GAdisposition of G-IVB2-20 in tTable B.2.3. The GALL repaddress this c

G-IVB3-1 B3.1.1, B3.1.3 Delete IASCC as a contributing mechanism. IASCC is not a likely aging mechanism because of the very low oxygen environment and the relatively low neutron fluence. SCC is the only likely mechanism. The likelihood of cracking such as was observed in stainless steel baffle bolts has no relevance to Combustion Engineering upper internals assemblies. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-52 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-2 B3.1.1, B3.1.3 Delete Void Swelling as a contributing mechanism. Void swelling is not a likely aging mechanism for the upper internals assembly because of the very low neutron fluence. The likelihood of embrittlement due to swelling is even more remote because irradiation hardening is associated with over 10% swelling in Fast Breeder Reactor cladding. No swelling is expected, therefore, embrittlement due to 10% swelling is not possible. Industry programs to address the occurrence and significance of void swelling will be used as part of the Core Shroud Assembly aging management activity to establish the need for an inspection program. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB3-3 B3.2.1, B3.2.2 Delete IASCC as a contributing mechanism. IASCC is not a likely aging mechanism because of the very low oxygen environment and the relatively low neutron fluence. SCC is the only likely mechanism. The likelihood of cracking such as was observed in stainless steel baffle bolts has no relevance to Combustion Engineering CEA shroud assemblies and bolts. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-53 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-4 B3.2.1, B3.2.2 Delete Void Swelling as a contributing mechanism. Void swelling is not a likely aging mechanism for the CEA shroud assemblies and bolts because of the very low neutron fluence. The likelihood of embrittlement due to swelling is even more remote because irradiation hardening is associated with over 10% swelling in Fast Breeder Reactor cladding. No swelling is expected, therefore, embrittlement due to 10% swelling is not possible. Industry programs to address the occurrence and significance of void swelling will be used as part of the Core Shroud Assembly aging management activity to establish the need for an inspection program. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB3-5 B3.3.1, B3.3.2 Delete IASCC as a contributing mechanism. IASCC is not a likely aging mechanism because of the very low oxygen environment and the relatively low neutron fluence. SCC is the only likely mechanism. The likelihood of cracking such as was observed in stainless steel baffle bolts has no relevance to Combustion Engineering Core Support Barrels. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-54 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-6 B3.3.1, B3.3.2 Delete Void Swelling as a contributing mechanism. Void swelling is not a likely aging mechanism for the Core Support Barrel (CSB) because of the very low neutron fluence and the low irradiation temperature. (The CSB is in direct contact with reactor coolant inlet water that is nominally 550F.) The likelihood of embrittlement due to swelling is even less remote because irradiation hardening is associated with over 10% swelling in Fast Breeder Reactor cladding. No swelling is expected, therefore, embrittlement due to 10% swelling is not possible. Industry programs to address the occurrence and significance of void swelling will be used as part of the Core Shroud Assembly aging management activity to establish the need for an inspection program. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-55 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-7 B3.3.1, B3.3.2 Modify the threshold value for loss of fracture toughness, or delete as a contributing mechanism. Loss of fracture toughness due to neutron irradiation embrittlement in Combustion Engineering Core Support Barrels is not a credible aging degradation mechanism because the austenitic stainless steel used to construct the CSB will retain significant amounts of ductility through its service life. The fluence threshold of 1x1017 n/cm2 is at least four orders of magnitude too low for loss of significant fracture toughness in austenitic stainless steel. There currently are industry programs underway to address the occurrence and significance of changes in strength and ductility due to neutron irradiation that can be used to determine the need to monitor loss of fracture toughness due to neutron irradiation embrittlement in CSBs. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB3-8 B3.4.1, B3.4.3 Delete Void Swelling as a contributing mechanism. Void swelling in the Core Shroud Assembly will be addressed through an industry program on the occurrence and significance of void swelling. The likelihood of embrittlement due to swelling is remote because irradiation hardening is associated with over 10% swelling in Fast Breeder Reactor cladding. Swelling as great as 10% is not expected, therefore, embrittlement due to 10% swelling is not likely. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-56 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-9 B3.4.1, B3.4.3 Modify the threshold value for loss of fracture toughness, or delete as a contributing mechanism. Loss of fracture toughness due to neutron irradiation embrittlement in Combustion Engineering Core Shroud Assemblies is not a credible aging degradation mechanism because the austenitic stainless steel used to construct the CSB will retain significant amounts of ductility through its service life. The fluence threshold of 1x1017 n/cm2 is at least four orders of magnitude too low for loss of significant fracture toughness in austenitic stainless steel. There currently are industry programs underway to address the occurrence and significance of changes in strength and ductility due to neutron irradiation that can be used to determine the need to monitor loss of fracture toughness due to neutron irradiation embrittlement in Core Shroud Assemblies. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB3-10 B3.4.2 Delete IASCC as a contributing mechanism. IASCC is not a likely aging mechanism because of the very low oxygen environment and the relatively low neutron fluence. SCC is the only likely mechanism. The likelihood of cracking such as was observed in stainless steel baffle bolts has no relevance to Combustion Engineering lower internals assemblies. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-57 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-11 B3.5.1 through B3.5.6 Delete IASCC as a contributing mechanism. IASCC is not a likely aging mechanism because of the very low oxygen environment and the relatively low neutron fluence. SCC is the only likely mechanism. The likelihood of cracking such as was observed in stainless steel baffle bolts has no relevance to Combustion Engineering Core Shroud Assembly Bolts. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c

G-IVB3-12 B3.5.1 through B3.5.6 Delete Void Swelling as a contributing mechanism. Void swelling is not a likely aging mechanism for the lower internals assembly because of the very low neutron fluence. The likelihood of embrittlement due to swelling is even less remote because irradiation hardening is associated with over 10% swelling in Fast Breeder Reactor cladding. No swelling is expected, therefore, embrittlement due to 10% swelling is not possible. Industry programs to address the occurrence and significance of void swelling will be used as part of the Core Shroud Assembly aging management activity to establish the need for an inspection program. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-58 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-13 B3.5.1 through B3.5.6 Modify the threshold value for loss of fracture toughness, or delete as a contributing mechanism. Loss of fracture toughness due to neutron irradiation embrittlement in Combustion Engineering lower internals assemblies is not a credible aging degradation mechanism because the austenitic stainless steel used to construct the components will retain significant amounts of ductility through its service life. The fluence threshold of 1x1017 n/cm2 is at least four orders of magnitude too low for loss of significant fracture toughness in austenitic stainless steel. There currently are industry programs underway to address the occurrence and significance of changes in strength and ductility due to neutron irradiation that can be used to determine the need to monitor loss of fracture toughness due to neutron irradiation embrittlement in lower internals assemblies. See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
April 2001 B.2.3-59 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-14 IV.B3.1.1- IV.B3.1.3, IV.B3.2.1, IV.B3.2.2, IV.B3.3.1, IV.B3.3.2, IV.B3.4.1, IV.B3.4.2, IV.B3.4.3, IV.B3.5.1, IV.B3.5.1, IV.B3.5.3, IV.B3.5.4, IV.B3.5.5, IV.B3.5.6 Remove entry for IASCC. IASCC is listed as an Aging Mechanism for the Upper Internals Assembly, CEA Shroud Assembly, Core Shroud Bolts, Core Support Barrel, Core Shroud/Tie Rod, and Lower Internals Assembly. The low levels of dissolved oxygen in a PWR environment and the low applied strain of the RV Internals components cause IASCC to be an unlikely Aging Mechanism for this device type. This position was accepted in NUREG-1705. This entry does not present conclusive evidence that this mechanism is plausible. This mechanism has been observed in BWRs where oxygen levels are considerably higher than in PWRs. A similar Aging Mechanism has also been observed in PWR CEDM tips where very high strain is applied at very low strain rate in a high fluence field. However, there is not conclusive evidence of IASCC for device types with the temperature, oxygen and radiation levels present for the RV Internals either in operating plants or in laboratory tests. Since there is not clear agreement on this Aging Existing AMP. Prior to year 40, if it is determined that IASCC is a significant issue in the renewal term, they would agree to develop a sufficient inspection program See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-60 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-14 (cont.) (including the basis, methods, locations to be examined, timing frequency and acceptance criteria) for management of the issue based upon the results of the industry information. This agreement would not constitute consideration of this Aging Mechanism as requiring management and the agreement would not constitute a “credited program” at this time.
April 2001 B.2.3-61 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-15 IV.B3.1.1- IV.B3.1.3, IV.B3.2.1, IV.B3.2.2, IV.B3.3.1, IV.B3.3.2, IV.B3.4.1, IV.B3.4.2, IV.B3.4.3, IV.B3.5.1, IV.B3.5.2, IV.B3.5.3, IV.B3.5.4, IV.B3.5.5, IV.B3.5.6 Remove references to ISI in entry for SCC. SCC is listed as an Aging Mechanism for the Upper Internals Assembly, CEA Shroud Assembly, Core Shroud Bolts, Core Support Barrel, Core Shroud/Tie Rods, and Lower Internals Assembly. SCC/IGSCC is not plausible for this device type due to non-susceptible material (Alloy Steel, Stainless Steel and/or Nickel Base Stainless Steel), lack of high tensile stresses and control of water chemistry. SCC is not a concern for SS components in treated borated water where chemistry controls maintain halides < 150 ppb or sulfates < 100 ppb (BAW-2270). Chemistry controls in accordance with industry guidelines assure this requirement is met. Therefore, for SCC, chemistry programs in accordance with industry guidelines alone should be credited. A similar position was accepted in NUREG-1705. This entry does not present conclusive evidence that this mechanism is plausible. The References, Existing AMP, Evaluation and Technical Basis, and Further Evaluation entries should be rewritten to correspond to the provided example. The NEI comm

NUREG-1705consequential and growth” das an aging efmanaged by aalso the need of the effectivecontrol with ISSee NRC dispcomment G-IVSection B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-62 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-16 IV.B3.2.2, IV.B3.4.2, IV.B3.4.3 Remove references to loose parts monitoring in entry for Stress Relaxation. Loose parts monitoring will not discover degradation resulting from stress relaxation until after the intended function has failed. ISI is adequate for aging management; loose parts monitoring adds no value for aging management. See NRC disp

comment G-IVAppendix B. SAccording to Wand Neutron NMonitoring. Loose parts mstress relaxatioperation befointended functare redundantmonitoring migdegradation udegradation oinspection is ronce every 10 shutdown perithose identifieWCAP 14577 (from this poinWestinghouse does not recomprograms, othrequirements, The GALL repaddress this c
April 2001 B.2.3-63 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB3-17 IV.B3.3.1, IV.B3.3.2, IV.B3.4.1, IV.B3.4.2, IV.B3.4.3, IV.B3.5.1, IV.B3.5.2, IV.B3.5.3, IV.B3.5.4, IV.B3.5.5, IV.B3.5.6 For Neutron Irradiation Embrittlement, include enhanced VT-1, with no further evaluation, as an option for aging management. This program combination was accepted in NUREG-1705. Recommend t

VT-1 to detect bolted applicaevaluation is rcomponents. Tfor SCC/IASCembrittlement was changed For license renenhanced VT-accepted for mand neutron emost susceptiFor non-bolted an acceptable applications, tacceptable AMarea(s) of intefor visual examexamination is bolting. A new developed in cthis approach. The GALL repaddress this c
NUREG-1739 B.2.3-64 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB4-1 B4. Incore guide tube assembly items are missing. See BAW-2248A. Missing internals items. The pertinent 

“incore guide twhich are subtoughness due embrittlementrevised to inclcomponents aThe GALL repaddress this c

G-IVB4-2 All Items Fatigue TLAA is applicable to replacement bolts (core barrel and thermal shield) only. TLAA not applicable to the majority of internals items. See BAW-2248A. B&W internals designed prior to Section III rules for design of RV internals. To account fo

Section III rulestatement waFor componenanalysis has b40 y period, faaging analysis performed for renewal, and fcomponents, eon fatigue are The GALL repaddress this c
April 2001 B.2.3-65 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB4-3 B4.1.1-B4.1.3 Plenum cover and plenum cylinder and CSS B4.4.1- B4.4.5 and flow distributor and lower internals SCC and IASCC are unlikely mechanisms for these items due to water chemistry and fluence. The B&WOG and NRC did not agree on thresholds; however, the NRC did agree that augmented inspections at limiting locations would be appropriate and bound other locations that may be susceptible to these mechanisms. AMP—the program description does not include provisions to identify limiting items and perform augmented inspections. The limiting items may not be associated with the plenum assembly and are most likely part of the core barrel assembly (e.g., baffle bolts). See BAW-2248A—Applicant Action Items. The following 

item under “AgProgram” for tacceptable AMfollowing elemsusceptible or develop approtechniques to characterizing (cracks) of intethe effectivenetechniques, aninspections durenewal term.” added for B4.1B4.4.3, and B4than boltings iB4.8. The GALL repaddress this c

G-IVB4-4 B4.1.1-B4.1.5, page IV B4-10 and all items Void Swelling—See comment number 14 above. Void swelling of the plenum cover and plenum cylinder unlikely owing to low fluence. BAW-2248A See NRC disp

comment G-IVTable B.2.3. The GALL repaddress this c
NUREG-1739 B.2.3-66 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVB4-5 B4.2.1-B4.2.5, page IV B4-12 Loss of Fracture Toughness—AMP should include provisions to ID limiting items and perform augmented inspections at those locations. BAW-2248A The following 

in “Aging Mancolumn for theacceptable AMfollowing elemsusceptible or develop approtechniques to characterizing (cracks) of intethe effectivenetechniques, aninspections durenewal term.” added to B4.4The GALL repaddress this c

G-IVB4-6 B4.3.2, page IV B4-16 and all subsequent items where loss of fracture toughness is listed Delete fluence threshold of 1.0E17. No justification is provided for the fluence threshold and calculation of fluence at the spacer castings is very difficult (i.e., large uncertainties). A statement w

X1.M2, “ThermEmbrittlement Stainless Steeparticipation in determine flueirradiation embcomponents. The GALL repaddress this c
April 2001 B.2.3-67 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVC1-1 IV-C1.1.5 through C1.11, C1.1.13 Delete the last sentence under the “Preventive Action” statement. If the staff insists on retaining a statement, revise the last sentence to read: “Also, hydrogen addition may be used to enhance the inhibition of IGSCC.” Use of HWC is an option an owner may want to use. However, control of water chemistry by implementing TR-103515 is sufficient. The GALL rep

appropriately. been added to plants using hchemistry. Botwere added as refers to revisefor piping.) The GALL repaddress this c

G-IVC1-2 IV-C1.1.5 through C1.11 Revise the “Parameters Monitored/Inspected” to read: “Inspection and flaw evaluation are to be performed in accordance with GL 88-01 or the referenced BWRVIP guideline as approved by the NRC staff.” The GL 88-01 reference is appropriate. The BWRVIP 

included in GAthe comment. The GALL repaddress this c

G-IVC1-3 IV-C1.1.5 through C1.11, C1.1.13, C1.2.1, C1.3.1, C1.3.2, C1.4.1 through C1.4.4 In every location where the GALL refers to BWRVIP-29 (TR-103515), replace the reference with “EPRI TR-103515, Rev. 2 (BWRVIP-79) or later approved version of TR103515. The EPRI document referred to has been updated as of March 2000. The latest issue is TR-103515, Rev.2. NRC staff in EMCB has the document. This document is updated periodically to identify the latest enhancements to the water chemistry programs. As such, the GALL ought to recognize such. See NRC disp

comment G-IVAppendix B, TThe GALL repaddress this c

G-IVC2-1 Page IVC2-11 through IVC2-19 Multiple entries with “same as...” are not in italics. Convert all “same as...” to italics. Need to be consistent with general format. The GALL rep

address this c
NUREG-1739 B.2.3-68 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVC2-2 C2.1.1-C2.1.4, page IV C2-4 Add crack growth due to service (cyclic) loadings as a mechanism. SCC of carbon steel pipe is unlikely. The AMP discusses Exam. Category B-J but is silent with regard to risk-informed ISI. EPRI- NP-1406-SR discusses the mechanism. SCC was rem

mechanism foThe GALL repaddress this c

G-IVC2-3 C2.1.5 Unanticipated thermal and mechanical loading is not a valid aging mechanism - Delete. If a mechanism is not anticipated, then it cannot be managed in anticipation. This is not an aging mechanism, it is a design issue. A global chang

the words “not “unanticipatedand mechanicThe GALL repaddress this c
April 2001 B.2.3-69 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVC2-4 C2.1.5 Program parameters monitored should be modified to allow the use of industry experience as inspections of small bore piping are done instead of requiring a plant- specific inspection. As experience is gained with these inspections, if the same material / environment combination exists, a plant-specific inspection may not be necessary. Operating exp

that small-bore effect that reqextended termthat a plant-spexamination oexamination (Ninspection of tthe piping neeFor Class 1 pismaller than n(NPS) 4 inch, the one-time inperformed to cinitiation and gcorrosion cracloading is occtime inspectioeffectiveness program. The GALL repaddress this c

G-IVC2-5 C2.1.5 Small-bore piping is either stainless steel, Alloy 600, or stainless steel clad carbon steel. In addition, loose or displaced thermal sleeves in HPI (2 1⁄2-inch NPS) connections are not addressed. AMP requires augmented inspection of thermal sleeves per GL 85-20. There is no small bore CS. Carbon steel w

material for smThe GALL repaddress this c
NUREG-1739 B.2.3-70 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVC2-6 C2.3.1 RCP Casing – Thermal Embrittlement. The AMP and Technical Basis text refer to thermal aging for valve body. Change to RCP casing. Correct topic is RCP casing. The AMP and 

correctly referRCP casing. The GALL repaddress this c

G-IVC2-7 C2.4.3 Valve closure bolting is either HSLAS or SS. Aging effect is loss of closure integrity by cracking and loss of preload. BAW-2243A Add SS to “Ma

cracking and l“Aging MechaThe GALL repaddress this c

G-IVC2-8 C2.5.8 Manway and Flange—aging effect of loss of material on external surface of the manway was omitted. BAW-2244A Add aging effe

on external suThe GALL repaddress this c

G-IVC2-9 C2.5.12 Cracking at weld that connects the pressurizer support plate to the shell was omitted. BAW-2244A Add cracking a

the pressurizeshell. The GALL repaddress this c
April 2001 B.2.3-71 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVD1-1 D.1.1.3, D1.1.4 Evaluation of Technical Basis – Discussion of NRC IN 90-04 should be deleted regarding general corrosion and pitting of the SG shell. The conclusion that additional inspection may be required that are associated with the IN discussion should also be deleted. IN 90-04 Cracking of Upper shell to Transition Girth Welds does not discuss cracking of SG shell remote from welds. The problems discussed in this IN were in –W- model 44 and 51 SGs and were discovered during ISI weld inspections. NRC IN 90-04 

corrosion and surface of SG 90-04 states: “corrosion pittinknown to existSection XI of tnot be sufficieisolated crackgeometric con3rd page, 2nd has been reposteam genera(NUREG/CR 4XI requires oninspections of detect cracks. examinations surface examito detect pittincorrosion. IN 9“The flaw indicdetected with procedures thexperienced nexamination pshell-to-transitlocated at a grdiscontinuity. Twide and typiccrown. These features comminnocuous reflsubsurface flaknown to exist diameter surfa
NUREG-1739 B.2.3-72 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVD1-1 (cont.) plant sites. In 

innocuous reflthe following pnecessary: scthe use of muoptimum anglereflector locatiby experienceThe rules of SCode require a examination otransition cone 10-year inspecrequired examlimited to one distributed amHowever, if geof the SG sherequirements ASME Code mdifferentiate isinherent geomlieu of volumevisual and MT interior circumweld were useIndian Point Usurface-conneThe GALL repaddress this c
April 2001 B.2.3-73 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVD1-2 D1.1.9 Evaluation of technical basis – delete discussion about potential cracking in cladding remote from welds. There is no justification provided to show that existing ASME inspections are not sufficient. The operation experience cited deal primarily with alloy 600 issues (IN 90-10 and 90-30). In 84-18 provides general information on SCC with a focus on systems, which generally are in standby or where contaminants have been introduced into the system. D1.1.9 was m

Items A2.4.1 tthe following cDeleting discucracking in clawelds and (2) Evaluation col“no.” The GALL repaddress this c

G-IVD1-3 D1.2.1 Fatigue of SG tubes is treated “same as” fatigue of top head, steam nozzle and safe end. Add the following. “For plants where analyses were completed in response to Bulletin 88-02, “Rapidly Propagating Cracks in SG Tubes,” the results of those analyses have to reconfirmed for the period of life extension. The type of fatigue analysis is different for certain tube locations. The analysis f

part of the denleft alone. Envwere also conThe GALL repaddress this c

G-IVD1-4 D1.2.1 SG Tubes – Fretting and Wear – under Technical Basis (2) The program provides no guidance or recommendations.... Change to “NEI 97-06 includes foreign material exclusion as a means to inhibit fretting and wear degradation. Incorporate available guidance from existing program. The revised A

Tube Integrityto incorporate comment and 06 as suggestThe GALL repaddress this c
NUREG-1739 B.2.3-74 April 2001 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVD1-5 D1.2.1 Technical Basis (5), change the referenced inspection interval for PWSCC to be consistent with the recommendation under Secondary Side visual inspection in NEI 97-06. Incorporate available guidance from existing program. The revised A

Tube Integrityto incorporate comment and 06 as suggestThe GALL repaddress this c

G-IVD1-5 (cont.) Technical Basis (6) incorrectly discusses PWSCC. Replace with “Loose parts or foreign objects that are found should be removed from the steam generators unless it can be shown by evaluation that these objects do not cause unacceptable tube damage. The evaluation will define an acceptable operating interval.” Incorporate available guidance from existing program. The revised A

Tube Integrityto incorporate comment and 06 as suggestThe GALL repaddress this c

G-IVD1-6 D1.2.1 For Aging Mechanism = General Pitting and Corrosion, under Technical Basis (6), add the performance criteria identified in NEI 97-06. Incorporate available guidance from existing program. The revised A

Tube Integrityto incorporate comment and 06 as suggestThe GALL repaddress this c

G-IVD1-7 D1.2.1 For “denting due to corrosion of tube support plates” change aging mechanism to specify carbon steel tube support plates. Denting has not been experienced with stainless steel support plates. Add “corrosion 

support” in “Agcolumn. This wreview findingThe GALL repaddress this c
April 2001 B.2.3-75 NUREG-1739 Table B.2.3: Disposition of NEI Comments on Chapter IV of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-IVD1-8 D1.2.1 Tube support lattice bars / FAC... Consider adding Carbon Steel Tube Support Plates as separate item. Effect = ligament cracking, mechanism = corrosion. AMP = Program in accordance with NEI 97-06. Corrosion of carbon steel support plates has a detrimental effect on SG tubes where they pass through the support plate. Denting of tubes is a secondary effect. Add additiona

corrosion of casupport plate (effect is ligamAMP was in a97-06. The GALL repaddress this c

G-IVD2-1 D2.1.3 Primary OTSG inlet and outlet nozzles do not have SS safe ends. Loss of material due to boric acid corrosion on external nozzles was omitted. NUREG-1723 Delete SS saf

material due to on external suThe GALL repaddress this c

G-IVD2-2 D21.8, page D2-12 Secondary side nozzles are susceptible to SCC and not PWSCC. Secondary sid

susceptible to PWSCC. The GALL repaddress this c
NUREG-1739 B.2.3-76 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.4

DISPOSITION OF NEI COMMENTS

ON CHAPTER V OF GALL REPORT
NUREG-1739 B.2.4-ii April 2001

This Page Intentionally Left Blank
April 2001 B.2.4-1 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-V-1 System Interface Include a reference to Section V E (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (V E). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. The links betw

components eSections A thrChapter V and Chapter V werbecause the ethose componaddressed in SThe GALL repaddress this cthe following s“System, StrucComponents” through D2 of management degradation of carbon steel cincluded in SeChapter V,” anreference link under “SystemComponents” Chapter V.
NUREG-1739 B.2.4-2 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VA-1 A.1.1-1.3, A.1.5, A.3.1, A.4.1 Regulatory Guide 1.44 does not manage cracking of stainless steel. This guide provides information to limit the sensitization of stainless steel during welding. However, sensitization of stainless steel during welding cannot be eliminated and it must be assumed that cracking will occur if the other parameters necessary for cracking (i.e., halogens) are present. Therefore, other programs (ex- chemistry) are necessary to manage cracking. Relative to SSC, the references, AMP and Evaluation and Technical Basis should include design and material controls consistent with Reg. Guide 1.43. Comment transmitted for previous draft was not incorporated. Certain stainle

of the PWR CSystem such apumps, and vato stress corroreferenced AMChemistry” (NThe main objeChemistry” AMdamage causeand crevice coThe GALL repaddress this cRG 1.44 from it does not profor preventing already sensitRG1.43 was nreference to thAMP because information rematerial controRG 1.43 contarelated to undeGrade 508 Cl-
April 2001 B.2.4-3 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VA-2 A.1.4, A.3.2, A.4.2, A.5.2, A.6.5 Delete Closure Bolting from this section of the GALL and revise E1.1 to clarify inclusion of bolting. Bolting is not a component. It is a piece part of components such as pipe, valves, and pumps. The bolt does not perform a component intended function. See comment G- V E-1. Bolting is an in

pipings, fittings related items, heat exchangecontainment sis considered component foengineered sabecause it can identified and small componcould be missunder a broadSection E of CGALL report foincludes AMPs all CS structurincluding closuaddition, ASMindividual boltiand requires inindividual bolticorrosion of clincluded in boof Chapter V oSection A, the leaking from aconnection in in Section E, it adjacent pipinconnection. The GALL repto address thi
NUREG-1739 B.2.4-4 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VA-3 A.1.1-A.1.3, A.1.5, A.3.1, A.4.1 Remove entry for SCC. Plausibility of mechanism seems based on design temperature of 400oF. This system is maintained in standby at ambient temperature; the temperature preconditions for SCC (>150oF) do not exist. Stress corrosi

stainless steel exposed to bopossible at tem200oF if contain the water. Toperating expeplants (IN 79-79-17). Howevthat that degraoccur if water maintained sinwithin the wateeither preclude or filter out consulfides and crequired for tracorrosion cracdepartures frowhich would aof contaminanfor the root cameasures undin accordance requirements 10 CFR Part 5The GALL repaddress this cwater chemistmanagement operating tem200oF in the “Efor line items Aand A.4-a.
April 2001 B.2.4-5 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VA-4 A.2.1-A.2.4, A.5.1 Remove references to Pitting and Crevice Corrosion. General Corrosion, Pitting, and Crevice Corrosion are listed as Aging Mechanisms for Carbon Steel in the Header and Spray Nozzles System. Carbon Steel exposed to Air will at most be susceptible to General Corrosion; Crevice Corrosion and Pitting require an aqueous environment. Carbon steel i

general corrosenvironment. The GALL Readdress this cpitting and creaging mechanonly operative environment. G-VB-1 B.2.1 Remove entry for Stainless Steel or materials should be separated into two groups with Stainless Steel having a specific reference to high temperature operating conditions and/or a salt air environment. The data in the other columns can remain the same, including the plant specific AMP. The material for the Filter Housing and Supports is listed as Carbon and Stainless Steel. Stainless steel is not subject to pitting or crevice corrosion unless exposed to salt- laden air or normal temperatures in excess of 200°F. Stainless steel is not normally subject to general corrosion unless exposed to repeated wet-dry cycling of salt- laden air. The BWR stan

systems filter fabricated from susceptible to to general corconditions. The GALL repaddress this cremoving SS fcolumn.
NUREG-1739 B.2.4-6 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VB-2 B.2.2 Delete entry for Charcoal Absorber. The charcoal filter medium is active, short-lived, and as such is not subject to an aging management review. The filter medium performs its intended function by undergoing a change of state, and will be eventually replaced on a periodic basis or due to its condition. The charcoal a

BWR Standby Systems will bonce during a and therefore an aging manaThe SRP will bguidance and consideration stated in Table Staff Guidance consumables category (d) sfire extinguishair packs. The GALL repaddress this cthe charcoal aline item and iin Section B o“System, StrucComponents” the SRP, referfilter.
April 2001 B.2.4-7 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VC-1 C.1.1 Delete entry for Valve Disc Seal. Valve internals are active and as such is not subject to an aging management review. See NUREG- 1705 for NRC position on valve internals. Valve internals

seals, are conshort-lived and an aging manaSRP will be usguidance and consideration As stated in TStaff Guidance consumables category (a) focomponent seThe GALL repaddress this cthe valve disc 

G-VC-2 C.2.1, C.2.1 Delete entry for Biofouling. Component intended function is pressure boundary only. Biofouling does not prevent this intended function. BWR and PW

are exposed to exists the posactivity resultindeposits. For this applicimpacts active The GALL repaddress this cthis line item was the aging eas the aging m
NUREG-1739 B.2.4-8 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VC-3 C.2.1, C.2.2 CS should not be included with low- alloy steel and SS. A separate line item should be made for CS. CS has different applicable aging effects than low-alloy or SS. CS and low-al

are grouped toPWR isolation they have simgeneral, pittingcorrosion and influenced corThe GALL repaddress this cseparate line ilow-alloy steel pitting, and crealso the combbiofouling; and pitting and crealso the combbiofouling. For gaseous wastas part of the 

G-VC-4 C.2.1, C.2.2 The environments in this item are quite varied. Consideration should be given to addressing each environment separately, as the aging effects can be different. SS and low-alloy materials are generally not subject to detrimental aging effects unless they are exposed to high temperatures (>200°F) under normal (long-term) operating conditions or salt-laden fluids. See NRC disp

Comment G-VTable B.2.4. G-VC-5 C.1.1 Typos in the Evaluation and Technical Basis Section. Editorial comment. See NRC dispG-VC-1 in Appwhich deleted valve disc seathe typos refercomment. The GALL repto address this 
April 2001 B.2.4-9 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD1-1 D1.1-1.6, D1.2.1, D1.4.1, D1.7.3, D1.8.1- 8.3 Regulatory Guide 1.44 does not manage cracking of stainless steel. This guide provides information to limit the sensitization of stainless steel during welding. However, sensitization of stainless steel during welding cannot be eliminated and it must be assumed that cracking will occur if the other parameters necessary for cracking (i.e., halogens) are present. Therefore, other programs (ex- chemistry) are necessary to manage cracking. Relative to SSC, the references, AMP and Evaluation and Technical Basis should include design and material controls consistent with Reg. Guide 1.43. Comment transmitted for previous draft was not incorporated. Certain stainle

of the PWR CSystem such apumps, and vato stress corroreferenced AMChemistry” (NThe main objeChemistry” AMdamage causeand crevice coThe GALL repaddress this cRG 1.44 from it does not profor preventing already sensitRG1.43 was nreference to thAMP because information rematerial controRG 1.43 contarelated to undeGrade 508 Cl-
NUREG-1739 B.2.4-10 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD1-2 D1.1.7, D1.2.2, D1.3.1, D1.4.1- 4.2, D1.5.3-5.5, D1.6.3-6.4, D1.8.4 Delete Closure Bolting from this section of the GALL and revise E1.1 to clarify inclusion of bolting. Bolting is not a component. It is a piece part of components such as pipe, valves, and pumps. The bolt does not perform a component intended function. See comment G- V E-1. Bolting is an in

pipings, fittings related items, heat exchangecontainment sis considered component foengineered sabecause it can identified and small componcould be missunder a broadSection E of CGALL report foincludes AMPs all CS structurincluding closuaddition, ASMindividual boltiand requires inindividual bolticorrosion at clincluded in boof chapter V oSection A, the leaking from aconnection in Section E, it is adjacent pipinconnections. The GALL repto address this 
April 2001 B.2.4-11 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD1-3 D1.1.1- D1.1.6 Remove “Lines to Emergency Sump” from entry for SCC. Plausibility of mechanism seems based on design temperature of up to 644oF. This portion of system is maintained in standby at ambient temperature; the temperature preconditions for SCC (>150oF) do not exist. Stress corrosi

stainless steel exposed to bopossible at tem200oF if contain the water. Toperating expeplants for spenlines (IN 79-19for safety injecand IN 84-18)casings (IN 80instrumentatiosafety injection However, the that degradatiowater chemistsince normal pwater chemistpreclude the inout contaminaand chlorides transgranular cracking. Any departures frowhich would aof contaminanfor the root cameasures undin accordance requirements 10 CFR Part 5The GALL repaddress this cwater chemist
NUREG-1739 B.2.4-12 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD1-3 (cont.) management 

further evaluatoperating tem200°F in the “Efor line items DD1.4-b, D1.7-b

G-VD1-4 D1.2.1 Delete entry for SCC. Plausibility of mechanism seems based on design temperature of up to 644°F. This portion of system is maintained in standby at ambient temperature; the temperature preconditions for SCC (>150°F) do not exist. See NRC disp

comment G-VTable B.2.4. G-VD1-5 D1.8.1-D1.8.3 Delete entry for SCC. This portion of system is maintained in standby at ambient temperature; the temperature preconditions for SCC (>150°F) do not exist. (This mechanism was considered Plausible for CCNPP but the root cause appeared to be contaminants not removed during initial fabrication. This is a plant-specific event and will not apply to other prospective applicants.) See NRC dispcomment G-VTable B.2.4.
April 2001 B.2.4-13 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD2-1 All items where the AMP is Plant Chemistry Controls Change Further Evaluation Column to “NO” wherever the AMP is the Plant Chemistry Controls, and the applicant has demonstrated their effectiveness through operating experience. Per prior discussions with NRC, Plants can show through their operating experience that the Chemistry Controls they are using are adequate for the purpose of preventing and mitigating aging effects. A one-time ins

verify the effecchemistry conconfirm either aging effect or progression oeffect for BWR aging effect is are evaluated appropriate coThe GALL repto address this 

G-VD2-2 D2.1.1-D2.1.7 Change lower limit for temperature to 93oC (200°F). SCC is not an applicable aging effect for these components due to the high quality of the water and the low normal operating temperature. Most RHR lines and most of the line connected to the SC will normally operate below 200°F. SCC can occur in SS components that utilize salt water for the cooling, but no commercial US reactors do. Pipings and fit

components foexposed to a denvironment rtemperature fr550°F). The telisted in the ‘Eindicates variaconditions; it is temperature fomechanism. The GALL repto address this 
NUREG-1739 B.2.4-14 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD2-3 D2.1.1-D2.1.7 This item should be revised to be restricted to components that Section XI and Appendix B require to be included in the applicant’s ISI program. The systems listed will have components that are not in the ISI plan for the applicant. As such, the inspections listed will not occur. The separate line item for the non-ISI components should be prepared with comment G-V D2-1, above, in mind. Pipings and fit

BWR ECCS fasteel can be sand intergranuinspections of required for agprogram XI.M7 those required BWRVIP-75. The GALL repprogram M7 waddress this c

it more specifiprogram to the and BWRVIP-

G-VD2-4 D2.1.8 This item should be separated by material into two items. The aging effects for SS are different than for CS in this case. It is extremely unlikely that the SS components will be subject to the aging effects listed due to the low temperatures of the air and due to the lack of electrolytes in the atmosphere. Pipings and fit

ECCS automasystem are fabwhich, when scontainment aor demineralizsusceptible to to crevice and The GALL repaddress this cunder “Aging Ethat carbon steconditions is ageneral corrospitting and cre
April 2001 B.2.4-15 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD2-5 D2.3.1 Change lower limit for temperature to 93oC (200°F). SCC is not an applicable aging effect for these components due to the high quality of the water and the low normal operating temperature. Most RHR lines and most of the line connected to the SC will normally operate below 200°F. SCC can occur in SS components that utilize salt water for the cooling, but no commercial US reactors do. Valves for BW

exposed to a denvironment rtemperature fr550°F). The telisted in the “Eis intended to operating condthreshold tempaging mechanThe GALL repto address this 

G-VD2-6 D2.5.1-D2.5.4 This item should be separated by material into two items or delete entry for General Corrosion, Pitting, and Crevice Corrosion. The aging effects for SS are different than for CS in this case. It is extremely unlikely that the SS components will be subject to the aging effects listed due to the low temperatures of the air and due to the lack of electrolytes in the atmosphere. Stainless Steel exposed to Air will not be affected by these Aging Mechanisms. Also, Carbon Steel exposed to Air will at most be susceptible to General Corrosion; Crevice Corrosion and Pitting require an aqueous environment. Pipings and fit

headers, and sBWR ECCS dsuppression csystem fabricaexposed to an susceptible to corrosion becamechanisms renvironment. Teffects are eithplugging of nosparger holesThe GALL repaddress this cstainless steel column and picorrosion from Effect/Mechan
NUREG-1739 B.2.4-16 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VD2-7 D2.5.1-D2.5.4 Why is plugging of the nozzles and spray sparger holes not considered an applicable aging effect? (Flow Blockage) Corrosion build-up inside CS spargers could lead to plugging of the sparger hole. Plugged holes could cause spray dispersal patterns that do not agree with the design basis analysis leading to inadequate SC cooling. Pipings and fit

headers, and sBWR ECCS dsuppression csystem fabricaexposed to an susceptible to Because of cobuildup, pluggorifice and spradded as an aeffect. The GALL repaddress this cthis new line it

G-VE-1 E.1.1 Revise Structure and Component “Carbon Steel Components (PWR’s)” to read “Carbon Steel Components and Closure Bolting (PWR’s)” Bolting is not a component; as such it should not be called out separately in other sections in chapter V. Chapter XI.M5, “Boric Acid Corrosion” applies. There is no need to distinguish bolting from other pressure boundary external surfaces relative to boric acid corrosion. GALL V, Secti

components indegradation of structures and including closuSection XI treaas a componeinspection of iline item for BAsurfaces refercarbon steel cnot contain bocomponents ccoolant are adsections of ChThe GALL repto address this 
April 2001 B.2.4-17 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VE-2 E.1.1 Delete second section related to atmospheric corrosion. Revise SRP Tables 3.2-1 (page 3.2-13) and 3.2- 2 (page 3.2-15) accordingly. Very few components of the ECCS systems are constructed of carbon steel. Reference to Chapter XI.S8 has the effect of back-fitting RG 1.54, Rev. 1. As a minimum, replace with a requirement for “plant specific” in lieu of S8. The external s

PWR CS comair, moisture, atemperatures susceptible to causing loss oThe GALL repaddress this cthe term “atmowith “general cdeleting the reChapter XI.S8 Monitoring and Program.” G-VE-3 E.1.1 Delete reference to ASME section XI in program description for BAC. Implementation of the Boric Acid Corrosion Program at the sites has nothing to do with ASME Section XI. This program is performed independent of Section XI for the identification of boric acid corrosion. Most utilities perform this inspection at the start of the outage to identify problems so that they may be repaired while off-line. Leakage identified during the performance of pressure tests and hydrostatic tests are handled per the ASME Code requirements. The Boric Acid is deemed to program and detect leaks sAcid Corrosion surfaces of CS exclusive of thinspections. SSection XI insare already pestartup, it was include them amanagement The GALL repaddress this crequirements tinspections in Corrosion progaccordance w
NUREG-1739 B.2.4-18 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VE-4 E.1.1 Atmospheric corrosion is only applicable to carbon steel components associated with portions of systems operating below 212°F. Since moisture is necessary for general, pitting and any other forms of atmospheric corrosion, the external surfaces of carbon steel components, which operate above 212°F, are not susceptible to loss of material due to corrosion. Several CS co

Engineered Saexposed to temthan 212°F ansusceptible to The GALL repaddress this cthe term “atmowith “general c

G-VE-5 E.1.1 Delete reference to XI.S8, “Coating Program” under Aging Management Program Column for atmospheric corrosion. Plant specific review should be performed. The use of coatings is a preventive measure to minimize or preclude the loss of material due to corrosion. Loss or degradation of coatings does not result in loss of material, and thus is not considered an aging effect. Programs credited for monitoring loss of material typically constitute periodic visual inspections of component external surfaces for signs of corrosion or loss of material. Since programs credited vary between plant sites, a plant specific review should be performed. The external s

PWR CS comair, moisture, atemperatures susceptible to causing loss oThe GALL repaddress this cthe term “atmowith “general cdeleting the reXI.S8 “ProtectMonitoring and Program.”
April 2001 B.2.4-19 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VE-6 E.2.1 (1) Delete “Air, Moisture, Humidity and Leaking Fluid” under Environment Column for Closure Bolting. Replace with “Air, Leaking Chemically treated Borated Water.” (2) Delete “Atmospheric Corrosion” under Aging Mechanism column and replace with “Boric Acid Corrosion”. Replace information in References column, Aging Management Program column and Evaluation and Technical Basis column with that provided in E.1.1 for Boric Acid Corrosion. Most carbon or low alloy steel bolting is in a dry environment and coated with a lubricant, thus general corrosion of bolting has not been a major concern in the industry. Corrosion of fasteners has only been a concern where leakage of a joint occurs, specifically, when exposed to aggressive chemical attack such as that resulting from borated water leaks. Aging effect requiring management should be loss of mechanical closure integrity due to aggressive chemical attack (boric acid corrosion). The purpose 

Chapter V of address carbosteel closure ambient envirair). Boric acibolting is not because it is item E.1-a in GALL report arespective sechapter. In addition, threvised to addby replacing “corrosion” witfor this line iteleaking fluid f“Environment
NUREG-1739 B.2.4-20 April 2001 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VE-7 E.2.1 Delete Aging Effect/Mechanism “Loss of Pre-load due to Stress Relaxation.” (Note: Reference column and AMP Column incorrect list Item H.2.1 instead of E.2.1.) Loss of pre-load of mechanical closures can occur due to settling of mating surfaces, relaxation after cyclic loading, gasket creep, and loss of gasket compression due to differential thermal expansion. The effects of these mechanisms are the same as that of a degraded gasket; that is, the potential for leakage of internal fluid at the mechanical joint. Since the ASME code does not consider gaskets, packing, seals, and O-rings to perform a pressure retaining function, these components are typically not considered to support an intended function and not within the scope of license renewal. Thus, with the exception of Class 1 components and those cases where a gasket or seal is utilized to provide a radiological barrier, the aging mechanisms associated with loss of pre-load, described above are not considered to require management. Class 1 components credit the ISI Inspection Program to address loss of pre-load due to stress relaxation. See NRC disp

comment for GAppendix B, T
April 2001 B.2.4-21 NUREG-1739 Table B.2.4: Disposition of NEI Comments on Chapter V of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VE-8 E.2.1 Delete Aging Effect/Mechanism “Crack Initiation/Growth” due to Cyclic loading, Stress Corrosion Cracking. (Note: Reference column and AMP Column incorrect list Item H.2.1 instead of E.2.1.) Although there have been a few instances of cracking of bolting in the industry due to SCC, these have been attributed to high yield stress materials and contaminants, such as the use of lubricants containing MoS2. For quenched and tempered low alloy steels (e.g., SA193 Grade B7) used for closure bolting material, susceptibility to SCC is controlled by yield strength. Additionally, operating experience and existing data indicate that SCC failure should not be a significant issue for the bolting materials of SA193 Grade B7. See dispositio

G-VII I-7 in ApTable B.2.6.
NUREG-1739 B.2.4-22 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.5

DISPOSITION OF NEI COMMENTS

ON CHAPTER VI OF GALL REPORT
B.2.5-ii

This Page Intentionally Left Blank
April 2001 B.2.5-1 NUREG-1739 Table B.2.5: Disposition of NEI Comments on Chapter VI of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G VI – 1 Table 6 Delete “BWR/” from the Type column for the “Non-EQ electrical connectors exposed to borated water leakage.” The program for Non-EQ electrical connectors exposed to borated water leakage is based on NRC GL 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants, and is only applicable to PWR plants. Borated water 

plants, and the NRC GL 88-05 PWR plants. Tproposed chanhas been incoThe GALL repwas revised to comment. G VI– 2 VI A-3 Paragraph 1 Delete the phrase, “are not normally used at nuclear power plants,” from paragraph 1, sentence 3. Section VI A-3, Paragraph 1, sentence 3 states: “High-voltage (>15kV) power cables and connections are not normally used at nuclear power plants, have unique, specialized constructions and must be evaluated on an application-specific basis.” The switchyards at nuclear plants normally do contain high-voltage power cables (transmission lines) and connections. The rest of the statement is accurate. High-voltage p

connections aswitchyards. Tproposed chanhas been incoThe GALL reprevised to add

G VI– 3 VI A-3 Paragraph 2 Revise the first sentence of paragraph 2 to read: “Electrical cables and their required terminations (i.e., connections) are typically reviewed as a single commodity.” Section VI A-3, Paragraph 2, sentence 1 states: “Electrical cables and their required terminations (i.e., connections) are reviewed as a single commodity.” This will be true for most plants but is an acceptable option to review cables and connections separately. Suggest adding the word “typically” to clarify this. Reviewing cab

terminations sa commodity, under 10 CFR proposed chanhas been incoThe GALL reprevised to add
NUREG-1739 B.2.5-2 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.6

DISPOSITION OF NEI COMMENTS

ON CHAPTER VII OF GALL REPORT
B.2.6-ii

This Page Intentionally Left Blank
April 2001 B.2.6-1 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII-1 General comment on System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (VII I). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. The external s

included in the structures and Section I of Chbetween CS cindividual sectrevising the Gthe following sStructures and Sections A1 to “Aging managdegradation of carbon steel cincluded in SeThe GALL repaddress this c

G-VIIA-1 A1.1.1 (p. A1-4) Remove reference to “Coating Degradation.” “Coating Degradation” is not a mechanism, the other items listed are. The condition of the coating does not directly affect the intended function, only indirectly through the other listed mechanisms. The carbon st

assembly is supitting, and creBecause the cdoes not direcfunction, coatideleted as an concern for auThe GALL repaddress this c
NUREG-1739 B.2.6-2 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA1-1 VII.A1.1.1, page VIIA1-5 Aging Management Program should list Structures Monitoring program. Additional information is superfluous. The carbon st

assembly is supitting, and creappropriate AgProgram (AMPMonitoring” (XVol. 2). The GALL repaddress this c

G-VIIA2-1 VII A2-4 (item A2.1.1) Provide a separate line for each of the neutron absorbing materials (Boraflex, Boral, Boron Steel). The AMP described in VII A2-5 is based on NRC guidance and industry experience of Boraflex aging mechanisms and aging effects. There is no specific NRC guidance or known industry issues with Boral and Boron Steel. Aging management effects for Boral and Boron should remain plant specific. The Boraflex n

sheets in spencan degrade wreduction of necapacity. The “Boraflex MonNUREG-1801NRC guidance experience is degradation of Steel neutron spent fuel storspecific AMP nThe GALL repcreate separatdistinguish betBoraflex and B
April 2001 B.2.6-3 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA2-2 VII A2-4 (item A2.1.1) Add Storage Racks under “Region of interest” column, Stainless Steel under “Material” column. If AMP is required, reference a generic AMP or state plant specific. Stainless Steel storage racks are listed in page VII A2-3 as included in Section A2. Stainless stee

racks are expotreated oxygenor borated watThe AMP for twater chemist1801, Vol. 2) tinitiation and gcorrosion cracThe GALL repaddress this c

G-VIIA2-3 VIIA2, page VIIA2-5 Aging Management Program column should only identify the Boraflex Monitoring Program and the program should be evaluated in Chapter XI of GALL. Additional information in AMP column is superfluous and should be included in the evaluation if it is to stay. The Boraflex n

sheets in spencan degrade wreduction of necapacity. The “Boraflex MonNUREG-1801information waThe GALL repaddress this c
NUREG-1739 B.2.6-4 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA2-4 VII A2-5 Eliminate the requirement for both visual inspection of the coupons and the BADGER device inspection. Either of the two methods in addition to RACKLIFE provides reasonable assurance that aging of boraflex is adequately managed. The visual ins

coupons is nomeasurement and predictive Boron areal deconjunction wi(RACKLIFE) ais an acceptabmethod of detof Boraflex remfuel pool racksThe GALL repaddress this c

G-VIIA2-5 VII A2-5 Delete the sentence “corrective action may consist of providing additional neutron absorbing capacity.” This is one option only. There are other corrective measures that could be taken such that the 5% subcriticality margin is maintained. The AMP “Bor

(XI.M22, NURstates that corinitiated if the the 5% subcritbe maintained current or projdegradation. Cconsist of provneutron absoror boron steel options that ara 5% subcriticThe GALL repaddress this c
April 2001 B.2.6-5 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA2-6 VII A2-5 Recommend changing “BADGER” to Areal Density measurements. The term is more generic and permits the use of new equipment and technologies. The AMP “Bor

(XI.M22, NURincludes: (1) pattenuation tesanalysis for silfuel pool wateresults using tcode or its equ(3) measuring a device such The GALL repaddress this c

G-VIIA2-7 VII A2-7 Provide operating experience that justifies the effectiveness of the program. Section A.1.2.3.10, page A.1-6 of draft SRP states “This information should provide objective evidence to support that the effects of aging will be adequately managed so that the structure and component intended function(s) will be maintained during the period of extended operation.” The descriptio

experience hathe AMP “Bora(XI.M22, NURprovide objectprogram is effthe AMP will esheets will maand will be effetheir intended The GALL repaddress this c
NUREG-1739 B.2.6-6 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA3-1 A3.1.1, A3.5.1 Delete reference to ASME Section XI as a technique for detecting boric acid corrosion. Refer to comments in Chapter XI.M5 for justification NRC GL 88-05 

alone program carbon steel scomponents foacid leakage aInservice inspleakage identiperformance ohydrostatic tesASME Code aindependent oCorrosion” (XIVol. 2) and weThe GALL repaddress this c

G-VIIA3-2 A3.2.1, A3.3.1, A3.5.1, A3.5.2 The material column refers to “carbon steel (CS) with lining.” It is not clear what type of lining material is intended by this description. If the lining material is stainless steel, then pitting and crevice corrosion should be deleted from this table. The introduction of system operation (Page VII A3-3) states that stainless steel components are not subject to significant aging degradation in borated water and are not considered further. In addition, further evaluation is not warranted. Pitting and cre

aging mechanfollowing degrprotecting the items were addegradation of filter housings exchangers. The GALL repaddress this c
April 2001 B.2.6-7 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA3-3 A3.3.1 The material column refers to “carbon steel (CS) with stainless steel (SS) cladding.” Stainless steel is not subjected to significant aging degradation in a borated water environment and should be deleted from this table. The introduction of system operation (Page VII A3-3) states that stainless steel components are not subject to significant aging degradation in borated water and are not considered further. Also, further evaluation is not warranted. Stainless stee

the presence ohave been insspent fuel pooInstances of chave included water storage spent fuel coo(NUREG–069IGSCC was obinjection accumIN 91-05). SS can be subborated water The GALL Readdress this c

G-VIIA3-4 A3.4.1, A3.4.2 Delete reference to ASME OM Standards and Guides, Part 2 from this table. Add “If the adequacy of the chemistry control programs cannot be confirmed over the total operating history of the plant or if any unexplained downward trend in heat exchanger performance is identified that cannot be remedied by maintenance of an open-cycle system, it may be necessary to selectively perform functional testing of the affected heat exchangers.” Refer to comments in Chapter XI.M4 for justification. See NRC disp

comment G-VAppendix B, TThe AMP “CloWater” (XI.M2Vol. 2), elemeTrending” provperformance aintervals to be applicant. The GALL repaddress this c
NUREG-1739 B.2.6-8 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA3-5 A3.5.1-A.3.5.3 Add external surfaces to the Region of Interest column. Consistent with other item numbers that are exposed to air and leaking chemically treated borated water. The external s

and nozzles in exchanger are leaking chemiwater. The comas external suThe GALL repaddress this c

G-VIIA3-6 A3.1.1-A3.2.1, A3.2.2, A3.3.1- A3.3.2, A3.4.1- A3.4.3, A3.5.1- A3.5.3, A3.6.1 Delete line items. All carbon steel external surfaces, including closure bolting exposed to atmospheric air and chemically treated borated water are evaluated under Chapter VII I – Carbon Steel Components. The compone

pool cooling acontain chemiwater, which mThe componecomponents streated boratethem. The GALL repaddress this cthe carbon steconsidered do water, by addithe system strdescription as itself of the casection. G-VIIA3-7 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (VII I). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. See NRC dispcomment G-VTable B.2.6.
April 2001 B.2.6-9 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIA3-8 A3.4.1, A3.4.2 Remove reference to MIC. Treated Closed Cycle Cooling Water is not susceptible to MIC. Carbon steel c

to chemically tcooling water microbiologicacorrosion becanot amenable The GALL repaddress this cthis aging meccomponents in pool cooling a

G-VIIA4-1 A4.1.1, A4.2.1, A4.3.1, A4.4.2- A4.4.4, A4.5.1, A4.5.2, A4.6.1 See comments on AMP for “Water Chemistry” in Chapter XI.M.11. See comments on AMP for “Water Chemistry” in Chapter XI.M.11. The section on 

in Element 4, Effects, in the Chemistry” (XVol. 2), was clinspection is neffectiveness control and coan aging effecdetected, the rto determine tcorrective actiThe reference this report” wathe GALL Repaddress this c

G-VIIA4-2 A4.4.1-A4.4.3 See comments on AMP for “Closed cycle cooling water system” in Chapter XI.M.4. See comments on AMP for “Closed cycle cooling water system” in Chapter XI.M.4. See NRC disp

comment G-VAppendix B, T
NUREG-1739 B.2.6-10 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIB-1 B.1.1 Remove reference to “Coating Degradation.” “Coating Degradation” is not a mechanism, but General Corrosion is. The condition of the coating does not directly affect the intended function, only indirectly through the other listed mechanism. The structural 

including bridgsubject to genBecause the cdoes not direcfunction, coatideleted as an concern for auCoatings are cmaintenance rThe GALL repaddress this c

G-VIIB1-2 VIIB1, page VIIB-3 The text under system interfaces should be changed to the following: Physical interfaces exist with the supporting structure. The direct interface is at the connection to the structure. Editorial clarification. The text follow

interfaces capintroductory painclude the fol“Physical intersupporting struinterface is at structure.” The GALL repaddress this c

G-VIIB1-3 VIIB1.1, page VIIB-4 Structure and component should be listed as Cranes. Bridge and trolley are subcomponents of the larger component, which is a crane. The structural 

including bridgsubject to genstructure and listed as Cranand trolley are The GALL repaddress this c
April 2001 B.2.6-11 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIB1-4 VIIB1.1, page VIIB-4 Delete ASME Section XI under reference for general corrosion. The structural girders are not inspected in accordance with ASME. The AMP “Ins

Heavy Load aHandling SystNUREG-1801so that referenXI and ANSI Nbecause ASMapply to crane N14.6 applies rather than the The GALL repaddress this c

G-VIIB1-5 VIIB1.1, page VIIB-5 (1) Aging Management Program should reflect CMAA Specifications #67 or #70. (2) Additional information such as cycles and CUF needs to be moved under evaluation and technical basis. (3) Further evaluation should say, “Yes, TLAA if applicable.” ASME NOG-1 is not a utility applied reference. Editorial clarification. (1) The AMP “

Overhead, HeLoad Handling NUREG-1801add the follow(specification the crane was be used). The Electric OInstitute, Inc., No. 61, SpecifOverhead Trathat this is CMwas a typo). Crane ManufaAmerica, Inc., No. 70, SpecifOverhead TraCrane ManufaAmerica, Inc., 
NUREG-1739 B.2.6-12 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIB1-5 (cont.) No. 74, Specif

Running and U(contd) Girder Electric Cranes. (2) The AMP “Overhead, HeLoad Handling NUREG-1801include only agaging effects dcorrosion and (3) Fatigue is evaluated for toperation in acCFR 54.21 reqlicense renewademonstrate coriginal licensicriteria for 60-not include a fapplicant does one. The GALL repaddress this c
April 2001 B.2.6-13 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIB1-6 VIIB1.1, page VIIB-5 Aging Management Program, delete information on ASME code Section XI for VT-3. The structural girders are not inspected in accordance with ASME Section XI. The AMP “Ins

Heavy Load aHandling SystNUREG-1801References to and ANSI N14because ASMapply to crane N14.6 applies rather than the The GALL repaddress this c

G-VIIB1-7 VIIB1.1, page VIIB-5 Delete information on coating degradation under AMP column. ASME Section XI and Coating inspections are not credited for managing the aging of cranes. Only the crane inspection or Maintenance Rule inspections are credited with managing aging of cranes. The structural 

including bridgsubject to genBecause the cdoes not direcfunction, coatideleted as an concern for auCoatings are cMaintenance RThe GALL repaddress this c
NUREG-1739 B.2.6-14 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIB1-8 VIIB1.1, page VIIB-5 Revise Attributes 1 – 6 as follows: (1) Scope of Program: The program is focused on managing the effects of general corrosion on the girders. (2) Preventive Actions: No preventive actions are identified. The Crane inspection is a monitoring program.) (3) Parameters Monitored/Inspected: OK as is. (4) Detection of Aging Effects: Rails and girders are visually inspected on a routine basis for degradation. Functional tests are also performed to assure their integrity. (5) Monitoring and Trending: Monitoring and trending are not required as part of the crane inspection program. (6) Acceptance Criteria: The acceptance criteria are no unacceptable visual indication of loss of material due to corrosion or wear. The attributes are changed to more correctly reflect the program. This statement matches how other preventive actions are addressed when it is a monitoring program. Changes are recommended because girders are not inspected in accordance with ASME. This matches how cranes are addressed in NUREGs 1705 and 1723. The statement in the GALL does not contain any acceptance criteria. These are the criteria that were accepted in NUREG 1723 for managing this aging effect. The AMP “Ins

Heavy Load aHandling SystNUREG-1801significantly reIn Element (1)loading” and “swere deleted bscope. Element (2) “prevised becauprogram. Element (4) “DEffects” was reSection XI doeElement (5) “MTrending” was address this cnot in scope. Element (6) “Awas revised wphrase at the applicable indgood industry The GALL repaddress this cabove. G-VIIB1-9 VIIB1.1, page VIIB-4, and VIIB.2.1, page VIIB-6 Environment should be changed to 100% relative humidity and 49°C. Many locations within the plant are exposed to relative humidity as high as 100%. Many location

exposed to relas 100%. The GALL repaddress this cthe listed envirelative humid
April 2001 B.2.6-15 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIB1-10 VIIB.2.1, page VIIB-6 and VIIB-7 Delete “and coating degradation” under references, AMP and evaluation and technical basis. Coating degradation does not in and of itself result in loss of material of the rail system. Corrosion results in loss of material. The condition 

not directly afffunction. Coatunder the MaiThe GALL repaddress this ccoating degradmechanism fo

G-VIIC1-1 System Description Revise sentence addressing Regulatory Guide 1.26 as follows: Based on the Nuclear Regulatory commission Regulatory guide 1.26, “Quality Group Classifications and Standards for Water, Steam, and Radioactive Waste Containing components of Nuclear Power Plants”, all components in the open cycle cooling water system are classified as Group “C” quality Standards, with the exception of those forming part of the containment penetration boundary which are Group “B.” Since scope of Section VII C2 now also includes containment isolation portion of system, Quality Group classification requires clarification. The Quality G

clarified by ussentence: “BaGuide 1.26, QClassifications Water, SteamWaste ContainNuclear Powecomponents in cooling water as Group “C” Qthe exception of the containmboundary whicThe GALL repaddress this c
NUREG-1739 B.2.6-16 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC1-2 System Interfaces Section Change wording to indicate ...systems that “may” interface with the open cooling water system... Many plants have a closed cooling water system that interfaces with the system listed. The system in

the introductorcycle cooling wwater system) indicate the syinterface with water system system). Many OCCW system the systems lisThe GALL repaddress this c

G-VIIC1-3 C1.1.1 Add stainless steel, as applicable material for open cycle cooling water systems (aboveground). The aging effects remain consistent with those items listed. Stainless steel is used in many open-cycle cooling water systems in an effort to minimize the adverse effect of MIC. Stainless stee

OCCW systemadverse effect The GALL repaddress this cto the list of apOCCW system 

G-VIIC1-4 C1.1.1 Add galvanic corrosion to aging mechanism column. The GALL Report identifies galvanic corrosion as being applicable only to piping exposed to a soil environment. This mechanism is also applicable to dissimilar metals in a raw water environment. Galvanic corro

dissimilar metenvironment aexposed to a sThe GALL repaddress this caging mechan(aboveground
April 2001 B.2.6-17 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC1-5 C1.1.1, C1.2.1, C1.3.1 through C1.3.5 Add the following to the aging mechanism column “General (For CS without internal lining or coating)...” General corrosion of lined carbon steel is listed as an aging mechanism. Lined carbon steel pipe may be susceptible to localized corrosion in areas of lining degradation but will not be susceptible to gross wastage. This position was accepted in the CCNPP SER. In addition, this proposed change would ensure consistency with GALL Section VII C3, Item C3.1.1. General corro

CS without an coating or for internal lining carbon steel psusceptible to areas of lining The GALL repaddress this c

G-VIIC1-6 C1.1.2 Add cast iron to material column and de-alloying as specific aging mechanism for only cast iron. Cast iron piping is a probable material type for underground piping. Cast iron was 

concern for unfittings (externwithout organiand aluminumpiping and fitti(service water leaching was ispecific aging is used througis the standard process (and ia subset of seAMP “SelectivMaterials” (XI.Vol. 2) was creThe GALL repaddress this c
NUREG-1739 B.2.6-18 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC1-7 C1.1.2 Delete reference to the AMA titled “Outer Surface of Buried Piping and Components.” Refer to Chapter XI.M8 comments. The AMP “Bur

Surveillance” (1801, Vol. 2) mburied carbon the Buried PipSurveillance Astandards) is nindustry standacceptable methe AMP “BuriSurveillance” (1801, Vol. 2) i“Buried Piping (XI.M34, NURwhich inspects frequency for tpiping consideexperience thacrediting the inis dug up for afrequency and experience coplant specific r

The GALL repaddress this c

G-VIIC1-8 C1.1.1, C1.2.1, C1.4.1, C1.5.1, C1.6.1 Eliminate Buildup of deposit/Flow Blockage as an aging effect and Biofouling as an Aging mechanism for all components except heat exchanger tubes. Buildup of deposit due to biofouling is an aging effect which impacts heat transfer intended function, and is thus documented only for heat exchanger tubes. Buildup of deposit does not affect pressure boundary, except for MIC, which is addressed under loss of material. Biofouling affe

performance aintegrity. Flow considered an covered under basis and showithin the scopHowever, biofomaterial, whicboundary and 
April 2001 B.2.6-19 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC1-8 (cont.) requires aging 

This position dLicense Renewwhich states thfunction for hewithin the scopTherefore, bioexchanger tubmanagement. The GALL repfollows to add1. Delete all hecomponents ethe material codeposits due t2. For all pipinother than heaall line items fodue to biofouli3. For all pipinincluding heat material due to included as an pressure boun4. The aging mXI.M20 “OpenSystem” was rreference to fl

G-VIIC1-9 C.1.3.1 through C.1.3.5 Add: Aluminum Brass material for heat exchanger tubes. All other columns remain the same. Some plants utilize aluminum brass heat exchanger tubes. Since aluminu

heat exchangeplants, the maThe GALL repaddress this c
NUREG-1739 B.2.6-20 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC1-10 C1.4.1 Remove references to General Corrosion. General Corrosion is listed as an Aging Mechanism for Stainless Steel Flow Orifices. Stainless Steel is not susceptible to General Corrosion, so this Aging Mechanism should not be considered. Flow orifice bo

OCCW system steel is not suscorrosion. The GALL repaddress this cthat the aging concern are pmicrobiologicacorrosion and 

G-VIIC1-11 C1.5.1 Add cast steel to the Material column. To be consistent with the same item under different aging effect. The pump cas

system can be steel or carbon The GALL repaddress this cGALL consistespecified undeeffect. G-VIIC1-12 C1.5.1 Remove “low flow cavitation” as an aging mechanism. Cavitation Erosion is localized material erosion caused by formation and collapse of vapor bubbles in close proximity to material surface. Fluid (liquid) flow and pressure variations, which temporarily drop the liquid pressure below the corresponding vapor pressure, are required for this mechanism. Cavitation Erosion does not occur in liquid systems that have low flow and steady pressure, such as open cycle cooling water systems, because there are not significant flow and pressure variations. The pump cassystem can be steel or carbon experience losgeneral, seleccrevice, and minfluenced corBecause there and pressure vsystems, low fviable aging mThe GALL repaddress this cthis aging mecin Auxiliary Sy
April 2001 B.2.6-21 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC1-13 C1.6.1 Apply general corrosion only to the carbon steel material as an applicable aging mechanism. Stainless steel is not susceptible to general corrosion. Basket straine

open-cycle cofabricated from Because the Ssusceptible to The GALL repaddress this cthat only CS cto this aging mboth SS and Csusceptible to microbiologicacorrosion and 

G-VIIC1-14 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (VII I). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. See NRC disp

comment G-VTable B.2.6.
NUREG-1739 B.2.6-22 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC2-1 System Description Revise sentence addressing Regulatory Guide 1.26 as follows: “Based on the Nuclear Regulatory commission Regulatory guide 1.26, “Quality Group Classifications and Standards for Water, Steam, and Radioactive Waste Containing components of Nuclear Power Plants,” all components in the closed cycle cooling water system are classified as Group “C” quality Standards, with the exception of those forming part of the containment penetration boundary which are Group “B.” Since scope of Section VII C2 now also includes containment isolation portion of system, Quality Group classification requires clarification. The Quality G

clarified by ussentence: “BaGuide 1.26, “QClassifications Water, SteamWaste ContainNuclear Powecomponents in cooling water as Group “C” Qthe exception of the containmboundary whicThe GALL repaddress this c

G-VIIC2-2 C2.1.1 Delete reference to ASME OM Part 2. Add: “If the adequacy of the chemistry control programs cannot be confirmed over the total operating history of the plant or if any unexplained downward trend in heat exchanger performance is identified that cannot be remedied by maintenance of an open-cycle system, it may be necessary to selectively perform functional testing of the affected heat exchangers. Refer to comments in Chapter XI.M4 for justification. See NRC disp

comment G-VAppendix B, T
April 2001 B.2.6-23 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC2-3 C.2.2.1 (1) Need to add Stainless material for valves. (2) Revise Aging Mechanism Column by adding “(carbon steel only)” after General corrosion. Some plants also utilize stainless steel valves in their closed cooling water systems. The Closed Cooling Chemistry Program addresses the aging effects of stainless steel. (1) It is correc

use SS valves  (2) The SS vaare not suscepcorrosion. The GALL repaddress this cas a material ovalves and clacomponents amechanism. G-VIIC2-4 C.2.3.1 Need to add Cast Iron material for Pump Casing. Also add “Dealloying (Cast iron only)” to Aging Mechanism Column. No other changes are required to remaining columns. Some plants also utilize cast iron material for pumps in their closed cooling water systems. The Closed Cooling Chemistry Program addresses the aging effects of cast iron. Some plants uCCCW systemis an aging mefor cast iron anAMP “SelectivMaterials” (XI.Vol. 2). The GALL repaddress this ccast iron as a consideration 

G-VIIC2-5 C.2.5.1 Need to add Stainless material for flow orifice. No other changes are required to columns. Some plants also utilize stainless steel orifices in their closed cooling water systems. The Closed Cooling Chemistry Program addresses the aging effects of stainless steel. SS has no agi

cooling water The GALL repaddress this c

G-VIIC2-6 C2.4.1, C2.5.1 Add general corrosion to aging mechanism column. General corrosion should be added in a manner similar to other equipment in this section. General corro

CS in treated wThe GALL repaddress this c
NUREG-1739 B.2.6-24 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC2-7 C2.6.1 This row is incomplete. The Reference and AMP column are blank. In addition, the index page (VII C2-1) for section C2 does not show this item number. Provide information in the appropriate columns and the index page OR remove and include lube oil cooler in the appropriate auxiliary system as stated in the second paragraph under “System, Structures, and Components” on page VII C2-3. There was onl

the lube oil coIGSCC in the power plant hioccurred at FoThe GALL repaddress this cthis line item. G- VIC2-8 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (VII I). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. See NRC disp

comment G-VTable B.2.6. G-VIIC3-1 C3.1.1, C3.2.1 Change aging mechanism from “selective leaching” to “dealloying” in the aging mechanism and AMP columns. To ensure consistency between GALL sections VII C1 and VII C3. Brass, bronze

subject to a semechanism. Tthroughout GAstandard term(and includes of selective leato dealloying in have been chaleaching. The GALL repaddress this c
April 2001 B.2.6-25 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIC3-2 C3.1.1, C3.2.1, C3.3.1 Add a comma after “Raw” in the environment column and “Untreated Salt Water.” To ensure consistency between GALL sections VII C1 and VII C3. A comma was 

the environme“Untreated Sahave consisteThe GALL repaddress this c

G-VIIC3-3 C3.2.1 Add carbon steel to the material column and general corrosion (for CS only without internal lining or coating) to the aging mechanism column. To ensure consistency between GALL sections VII C1 and VII C3 and the AMP column. Global change

throughout Chconsistent deslinings (elasto(SS). The GALL repaddress this c

G-VIIC3-4 C3.3.1 Revise the AMP column and the Evaluation and Technical Basis column to delete any reference to selective leaching for brass. Brass material is not included in the material column of this Item number. The selective 

material “brasconsideration The GALL repaddress this c

G-VIIC3-5 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (VII I). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. See NRC disp

comment G-VTable B.2.6.
NUREG-1739 B.2.6-26 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIID-1 System Description Revise sentence addressing Regulatory Guide 1.26 as follows: “Based on the Nuclear Regulatory commission Regulatory guide 1.26, “Quality Group Classifications and Standards for Water, Steam, and Radioactive-Waste Containing components of Nuclear Power Plants,” all components of the compressed air system are classified as Group “D” quality Standards, with the exception of those forming part of the containment penetration boundary which are Group “B.” Since scope of Section VII D now also includes containment isolation portion of system, Quality Group classification requires clarification. The Quality G

clarified by ussentence: “BaGuide 1.26, “QClassifications Water, SteamWaste ContainNuclear Powecomponents osystem are claQuality Standaexception of ththe containmeboundary whicThe GALL repaddress this c

G-VIID-2 D.1.1, D.2.1 through D.2.3, D.3.1, D.4.1 through D.4.3 Replace “Internal: Dry, Oil-Free Air” with “Saturated Air”. Dry, Oil-Free Air is not an aggressive environment conducive to aging effects for carbon and low alloy steels; however, moist or saturated air is. Saturated or moist air conditions should exist only upstream of air dryers in typical compressed air system. Plants have addressed air quality issues downstream of dryers per their response to GL 88-14. These responses included many one-time verifications of proper system design, and also assuring adequate maintenance/operating practices: 1) Verification that actual instrument air quality is consistent with manufacturers recommendations for safety related components, 2) The environm

components osystem are exfrom saturated fittings to meredryer. The AMMonitoring” (XVol. 2) reflects it proceeds thrdryers. The GALL repaddress this c
April 2001 B.2.6-27 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIID-2 (cont.) Verification that maintenance practices, emergency procedures, and training are adequate, and 3) Verification that the design of the entire system including air or other pneumatic accumulators is in accordance with its intended function. Note: This included testing of air operated valves. Compressed air systems having design features such as air dryers and filters typically have dew point alarms and/or dew point is tested periodically by the operators as part of their routine monitoring of the equipment. This should not be considered as an aging management program. Aging management activities or programs should only be provided for “saturated air” portion of the system upstream of air dryers. These components are subject to internal general and pitting corrosion. However, because of differences in system design and management philosophy, these aging management activities should be evaluated on a plant specific basis.
NUREG-1739 B.2.6-28 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE1-1 E1.6.1, E1.6.2 Delete E1.6.1 from Item column and delete Casing from Region of Interest column for BAC Aging Mechanism. The Low Pressure Pump Casing (item E1.6.1) is stainless steel and not subject to BAC. The low-press

fabricated from susceptible to The casing waof interest. The GALL repaddress this c

G-VIIE1-2 E1.7.1 through E1.7.4 (p. E1-8) Change Material from LAS, CS to stainless steel. The Regenerative Heat Exchanger has a borate water for both shell and tube side and is made of stainless steel not carbon steel. The regenerat

fabricated only The closure bofrom the LAS The GALL repaddress this c

G-VIIE1-3 E1.10.1 through E1.10.4 (really E1.10.2 through E1.10.4) Delete this item. The Volume Control Tank is made of stainless steel not carbon steel. The listed Aging Mechanism is not valid for stainless steel and borated water. The volume co

constructed onsusceptible to corrosion in bovolume controfabricated of Lretained as a tSection E1 beboric acid corrThe GALL repaddress this cthe line items E1.10.4 (shell nozzle, and pe

G-VIIE1-4 E1.10.1 through E1.10.4 If comment G-VII E1-3 above is not incorporated, Change “Pitting and Crevice Corrosion” to “BAC”. This entry seems inconsistent with all other entries on leaking Borated Water. See NRC disp

Comment G-VTable B.2.6.
April 2001 B.2.6-29 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE1-5 E1.7.1 through E1.7.4 Delete the Aging Mechanism ‘Unanticipated cyclic loading’. Unanticipated cyclic loading is not a valid Aging Mechanism. The term “una

eliminated becis not anticipatmanaged in anThe GALL repaddress this c

G-VIIE1-6 E1.8.1 through E1.8.3 Delete the Aging Mechanism ‘Unanticipated cyclic loading.’ Unanticipated cyclic loading is not a valid Aging Mechanism. The term “una

eliminated becis not anticipatmanaged in anThe GALL repaddress this c

G-VIIE1-7 E1.5.1, E1.5.2, E1.6.1, E1.6.2 Delete the Aging Mechanism Fatigue. Fatigue is listed as an Aging Mechanism for the Low Pressure and High Pressure Pump. These components are not subjected to high temperatures or thermal cycles that could cause Fatigue; this Aging Mechanism should not be listed for these items. Temperatures 

are relatively bbeen deleted amechanism fohigh-pressure chemical and for PWRs. The GALL repaddress this c
NUREG-1739 B.2.6-30 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE1-8 E1.2.1 Delete the Aging Mechanism stress corrosion cracking. Low Pressure Piping Stress Corrosion Cracking identifies the Environment as External with Heat Tracing and internal with treated water. The Region of Interest is identified as Low Pressure Piping up to 100°C. The use of adhesives with halogens would appear to be a ‘Degradation induced by human activities’ (Generic Licensing Renewal Issue # 98-0013) and not a real Aging concern. Pipe, fittings, a

150psig rating deleted as comThe SCC aginpressure pipinbecause the uhalogens can induced by hu(Generic Licen98-0013) whicconcern. The GALL repaddress this c

G-VIIE1-9 E1.4.1 Delete the Aging Mechanism stress corrosion cracking. Low Pressure Valves Stress Corrosion Cracking identifies the Environment as External with Heat Tracing and internal with treated water. The Region of Interest is identified as Low Pressure Piping up to 100°C. The use of adhesives with halogens would appear to be a ‘Degradation induced by human activities’ (Generic Licensing Renewal Issue # 98-0013) and not a real Aging concern. The SCC agin

pressure valvebecause the uhalogens can induced by hu(Generic Licen98-0013), whicconcern. The GALL repaddress this c
April 2001 B.2.6-31 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE1-10 E1.1.2 Remove all references to ISI for managing Boric Acid Corrosion. See justification for comment on item XI.M5. NRC GL 88-05 

alone program carbon steel scomponents foacid leakage aInservice inspleakage identiperformance ohydrostatic tesASME Code aindependent oCorrosion” (XIVol. 2) and we

The GALL rep

address this c

G-VIIE1-11 E1.7.1 through

E1.7.4, E1.8.1through E1.8.3

Delete entry for Crack Initiation andGrowth.

This AE, shown as resulting from“SCC, Unanticipated Cyclic Loading”has been added since the originaldraft. No reference is provided tojustify the inclusion of thesemechanisms. In addition,“Unanticipated Cyclic Loading” is notclearly defined. This AE/AMcombination was not identified in thefirst two LRAs.

Crack initiation legitimate aginSCC and cycliregenerative hPWR chemicasystem. The tewas eliminated mechanism is cannot be manThe GALL repaddress this c
NUREG-1739 B.2.6-32 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE1-12 E1.10.2 through E1.10.4 Make this entry consistent with the remainder of section VII.E1. Both the inclusions of the AE/AM combination and the credited program seem inconsistent with other entries. AE/AM: Loss of Material/Pitting and Crevice Corrosion is not included as an external effect for other CS/LAS components. Programs: For Loss of Material/Pitting and Crevice Corrosion, this entry refers to a previous entry for the same AE/AM for item VII E1.8.4. The previous item credits the Closed Cycle Cooling Water Chemistry program, which applies to neither external nor borated water environments. The volume co

constructed onsusceptible to corrosion in boitems E1.10.2 and access copenetration) wvolume controfabricated of Lretained as a tSection E1 beboric acid corrThe GALL repaddress this c

G-VIIE2-1 E2.1.1 Under element 3 of Evaluation and Technical Basis, delete the second sentence and replace with, “Inspection requirements of IWC 2500-1 specify periodic volumetric or surface examination of welds in class 2 components.” As stated in our previous comments sent to the NRC, the category references like category C-A or C-F- 1 are only applicable to the 1989 Edition of ASME Section XI. These categories may be deleted or changed to something else in later editions. The AMP should be based on ASME Section XI requirements for class 2 components, period. Stainless stee

the presence ohave been insspent fuel pooCracking instaPWRs were st(1980). Affectepiping from botank to RHR scooling pipingAMP is “WateNUREG-1801The GALL repaddress this c
April 2001 B.2.6-33 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE2-2 Entire section Typos in the Material and environment columns require correction. These typos make an evaluation of the material presented in the other columns difficult. Structures and 

standby liquid BWRs are subenvironment cpentaborate so90°F) and ~ 24The GALL repaddress this c

GVIIE2-3 E2.1.1 Environment temperature ranges do not agree. SCC ranges should be from 93oC to 194oC. SCC is not an appropriate aging effect for the internal surfaces of these components when their normal operating temperature is less than 200°F (93oC). Even at lower 

21-32°C (70-9subject to SCC impurities. Theinstances of fapool cleanup sinstances in pstudied in NURAffected systefrom borated wRHR suction, piping, etc. An “Water Chemi1801, Vol. 2). a particular agactive can not since it cannot predicted even disregarded bactive aging mtime then that the predictabilrange over whaging mechanThe GALL repaddress this c
NUREG-1739 B.2.6-34 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE2-4 E2.1.1 Specifically with respect to the piping that is downstream of the explosive valves and upstream of the containment isolation valves, errors in the table for materials (should be SS) and Environment (should be Treated Water or Demineralized water). Temperature range should be from 93oC to 194oC. Higher temperatures are unlikely in this item. Also demineralized water is most often used to flush any part of this line, and the cleanliness requirements and chemical controls are at least as good as the treated water systems. This section o

only exposed does not occudeleted. The GALL repaddress this c

GVIIE2-5 E2.1.1 AMP should be Chemistry Controls with resultant E&TB section. This section of piping will receive the same treatment as any piping that could discharge water into the reactor vessel. Therefore, an acceptable AMP would be the AMP outlined in XI.M11. Stainless stee

contact with sosolution (~ 24,21-32°C (70-9susceptible to cracking. An a“Water Chemi1801, Vol. 2). The GALL repaddress this c

GVIIE2-6 E2.2.1, E2.3.1, E2.4.1 The temperature range appears unusually high, especially for the storage tank. The temperature range should not exceed boiling (~100oC). The low temperature for the range should be in keeping with the other comments of this section: 93oC (200°F). While high temperature spots around the heaters are possible, it is very unlikely that 302oF would ever be reached. SCC is not a detrimental aging effect in components containing sodium pentaborate unless the mixing is inadequate and the temperature normally exceeds 200°F. In the standby 

in BWRs, the storage tanks, bonnets, and tcasing are exppentaborate soB) at 21-32°C susceptible to cracking. The GALL repaddress this c
April 2001 B.2.6-35 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE2-7 Item Missing, applies to E.2.1.1 Cracking due to thermal fatigue is not discussed in this section for piping and should be to be consistent with other sections. Cracking due to thermal cycling induced fatigue will have been addressed through a TLAA for BWR plants. This section does not contain this aging effect and should to be consistent with other sections. In the standby 

in BWRs, the and fittings are sodium pentabdemineralized (between the edischarge valvisolation valvesystem. Since used in emergexperience cyThe GALL repaddress this c

GVIIE2-8 E2.1.1, E2.2.1, E2.2.2, E2.3.1, E2.4.1 Delete all entries for SCC. Based on the operating experience presented in the Evaluation and Technical Basis entries, Items (4) and (10), it appears that these entries should be removed as the case is made that this Aging Mechanism will not occur. Stress corrosi

stainless steel exposed to boat temperaturecontaminants water. This is operating expe(NRC IN 79-19As suggested meeting on 01reviewed the iNUREG/CR-6that operating that degradatiowater chemistaging managerevised to rely chemistry progThe GALL repaddress this c
NUREG-1739 B.2.6-36 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE3-1 All Items This section should be deleted. (Comments below are provided in case this comment is not incorporated into GALL.) The components in this section are not in scope of license renewal. Even though t

cleanup systethe reactor waa pressure booperation (NRfor license renThe GALL repdocument. The GALL repaddress this c

GVIIE3-2 E3.1.1 Consistency issue: this item correctly identifies the temperature range for SCC in SS components. Other commodities in other sections do not. SCC is not an applicable aging effect in non-saline solutions when the normal operating temperature is less than 200°F. The temperatu

SS componenconsistent for regimes throuVII. The tempeup to 550°F unheat exchangedecreasing. SGALL. The GALL repaddress this c

GVIIE3-3 E3.1.1 The lower limit of, “>93oC,” should read, “Up to 288oC (550°F)” for the line item dealing with Cumulative Fatigue Damage. The basis for excluding piping that has thermal cycles from room temperature up to 93oC is unclear. Depending upon the pipe geometry, low to moderate temperature cycling may be dominating in the pipe stress analysis. Stainless stee

beyond the sethe BWR reac(RWCU) systeoxygenated w550°F). The GALL repaddress this c
April 2001 B.2.6-37 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE3-4 E3.2.1 A lower limit should be placed on the temperature range for SCC in the pump casing. This limit should be 200°F. NUREG-0313 provides a basis for 200°F as a lower limit. Given the high controls placed on the chemistry of the RWCU fluids, SCC is not an applicable aging effect for the pump casings that operate normally below 200°F. The cast auste

RWCU pump oxygenated w550°F). The GALL repaddress this c

GVIIE3-5 E3.2.2 SLAS should be spelled when first used. Writing style comment. Acronyms suc

alloy steel (HSwhen they are chapter of GAThe GALL repaddress this c

GVIIE3-6 E3.2.1 A site-specific program should handle fatigue for the pump casing. No CLB may exist for a TLAA on the pump casings. The design analysis is vendor specific and may not be a TLAA. The comment 

licensing basis TLAA on the pvalid for some the extent that may not have these older plarenewal applicdemonstrate coriginal licensicriteria for 60-not include a fthe applicant dperform one. The GALL repaddress this c
NUREG-1739 B.2.6-38 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE3-7 E3.2.2 Delete entry for Stress Relaxation. Stress Relaxation is the unloading of pre-loaded components caused by long term exposure to elevated temperatures and/or neutron irradiation. The stress in a member decreases when a constant amount of deformation is applied due to creep. Loss of prestress occurs at a decreasing rate; the majority of the loss is within the first year. The amount of prestress loss significantly decreases with time to approach an asymptotic value. Therefore, the level of prestress with extended operation should be comparable to current conditions. Proper component specification, design, and maintenance practices prevent this mechanism from occurring. Creep is not a concern for alloy and ferritic steels below 700oF, for austenitic steels below 800oF, and for nickel based alloys below 1800oF. Creep is not generally a consideration in light water reactors due to operation at a maximum of 650oF or below, which is somewhat below the creep range for most ASME Code materials. ` The high-stren

RWCU pump be affected by the operationaThis entry was The GALL repaddress this c
April 2001 B.2.6-39 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE3-8 E3.3.1 through E3.3.4 The line item addressing Crack Initiation and Growth for the Regenerative Heat Exchanger should be split into two items because the temperature limitations on the SCC mechanism are different from the cyclic loading mechanism. SCC is not an applicable aging effect in non-saline solutions when the normal operating temperature is less than 200°F. The stainless 

the regeneratiexposed to ox288°C (550°F) temperature apressure. Eve(comment E2-SCC should blegitimate aginThe GALL repaddress this c

GVIIE3-9 E3.3.1 through E3.3.4 Remove references to “Cyclic Loading”. “Cyclic Loading” is not a mechanism. SCC can be postulated to result in crack growth without consideration of “Cyclic Loading”. Inclusion of “Cyclic Loading” adds no value to this entry. Stress corrosi

stainless steel regenerative hBWR reactor wresults in cracThe term “cycdeleted from caging mechanThe GALL repaddress this c

GVIIE3-10 E3.4.1 through E3.4.4 The line item addressing Crack Initiation and Growth for the Non-Regenerative Heat Exchanger should be split into two items because the temperature limitations on the SCC mechanism are different from the cyclic loading mechanism. SCC is not an applicable aging effect in non-saline solutions when the normal operating temperature is less than 200°F. The stainless 

the nonregeneare exposed to a 288°C (550°temperature apressure. Eve(comment E2-SCC should blegitimate aginThe GALL repaddress this c
NUREG-1739 B.2.6-40 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

GVIIE3-11 E3.4.1 through E3.4.4 Remove references to “Cyclic Loading”. “Cyclic Loading” is not a mechanism. SCC can be postulated to result in crack growth without consideration of “Cyclic Loading”. Inclusion of “Cyclic Loading” adds no value to this entry. Stress corrosi

stainless steel nonregeneratithe BWR reacsystem results growth. The tewas deleted fran aging mechThe GALL repaddress this c

GVIIE3-12 E3.4.4 A maximum temperature limit for the line item for MIC should be expressed. 200°F is an acceptable limitation. For portions of the RWCU that regularly see temperatures in excess of 200°F, MIC is not an applicable aging mechanism. Microbiologica

corrosion affecheat exchangecycle cooling waccess cover mechanism of of the RWCU under 200°F. The GALL repaddress this c
April 2001 B.2.6-41 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE4-1 E4.1.1 Under element 2 of Evaluation and Technical Basis, delete the last sentence regarding hydrogen water chemistry. Both hydrogen water chemistry and noble metal addition are economic and business decisions made by each utility for their plants and should not be credited as a preventive action within GALL. This is a generic comment in various sections of the GALL for BWR’s. The AMP “W

(XI.M2, NUREaugmentation Time Inspecti1801, Vol. 2) piping and fittcooling system denoted in EleActions” of thChemistry” (XVol. 2), the uschemistry and are not requiruse may allow of inservice insteel piping ainternals. Hydeffective in reelectrochemicrecirculation pless effective Noble metal acatalytic actioeffectiveness in the core reThe GALL repaddress this c
NUREG-1739 B.2.6-42 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE4-2 E4.1.1 The Evaluation and Technical Basis elements 3, 5 and 10 have detailed information that is not necessary. Chapter V D2, item D2.1.1-D2.1-7 for similar materials and aging effect provides clear and succinct information for these elements and should be duplicated in this chapter and section. Specifics are as follows: Element 3, Parameters Monitored/Inspected: delete all and replace with element 3 information of Evaluation and Technical Basis of Chapter V.D2, item D2.1.1-D2.1.7. Element 5, Monitoring and Trending: delete the example after Section XI that states “e.g., 25% are examined every 10 y. at least 12% in 6 y.” Element 10, Operating Experience: delete all sentences after second sentence and replace with, “The AMP outlined in GL 88-01 has been effective in managing the effect of stress corrosion cracking in SS piping.” These changes will make the GALL consistent for description of AMPs for similar materials and aging effects in different chapters of the GALL report. Stainless stee

shutdown cooBWRs exposwater are suscorrosion cracaging manageinclude “BWR Cracking” (XIVol. 2) and “W(XI.M2, NUREThe GALL repaddress this c
April 2001 B.2.6-43 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIE4-3 E4.3.1 In the AMP column, (1) delete the “and” between BWRVIP 29 and TR-103515. Instead replace with “BWRVIP 29 (TR-103515). (2) Evaluation and Technical Basis: Element 2 delete “and TR-103515” and the last sentence about hydrogen water chemistry. (3) Element 3 delete the second sentence about details of ISI categories. TR-103515 is BWRVIP 29. See rationale above and in comment 1. Makes it consistent with other GALL sections. See comment 2. Stainless stee

bonnets in shsystems in oldoxygenated wstress corrosiAppropriate aprograms incCorrosion CraNUREG-1801Chemistry” (XVol. 2). (1 and 2) The BWRVIP-29 asame documedocument is uis referred to (3) As denote“Detection of AMP “Water CNUREG-1801itself, inspecticomponents mverify the effechemistry conensure that siis not occurrinintended funcduring the extoperation. The GALL repaddress this cabove.
NUREG-1739 B.2.6-44 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF1-1 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping. The external surfaces of piping etc. should be included in Section VIII I, however this link is not clearly established. See NRC disp

comment G-VTable B.2.6. G-VIIF1-2 System Interface Include a reference to Section VII C2 (Closed Cycle Cooling Water System) as the cooling coils typically receive their cooling from this source. The cooling coils typically receive their cooling from another system and this source is typically a Closed Cycle Cooling Water System. Clarification hathe System Intintroductory paRoom Area Ve(Table F1) by sentence. “Ththeir cooling wsystems such system or the system.” The GALL repaddress this c
April 2001 B.2.6-45 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF1-3 F1.4.2 Delete all references to Charcoal Adsorber Filter. The Charcoal Adsorber Filter is not a ‘passive long lived component.’ Charcoal Adsorber is typically tested in accordance with Technical Specifications and Reg. Guide 1.52. Change out of Charcoal is expected during a 40-year plant life. The charcoal a

replaced durinThe charcoal apassive, long-will not be submanagement The SRP was guidance and consideration stated in SRP Staff Guidance consumables (d) for system extinguishers, packs are typion performancmonitoring thathese compontheir qualified excluded, on a from aging maunder 10 CFR The GALL repaddress this c
NUREG-1739 B.2.6-46 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF1-4 F1.1.1, F1.1.2, F1.2.1, F1.4.1 Remove reference to MIC. Microbiologically Influenced Corrosion is listed as an Aging Mechanism for the ducting, filters, and cooling coils. The fluid inside the duct is air with the potential for some moisture. Moisture does not subject the components to the aggressive environment normally associated with this type of corrosion. Therefore, this aging mechanism should not be considered. See NUREG-1705. Microbiologica

corrosion (MICmechanism focooling coils thcharacterized aggressive enassociated witThe GALL repaddress this cMIC as an agiconcern for dufor moisture d

G-VIIF1-5 F1.2.1 Remove reference to General Corrosion. This Aging Mechanism is listed for the Containment Air Handler Heating/Cooling Coils. The coils are annealed 90/10 copper nickel and is not susceptible to this type of corrosion. Therefore, this Aging Mechanism should not be considered. The 90/10 cop

containment aheating/coolinroom area venexposed to wasusceptible to corrosion. This susceptible to The GALL repaddress this cgeneral corrosmechanism.
April 2001 B.2.6-47 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF1-6 F1.3.1 Remove reference to MIC. Treated Closed Cycle Cooling Water is not susceptible to MIC. Carbon steel c

to chemically tcooling water susceptible to influenced cortreated CCCW biological growmechanism wand fittings in ventilation sysThe GALL repaddress this c

G-VIIF1-7 F1.1.3, F1.1.4 Remove “and Radiation” from Aging Mechanism entry. Location of equipment would preclude radiation from contributing to aging during normal operations. The Neoprene 

in the control rsystem are exair and are susinduced elastoThere is no ranormal operatThe GALL repaddress this cthe contributioaging mechan

G-VIIF2-1 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping. The external surfaces of piping etc. should be included in Section VIII I, however this link is not clearly established. See NRC disp

comment G-VTable B.2.6.
NUREG-1739 B.2.6-48 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF2-2 System Interface Include a reference to Section VII C2 (Closed Cycle Cooling Water System) as the cooling coils typically receive their cooling from this source. The cooling coils typically receive their cooling from another system and this source is typically a Closed Cycle Cooling Water System. Clarification ha

the System Intintroductory paand Radwaste System (Table following sentereceive their cother systems system or the system.” The GALL repaddress this c

G-VIIF2-3 F2.4.2 Delete all references to Charcoal Adsorber Filter. The Charcoal Adsorber Filter is not a ‘passive long lived component.’ Charcoal Adsorber is typically tested in accordance with Reg. Guide 1.52. Change out of Charcoal is expected during a 40-year plant life. See NRC disp

comment G-VAppendix B, T

G-VIIF2-4 F2.1.1, F2.1.2, F2.2.1, F2.4.1 Remove reference to MIC. Microbiologically Influenced Corrosion is listed as an Aging Mechanism for the ducting, filters, and cooling coils. The fluid inside the duct is air with the potential for some moisture. Moisture does not subject the components to the aggressive environment normally associated with this type of corrosion. Therefore, this aging mechanism should not be considered. See NUREG-1705. See NRC disp

comment G-VAppendix B, T
April 2001 B.2.6-49 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF2-5 F2.2.1 Remove reference to General Corrosion. This Aging Mechanism is listed for the Containment Air Handler Heating/Cooling Coils. The coils are annealed 90/10 copper nickel and is not susceptible to this type of corrosion. Therefore, this Aging Mechanism should not be considered. See NRC disp

comment G-VAppendix B, T

G-VIIF2-6 F2.3.1 Remove reference to MIC. Treated Closed Cycle Cooling Water is not susceptible to MIC. See NRC disp

comment G-V

Appendix B, 

G-VII F2-7 F2.1.3, F2.1.4 Remove “and Radiation” from Aging Mechanism entry. Location of equipment would preclude radiation from contributing to aging during normal operations. See NRC disp

comment G-V

Appendix B, 

G-VII F3-1 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping. The external surfaces of piping etc. should be included in Section VIII I, however this link is not clearly established. See NRC disp

comment G-VTable B.2.6. G-VIIF3-2 System Interface Include a reference to Section VII C2 (Closed Cycle Cooling Water System) as the cooling coils typically receive their cooling from this source. The cooling coils typically receive their cooling from another system and this source is typically a Closed Cycle Cooling Water System. Clarification hathe System Intintroductory paContainment HSystem (Table following sentereceive their cother systems system or the system.” The GALL repaddress this c
NUREG-1739 B.2.6-50 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF3-3 F3.4.2 Delete all references to Charcoal Adsorber Filter. The Charcoal Adsorber Filter is not a ‘passive long lived component.’ Charcoal Adsorber is typically tested in accordance with Technical Specifications and Reg. Guide 1.52. Change out of Charcoal is expected during a 40-year plant life. See NRC disp

comment G-VAppendix B, T

G-VIIF3-4 F3.1.1, F3.1.2, F3.2.1, F3.4.1 Remove reference to MIC. Microbiologically Influenced Corrosion is listed as an Aging Mechanism for the ducting, filters, and cooling coils. The fluid inside the duct is air with the potential for some moisture. Moisture does not subject the components to the aggressive environment normally associated with this type of corrosion. Therefore, this aging mechanism should not be considered. See NUREG-1705 See NRC disp

comment G-VAppendix B, T

G-VIIF3-5 F3.2.1 Remove reference to General Corrosion. This Aging Mechanism is listed for the Containment Air Handler Heating/Cooling Coils. The coils are annealed 90/10 copper nickel and is not susceptible to this type of corrosion. Therefore, this Aging Mechanism should not be considered. See NRC disp

comment G-VAppendix B, T

G-VIIF3-6 F3.3.1 Remove reference to MIC. Treated Closed Cycle Cooling Water is not susceptible to MIC. See NRC disp

comment G-V

Appendix B, 

G-VIIF4-1 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of piping. The external surfaces of piping etc. should be included in Section VIII I, however this link is not clearly established. See NRC disp

comment G-VTable B.2.6.
April 2001 B.2.6-51 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF4-2 System Interface Include a reference to Section VII C2 (Closed Cycle Cooling Water System) as the cooling coils typically receive their cooling from this source. The cooling coils typically receive their cooling from another system and this source is typically a Closed Cycle Cooling Water System. Clarification ha

the System Intintroductory paGenerator BuiSystem (Table following sentecoils receive thother systems system or the system.” The GALL repaddress this c

G-VIIF4-3 F4.1.1, F4.1.2, F4.2.1 Remove reference to MIC. Microbiologically Influenced Corrosion is listed as an Aging Mechanism for the ducting, filters, and cooling coils. The fluid inside the duct is air with the potential for some moisture. Moisture does not subject the components to the aggressive environment normally associated with this type of corrosion. Therefore, this aging mechanism should not be considered. See NUREG-1705. See NRC disp

comment G-VAppendix B, T

G-VIIF4-4 F4.2.1 Remove reference to General Corrosion. This Aging Mechanism is listed for the Containment Air Handler Heating/Cooling Coils. The coils are annealed 90/10 copper nickel and are not susceptible to this type of corrosion. Therefore, this Aging Mechanism should not be considered. See NRC disp

comment G-VAppendix B, T

G-VIIF4-5 F4.3.1 Remove reference to MIC. Treated Closed Cycle Cooling Water is not susceptible to MIC. See NRC disp

comment G-V

Appendix B, 
NUREG-1739 B.2.6-52 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIF4-6 F4.1.3, F4.1.4 Remove “and Radiation” from Aging Mechanism entry. Location of equipment would preclude radiation from contributing to aging during normal operations. See NRC disp

comment G-V

Appendix B, 

G-VIIG-1 VIIG The fire protection program needs to be combined and placed in Chapter XI. Separate sections could be provided for fire barrier penetration seals; fire barrier walls, ceiling, and floors; and fire rated doors. Place program in Chapter XI to be consistent with other programs. The AMP “Fire 

NUREG-1801barrier inspectdiesel-driven fprogram. The program requiinspection of fseals, fire barrfloors, and perand function teto ensure that maintained. The GALL repaddress this c
April 2001 B.2.6-53 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIG-2 VIIG Rather than focus on structures, which may change from site to site, this section should be rewritten to focus on components. Combine items G.1, G.2, G.3, G.4, and G.5 into three items: Fire Barriers, Fire Barrier Penetrations Seals, and Fire Rated Doors. Editorial comment The AMP “Fire 

NUREG-1801barrier inspectdiesel-driven fprogram. The program requiinspection of fseals, fire barrfloors, and perand function teto ensure that maintained. Abe different in The GALL repaccording to sstructures. Clatypically includand componenThe applicant of conducting specific prograThe GALL repaddress this c
NUREG-1739 B.2.6-54 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIG-3 VIIG, Page VIIG-3 The structures in the first paragraph are not necessarily included within fire protection at all sites. The list of structures should be deleted. Editorial comment Representativ

structures, turprovided in the and Componeintroductory paProtection secbe applicable although there examples. The scoping documstructures typistructures and identified in VIalways has the an alternative program. The GALL repaddress this c

G-VIIG-4 VIIG, G1.1 Page VIIG-5 Add the following as introduction for evaluation and technical basis: SECY-96-146 documents aging evaluations of fire barrier penetration seals, with details provided in an attached report. The report states that “many fire barrier materials are resistant to thermally accelerated aging and that the material properties of silicone-based material, which dominate the industry, are particularly age independent.” The document also reports they “did not find any penetration seal problems that were directly related to aging.” Therefore, SECY-96-146 has drawn conclusions on aging of penetration seals. To ensure that these conclusions are captured and that no programs are required for aging management for penetration seals, the information should be included in this section. Section 5.7 of 

concludes thavendor seal inare adequate penetration seproblems. Howconcluded thapenetration seadequate to admonitoring/preaging penetratexample, planfocus on degravoids, holes, spenetration seare penetratioissues. The in
April 2001 B.2.6-55 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIG-4 (cont.) no aging effects should be identified for penetration seals. However, if plant specific aging effects are identified which require aging management, the fire barrier inspection as presented below provides an acceptable method for managing aging. An applicant needs to ensure that its implementation of the fire barrier inspection is consistent with this evaluation. is to manage t

prior to the losfunction. Actiopreventive/mowould focus oaging effects, cracking or seeventually affethe loss of the an indication tpenetration seintent of 10 CFthe staff did no96-146 that abaging could neas plants operFurthermore, the influence omovement cauheatup/cooldowith refueling movements caseals to move lead to shrinkacracking and sThe GALL repaddress this c
NUREG-1739 B.2.6-56 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIG-5 VIIG1.1, page VIIG-5 Change the following attributes under the program: (2) Preventive Actions: No preventive actions are specified. The program is a monitoring program. (4) Detection of Aging Effects: Visual inspection should detect cracking, separation from walls and component, rupture and puncture of seal. Visual inspection of a sample is performed at least once every 18 months. The frequency and extent of inspection ensures timely detection of the aging effects before loss of component intended function. The attributes are changed to more correctly reflect the program. This statement matches how other preventive actions are addressed when it is a monitoring program. Clarified that a sample is inspected every 18 months. The AMP “Fire 

NUREG-1801barrier inspectdiesel-driven fprogram becanot clearly outand (4) have bhow other prevaddressed and detection of agThe GALL repaddress this c
April 2001 B.2.6-57 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIG-6 VIIG1.2, page VIIG-5 and VIIG1.3, page VIIG-7 Change the following attribute: (2) Preventive Actions: No preventive actions are specified. It is a monitoring program. This statement matches how other preventive actions are addressed when it is a monitoring program. The fire barrie

floors and also the intake struaging resulting The AMP “Fire NUREG-1801“Structural MoNUREG-1801aging of the firceilings, and fProtection”(XIVol. 2) managrated doors. In AMP, element include the folplants, fire hazthe fire potentsafety-related specifies meaprevention, fire suppression, aand alternative for each fire astructures, syscomponents imThe GALL repaddress this c
NUREG-1739 B.2.6-58 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIIG-7 VIIG1.2, Page VIIG-5 Under parameters monitored, do not discuss the mechanisms. The rule focuses on aging effects, not mechanisms. Aging of the fi

ceilings, and fstructure is ma“Fire Protectio1801, Vol. 2) aMonitoring AM(3) “ParameteMonitored/Insp“Fire Protectio1801, Vol.2), vfire barrier wais said to examdegradation suspalling, and loby freeze-thawreaction with ainspection of pexamines the such as crackfrom walls and separation of lrupture and puare directly cahardness and material due to The focus in theffects (as promechanisms). The GALL repaddress this c
April 2001 B.2.6-59 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII G-8 G.1.3, G.2.3, G.3.3, G.4.3, G.5.2 Delete entry for “Wear.” Element (10) of Evaluation and Technical Basis concludes, “Operating experience with this AMP has shown that degradation is insignificant.” If degradation is insignificant, it cannot affect the intended function. Absence of de

first 40 years dproblems durinextended operElement 10 “Oit is noted that experienced whandles. The GALL repaddress this c
NUREG-1739 B.2.6-60 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII G-9 G.6.1, G.6.2 Delete entries for “Biofouling” for all components except sprinklers. Component intended function is pressure boundary only. Biofouling does not prevent this intended function. This Aging Mechanism has the potential to cause blockage of deluge system spray nozzles. Other than that, it should not be considered applicable for fire protection system piping and components. Biofouling affe

performance aintegrity. Flow considered an covered under basis and showithin the scopHowever, biofomaterial, whicboundary and requires aging The GALL repfollows to add1. For all pipinline items for bto biofouling w2. Loss of matwas included apiping and precomponents. 3. The aging mXI.M20 “OpenSystem,” XI.Mand XI.M27 “Fwere revised tflow blockage aging effect to material.
April 2001 B.2.6-61 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII G-10 G.7.1, G.7.2 Delete entries for Lubricating Oil environment. (1) General Corrosion, Galvanic Corrosion, Crevice Corrosion, and Pitting are listed as Aging Mechanisms for the RCP Oil Collection Tank, Piping, Tubing, and Valves. These corrosion mechanisms are not plausible for these components since the internal environment is lube oil and air. (2) Lube oil acts to inhibit corrosion of carbon steel, and there is inadequate moisture in the system to promote corrosion. Therefore, General Corrosion, Crevice Corrosion, and Pitting should not be listed for the lube oil collection system components. This position was accepted in the CCNPP SER. (3) The element (10) Operating Experience entries under Evaluation and Technical Basis concur that no corrosion-related degradation has been observed for these components. The collection 

tubing, and vareactor coolansystem are suoil environmen(1 and 2) Corrmechanism wcontaminant fo(tank, piping, tthe reactor cocollection systaddressed in tII, page 3.5-11 9, Vol. II, page ONS License 3-149 to 150). “lubricating oilcolumn was re“lubricating oil and/or moistu(3) A plant-spesuggested to dthickness of thtank. An accepprogram is pro“One-Time InsNUREG-1801The GALL repaddress this cabaove.
NUREG-1739 B.2.6-62 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII G-11 G.8.1 Remove reference to the Diesel Driven Fire Pump (Pump Casing). The fire water pump has been mistakenly included with fuel oil components. Both the fire w

the fuel oil line the program. Tshould be kepcasing. BG&E diesel fire pumto verify operathrough flow atests. The pumobservation duthe above testthe fuel oil supimmediately eThe GALL repaddress this c

G-VII G-12 G.8.1 Delete entry for Fuel Oil environment. (1) Loss of Material is listed as an applicable Aging Effect due to the Aging Mechanisms Crevice Corrosion, Pitting, Galvanic Corrosion, and General Corrosion for the Diesel Fire Pump Fuel Oil Supply Line. These corrosion mechanisms should only be considered plausible in fuel oil systems where there is a potential for water to pool or separate (tanks, receivers, stagnant piping, etc. (BAW-2270). The fuel oil supply line is not such a location, therefore, these mechanisms should not be considered. (2) This position was accepted in the Oconee SER. (3) The element (10) Operating Experience entries under Evaluation (1) The carbon 

fire pump casiline in the diesexposed to a fand are suscegalvanic, pittincorrosion. The and “Fuel Oil Cand XI.M30, Nmanage aging3 of the AMP “(XI.M26, NURdriven fire pumobservation dutests such as test, sequentiatest, and contrdetecting any supply line. Evaccepted in th
April 2001 B.2.6-63 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII G-12 (cont.) and Technical Basis concur that no corrosion-related degradation has been observed for these components. corrosion wou

the fuel oil syspotential for wseparate (tankpiping), this doposition appliein configurationot necessarilfrom having to (2) GALL is a document. A pthe Oconee Snecessarily prfrom having to (3) Absence ooperation to daproblems durinextended operThe GALL repaddress this c
NUREG-1739 B.2.6-64 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H1-1 H1.1.1, H1.4.2 (1) Delete the references in the References column Replace “For description of the AMP, see Chapter XI.S8 ‘Coating Program” with “Plant-specific aging management program” in the Aging Management Program column Replace “For evaluation and technical basis of the 10 elements of the AMP, see Chapter XI.S8 ‘Coatings Program’ with “Plant- specific aging management program is to be evaluated.” The aging effect to be managed is loss of material of the carbon steel tank. The program described is management of the degradation of the coating. Degradation of the coating will not result in a loss of the component intended function of the tank. Different plants use a variety of activities or programs to monitor for loss of material of the carbon steel tank, not degradation of the coating. Due to this variety, the industry proposes that the aging management program be a plant- specific aging management program. The condition 

not directly afffunction. Coatunder the Maishown in the crecommended Evaluation,” a to be evaluateevaluation is saboveground The GALL repaddress this ccoating degradmechanism of systems.
April 2001 B.2.6-65 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H1-2 H1.1.2 Delete the entries in the Reference, Aging Management Program, and Evaluation and Technical Basis columns and replace with the following: Leave the Reference column blank Insert “Plant-specific aging management program is to be evaluated“ in the Aging Management Program column. Insert Plant-specific aging management program is to be evaluated” in the Evaluation and Technical Basis column. The program described is not an industry standard practice at nuclear plants. Various activities are employed by different utilities that are not encompassed within the description of this program. The industry proposes that plant-specific aging management programs be evaluated for managing this aging effect. The AMP “Bur

Surveillance” (1801, Vol. 2) mburied carbon the Buried PipSurveillance Astandards) is nindustry standacceptable methe AMP “BuriSurveillance” (1801, Vol. 2), Piping and Ta(XI.M34, NURwhich inspects frequency for tpiping consideexperience thacrediting the inis dug up for afrequency and experience coplant specific r

The GALL repaddress this c
NUREG-1739 B.2.6-66 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H1-3 H1.4.1 Should “ASTM D 270” be “ASTM D 4057.” This ASTM Standard was not in the 1996 through 2000 editions of the ASTM Standards. ASTM D 4057 has the same title. It may have replaced ASTM D 270. The AMP “Fue

(XI.M30, NURmanages the ainternal surfacdiesel fuel oil sASTM D 270 wD 4057-95(20

for Manual Saand Petroleum The GALL repaddress this c

G-VII H1-4 H1.4.1 (1) Replace: “Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by periodic cleaning/draining tanks and by verifying the quality of new oil before its introduction into the storage tanks.” With: “Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by verifying the quality of stored fuel oil and new fuel oil before its introduction.” (2) Delete the following sentences from the Aging Management Program column: “However, corrosion may occur at locations where contaminants may accumulate, such as tank bottom, and verification of the effectiveness of the program should ensure that Fuel oil chemistry alone is sufficient to manage aging the fuel oil storage tanks. Proper monitoring and maintenance of the fuel oil quality will preclude the accumulation of contaminants that could lead to corrosion. The AMP “Fue

(XI.M30, NURmanages the ainternal surfacdiesel fuel oil s(1) The AMP pstates “Exposucontaminants, microbiologicaminimized by pcleaning of tancleaning and dremoval of seddraining of wabottom of a tathe amount of of contact time(2) The AMP pstates that corlocations in whaccumulate, sAccordingly, thverification of 
April 2001 B.2.6-67 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H1-4 (cont.) significant degradation is not occurring and the component intended function will be maintained during he extended period of operation. An acceptable verification program consists of a one-time thickness measurement of the tank bottom surface.” the program to 

significant degoccurring and intended functmaintained duperiod of operthickness meaacceptable meeffectiveness The GALL repaddress this c

G-VII H1-5 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of carbon steel components in this section. It is not clear that the external surfaces of carbon steel components are addressed in Section VII I of the GALL. See NRC disp

comment G-VTable B.2.6.
NUREG-1739 B.2.6-68 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H1-6 H1.4.1 Delete entry for Biofouling. Buildup of Deposit/Biofouling is listed as an Aging Effect/Mechanism for DFO Tank Internal Surfaces. The only passive intended function for the DFO Tank in the Diesel Fuel Oil System is the pressure boundary function. Buildup of Deposit/Biofouling does not affect the Tank’s ability to accomplish this intended function, so this Effect/Mechanism should not be considered. Biofouling affe

performance aintegrity. Flow considered an covered under basis and showithin the scopHowever, biofomaterial, whicboundary and requires aging The GALL repfollows to add1. For all pipinline items for bto biofouling w2. For all pipinloss of materiawas included amechanism focomponents. 3. The managXI.M20 “OpenSystem” was rreference to fl
April 2001 B.2.6-69 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-1 H2.1.1, H2.1.2 Delete ASME OM S/G Part 2 from the References column. ASME OM S/G Part 2 provides performance and functional testing requirements that verifies the active functions of a system. The parameters monitored by this OM do not detect loss of material of the system components prior to a loss of the component function. Chemistry alone is sufficient in managing loss of material. This is demonstrated by the two industry events listed in the operating experience of the program description. One of those events was the loss of an active component function, not a passive function. The AMP “Clo

Water” (XI.M22) AMP relies measures to mmaintaining inperforming suinspection basof EPRI-TR-10cooling water These measuCCCW systemserviced by thperforming theThe requiremefunctional testPart 2 was de“Closed-Cycle (XI.M21, NURThe GALL repaddress this c
NUREG-1739 B.2.6-70 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-2 H2.1.1, H2.1.2 Delete the following in the Aging Management Program column: “, and performance and functional testing in accordance with ASME OM Standards and Guides, Part 2 to ensure that the CCCW system or components serviced by the CCCW system are performing their functions acceptably.” ASME OM S/G Part 2 provides performance and functional testing requirements that verifies the active functions of a system. The parameters monitored by this OM do not detect loss of material of the system components prior to a loss of the component function. Chemistry alone is sufficient in managing loss of material. This is demonstrated by the two industry events listed in the operating experience of the program description. One of those events was the loss of an active component function, not a passive function. The AMP “Clo

Water” (XI.M22) relies on prminimize corroinhibitors and surveillance tebased on the g107396 for clowater (CCCWmeasures will CCCW systemserviced by thperforming theThe requiremefunctional testPart 2 was de“Closed-Cycle (XI.M21, NURThe GALL repaddress this c

G-VII H2-3 H2.1.1, H2.1.2 Need to add general corrosion, pitting corrosion, and crevice corrosion to the Aging Mechanism column for piping and fittings service by open cycle cooling water system. These mechanisms will occur on carbon steel exposed to a raw water environment. Carbon steel p

the diesel gensubsystem in tgenerator systgeneral, pittingcorrosion. The GALL repaddress this c
April 2001 B.2.6-71 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-4 H2.1.1, H2.1.2 Delete “Jacket” from the Region of Interest column. The jacket is a part of the diesel engine that is excluded from a license renewal aging management review. The jacket (as

diesel engine subsystem) is engine that is license renewareview. The jadeleted from cThe GALL repaddress this c

G-VII H2-5 H2.1.1, H2.1.2 (1) Make the following change in the Aging Management Program column for carbon steel susceptible to erosion/corrosion: “However, the system is chemically treated with hydrazine to lower the dissolved oxygen level in order to minimize the corrosion effects. Lowering the oxygen content increases the susceptibility of the carbon steel piping to erosion/corrosion. This susceptibility depends on the flow rate, which is plant specific. Therefore a plant specific AMP is necessary.” Should read as: “However, the system may be chemically treated with hydrazine to lower the dissolved oxygen level in order to minimize the corrosion effects. Lowering the oxygen content increases the susceptibility of the carbon steel piping to erosion/corrosion. This susceptibility depends on the parameters outlined in NSAC 202L-R2. If the system is Just using hydrazine and lowering the oxygen content does not necessarily make erosion/corrosion a concern in this system. Other factors must be considered as outlined in NSAC 202L-R2. The AMP “Op

Water System1801, Vol. 2) mthe carbon stefor the diesel gwater subsystecycle cooling waging mechanerosion/corrosfrom consideraof the emergesystem in GALcooling water (H2.1.2) was dconsideration it is part of the excluded from aging managefurther evaluatchanged to “NThe GALL repaddress this c
NUREG-1739 B.2.6-72 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-5 (cont.) susceptible to erosion/corrosion, the components should be added to the scope of Flow Accelerated Corrosion program.” (2) Change: “Plant-specific aging management program is to be evaluated.” to read “The scope of the Flow Accelerated Corrosion Program may need to be expanded to include these components if they are found to be susceptible to erosion/corrosion.” (3) Change “Yes, plant specific” to “No” under the Further Evaluation column. G-VII H2-6 H2.1.1, H2.1.1 Vibration induced cracking is not a license renewal aging effect and should be deleted. Vibration induced cracking is expected to occur during the current term and be corrected. This type of aging is random and is corrected as discovered with inspections of similar locations and configurations to ensure the event is location specific or a one-time event. Vibration-indu

failure and subof affected devand swift correnot an aging ismechanism of cracking was dconsideration the emergency system in GALThe GALL repaddress this c
April 2001 B.2.6-73 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-7 H2.5.1 Should “ASTM D 270” be “ASTM D 4057.” This ASTM Standard was not in the 1996 through 2000 editions of the ASTM Standards. ASTM D 4057 has the same title. It may have replaced D 270. The AMP “Fue

(XI.M30, NURmanages the atanks in the disubsystem. Th270 was repla95(2000), StanManual SampPetroleum ProThe GALL repaddress this c

G-VII H2-8 H2.5.1 (1) Replace: “Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by periodic cleaning/draining tanks and by verifying the quality of new oil before its introduction into the storage tanks.” With: “Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by verifying the quality of stored fuel oil and new fuel oil before its introduction.” (2) Delete the following sentences from the Aging Management Program column: “However, corrosion may occur at locations where contaminants may accumulate, such as tank bottom, and verification of the effectiveness of the program should ensure that significant degradation is not Fuel oil chemistry alone is sufficient to manage aging the fuel oil storage tanks. Proper monitoring and maintenance of the fuel oil quality will preclude the accumulation of contaminants that could lead to corrosion. The AMP “Fue

(XI.M30, NURmanages the astorage tanks. (1) The AMP “states, “Exposcontaminants, microbiologicaminimized by pcleaning of tancleaning and dremoval of seddraining of wabottom of a taamount of watcontact time. (2) The AMP pstates that corlocations in whaccumulate, sAccordingly, thverification of the program to 
NUREG-1739 B.2.6-74 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-8 (cont.) occurring and the component intended function will be maintained during he extended period of operation. An acceptable verification program consists of a one-time thickness measurement of the tank bottom surface.” significant deg

occurring and intended functmaintained duperiod of operthickness meaacceptable meeffectiveness The GALL repaddress this c

G-VII H2-9 System Interface Include a reference to Section VII I (Carbon Steel Components) for the external surfaces of carbon steel components in this section. It is not clear that the external surfaces of carbon steel components are addressed in Section VII I of the GALL. See NRC disp

comment G-VTable B.2.6. G-VII H2-10 H2.1.1, H2.1.2 Remove references to MIC. Demineralized water in a closed cycle is not subject to MIC. Carbon steel p

the diesel engsubsystem (secooling water chemically trea<90°C (194°F) to general, pittcorrosion. Micinfluenced cordeleted, as an because demiclosed-cycle is The GALL repaddress this c
April 2001 B.2.6-75 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-11 H2.1.1, H2.1.2 Delete entry for Biofouling. The only passive intended function for the components in question is the pressure boundary function. Buildup of Deposit/Biofouling does not affect the components’ ability to accomplish this intended function, so this Effect/Mechanism should not be considered. Biofouling affe

performance aintegrity. Flow considered an covered under basis and showithin the scopHowever, biofomaterial, whicboundary and requires aging The GALL repfollows to add1. For all pipinother than heaitems for buildbiofouling wer2. For all pipinloss of materiawas included amechanism focomponents. 3. The aging mXI.M20 “OpenSystem” was rreference to fl
NUREG-1739 B.2.6-76 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-12 H2.1.1, H2.1.2 Delete entry for Erosion/Corrosion. There is no operating experience to justify inclusion of this mechanism. Also, Hydrazine is not typically used in Diesel cooling water systems. The AMP “Op

Water System1801, Vol. 2) mthe carbon stefor the diesel gwater subsystecycle cooling waging mechanerosion/corrosfrom consideraof the emergesystem in GALcooling water (H2.1.2) was dconsideration it is part of the excluded from aging manageThe GALL repaddress this c
April 2001 B.2.6-77 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-13 H2.1.1, H2.1.2 Delete entry for Vibration Induced Cracking. There is no operating experience to justify inclusion of this mechanism. Why is this diesel subsystem susceptible to vibration but no others are? Excessive vibration is a design or maintenance issue, not an aging mechanism. Vibration-indu

failure and subof affected devand swift correnot an aging ismechanism of cracking was dconsideration the emergency system in GALcooling water (H2.1.2) was dconsideration it is part of the excluded from aging manageThe GALL repaddress this c

G-VII H2-14 H2.5.1 “Dip” Tank should be “Drip” Tank. There is no such thing as a “Dip” Tank. The carbon st

comprise part fuel oil subsyschanged to drtypo. The GALL repaddress this c
NUREG-1739 B.2.6-78 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII H2-15 H2.5.2 Delete entry for Fuel Oil environment. Loss of Material is listed as an applicable Aging Effect due to the Aging Mechanisms Crevice Corrosion, Pitting, Galvanic Corrosion, and General Corrosion for the Diesel Fuel Oil Strainer. These corrosion mechanisms should only be considered plausible in fuel oil systems where there is a potential for water to pool or separate (tanks, receivers, stagnant piping, etc. (BAW-2270). The fuel oil strainer is not such a location, therefore, these mechanisms should not be considered. This position was accepted in the Oconee SER. The fuel oil str

environment wpotential for wseparate. Corrmechanism shconsidered. ThThe GALL repaddress this c
April 2001 B.2.6-79 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII I-1 I.1.1 Revise Structure and Component “Carbon Steel Components (PWR’s) to read “Carbon Steel Components and Closure Bolting (PWR’s). Bolting is not a component; as such it should not be called out separately in other sections in chapter VII. Chapter XI.M5, “Boric Acid Corrosion” applies. There is no need to distinguish bolting from other pressure boundary external surfaces relative to boric acid corrosion. Bolting is an in

fittings and miitems, pumps, exchangers in spray system. to be a system individual engsystem becauidentified and small componcould be missa broader cateCS Componendegradation of components, ibolting. In addtreats individucomponent anof individual boThe GALL repaddress this c
NUREG-1739 B.2.6-80 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII I-2 I.1.1 Delete reference to ASME section XI in program description for BAC. Implementation of the Boric Acid Corrosion Program at the sites has nothing to do with ASME Section XI. This program is performed independent of Section XI for the identification of boric acid corrosion. Most utilities perform this inspection at the start of the outage to identify problems so that they may be repaired while off-line. Leakage identified during the performance of pressure tests and hydrostatic tests are handled per the ASME Code requirements. NRC GL 88-05 

alone program carbon steel scomponents foacid leakage aInservice inspleakage identiperformance ohydrostatic tesASME Code aindependent oCorrosion” (XIVol. 2) and we

The GALL rep

address this c

G-VII I-3 I.1.1 Atmospheric corrosion is only

applicable to carbon steelcomponents associated withportions of systems operating below212°F.

Since moisture is necessary forgeneral, pitting and any other formsof atmospheric corrosion, theexternal surfaces of carbon steelcomponents, which operate above212°F, are not susceptible to loss ofmaterial due to corrosion.

Several CS coAuxiliary Systetemperatures are therefore scorrosion. Beccorrosion is noenvironment, tdeleted and recorrosion, whienvironment.The GALL repaddress this c
April 2001 B.2.6-81 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII I-4 I.1.1 Delete reference to XI.S8, “Coating Program” under Aging Management Program Column for atmospheric corrosion. Plant specific review should be performed. The use of coatings is a preventive measure to minimize or preclude the loss of material due to corrosion. Loss or degradation of coatings does not result in loss of material, and thus is not considered an aging effect. Programs credited for monitoring loss of material typically constitute periodic visual inspections of component external surfaces for signs of corrosion or loss of material. Since programs credited vary between plant sites, a plant specific review should be performed. The external s

PWR CS comto air, moistureresulting in losby general cor“atmospheric creplaced with A plant-specifiprogram needthese conditioAMP “Protectiand MaintenanNUREG-1801Because the cdoes not direcfunction, coatideleted as an concern for aushown in the crecommended Evaluation,” a to be evaluateevaluation is sThe GALL repaddress this c
NUREG-1739 B.2.6-82 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII I-5 I.2.1 (1) Delete “Air, Moisture, Humidity and Leaking Fluid” under Environment Column for Closure Bolting. Replace with “Air, Leaking Chemically treated Borated Water.” (2) Delete “Atmospheric Corrosion” under Aging Mechanism column and replace with “Boric Acid Corrosion.” (3) Replace information in References column, Aging Management Program column and Evaluation and Technical Basis column with that provided in I.1.1 for Boric Acid Corrosion. Most carbon or low alloy steel bolting is in a dry environment and coated with a lubricant, thus general corrosion of bolting has not been a major concern in the industry. Corrosion of fasteners has only been a concern where leakage of a joint occurs, specifically, when exposed to aggressive chemical attack such as that resulting from borated water leaks. Aging effect requiring management should be loss of mechanical closure integrity due to aggressive chemical attack (boric acid corrosion). (1)Closure bol

or high-tempesystems can bto “Air, MoistuLeaking Fluid” general term “used to also ewater found in (2) Because ais not applicabthe term has breplaced with which is applicenvironment. (the above-mehigh-pressure BWR or PWR susceptible to resulting in losAMP “Bolting NUREG-1801all bolting withrenewal manaThe GALL repaddress this cpart (2).
April 2001 B.2.6-83 NUREG-1739 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII I-6 I.2.1 Delete Aging Effect/Mechanism “Loss of Pre-load due to Stress Relaxation.” (Note: Reference column and AMP Column incorrect list Item H.2.1 instead of I.2.1.) Loss of pre-load of mechanical closures can occur due to settling of mating surfaces, relaxation after cyclic loading, gasket creep, and loss of gasket compression due to differential thermal expansion. These effects are the same as that of a degraded gasket; that is, the potential for leakage of internal fluid at the mechanical joint. Since the ASME code does not consider gaskets, packing, seals, and O-rings to perform a pressure retaining function, these components are typically not considered to support an intended function and not within the scope of license renewal. Thus, with the exception of Class 1 components and those cases where a gasket or seal is utilized to provide a radiological barrier, the aging mechanisms associated with loss of pre-load, described above are not considered to require management. Class 1 components credit the ISI Inspection Program to address loss of pre-load due to stress relaxation. Loss of preloa

leakage and wpart of the boltThe GALL repaddress this closs of preload (Errors in the columns were 1801, Vol. 2.)
NUREG-1739 B.2.6-84 April 2001 Table B.2.6: Disposition of NEI Comments on Chapter VII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VII I-7 I.2.1 Delete Aging Effect/Mechanism “Crack Initiation/Growth” due to Cyclic loading, Stress Corrosion Cracking. (Note: Reference column and AMP Column incorrect list Item H.2.1 instead of I.2.1.) Although there have been a few instances of cracking of bolting in the industry due to SCC, these have been attributed to high yield stress materials and contaminants, such as the use of lubricants containing MoS2. For quenched and tempered low alloy steels (e.g., SA193 Grade B7) used for closure bolting material, susceptibility to SCC is controlled by yield strength. Additionally, operating experience and existing data indicate that SCC failure should not be a significant issue for the bolting materials of SA193 Grade B7. Closure bolting 

high-temperatsystems expohumidity and lsusceptible to mechanisms ostress corrosioexperience shGL 91-17) caufailures. The bGrade B7 can 175 ksi and fareported with YIn Section II of specification fobolting only giv105, but no mCrack initiation result in leakafailure is due tThe GALL repaddress this c
DRAFT-March 1, 2001 B.2.6-85 NUREG-1739 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.7

DISPOSITION OF NEI COMMENTS

ON CHAPTER VIII OF GALL REPORT
B.2.7-ii

This Page Intentionally Left Blank
April 2001 B.2.7-1 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII-1 General comment on System Interface Include a reference to Section VIII H (Carbon Steel Components) for the external surfaces of piping in each specific section’s System Interface paragraph. The external surfaces of piping etc. is included in the scope of Carbon Steel Components (VIII H). The link between Carbon Steel Components and the individual sections is not clearly established in the System Interface sections of the individual sections. The external s

included in the structures and Section H of Cbetween CS cindividual sectrevising the Gthe following sStructures and Sections A to “Aging managdegradation of carbon steel cincluded in SeVIII.” (Similar cmade in ChapThe GALL repaddress this c
NUREG-1739 B.2.7-2 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII A-1 A.1.1, A.1.2, A.2.1 Need to add the aging effect loss of material due to general, crevice, and pitting corrosion for carbon steel piping, fittings, and valves that is managed by Water Chemistry, with the reference being EPRI TR- 102134, Revision 3 or later. Carbon steel components are susceptible to this aging effect in this environment. Water Chemistry will manage the aging effect. Carbon steel p

valves are susmechanisms ocrevice corrosenvironment. Tmechanisms wGALL report fothe Steam Turincluding two ageneral, pitting corrosion for pfor valve bodiethese new line chemistry auginspection (XINUREG-1801change was mextraction systand valves; cocoolers/condeside); and steablowdown sysblowdown heawater side). Oneeded to verwater chemistthe absence oaging effect is are evaluated appropriate coThe GALL repaddress this c
April 2001 B.2.7-3 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII A-2 System Interface Include a reference to Section VIII H (Carbon Steel Components) for the external surfaces of carbon steel components in this section. It is not clear that the external surfaces of carbon steel components are addressed in Section VIII H of the GALL. See NRC disp

comment G-VAppendix B, T

G-VIII B1-1 B1.1.1, B1.1.2, B1.2.1 Add general corrosion to the Aging Mechanism column. General corrosion could occur in this environment. General corro

mechanism of environment w300°C becausrelatively dry aenough moistucorrosion. The GALL repaddress this c

G-VIII B1-2 System Interface Include a reference to Section VIII H (Carbon Steel Components) for the external surfaces of carbon steel components in this section. It is not clear that the external surfaces of carbon steel components are addressed in Section VIII H of the GALL. See NRC disp

comment G-VAppendix B, T
NUREG-1739 B.2.7-4 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII B2-1 B2.2.1 The FAC program described in Section XI is not usually applied to valve bodies. A note stating that the applicant’s FAC program must choose bounding locations for the measurement of wall thinning in valves may need to be placed here. FAC programs generally monitor thinning in pipe locations, since valve bodies are usually much thicker than pipe walls. Wall thinning i

concern becauthe valve bodiaccelerated coEPRI program evaluates valvsusceptibility. XI-M6 (XI-M17 Vol. 2) explainFAC program bounding locameasurement than piping. AGALL report wvalve bodies arequires boundThe GALL repaddress this c
April 2001 B.2.7-5 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII B2-2 All Items Thermal Cycling Induced Fatigue is not listed as an Aging Effect. This is unusual in that most other sections list this aging effect, with the resultant AMP of a TLAA. Consistency is the issue here. Either thermal cycling induced fatigue should be added here or stricken from the other sections. A TLAA is appropriate since this piping is usually design as Non-Class 1 with an assumed number of temperature cycles for 40-year life. Thermal-cycle 

aging mechanexperienced bcomponents spiping and fittiThis aging mefor non-Class were analyzed (< 7000 cyclesThis is a TLAA the period of ea result of this were added in GALL report fodamage: 1) pimain steam sy2) piping and ffeedwater sys3) piping and ffeedwater sysThe GALL repaddress this c
NUREG-1739 B.2.7-6 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII D1-1 D1.1.1 General, Crevice, and Pitting Corrosion, delete one-time inspections from the Aging Management Program column. Revise the Further Evaluation Column to state ‘No’. Operating experience alone has shown the chemistry control program has been effective in controlling corrosion of the Feedwater Systems in plants. Feedwater chemistry parameters are well monitored and well controlled in plants. Routine maintenance on equipment has not shown any concerns over loss of material in feedwater systems. General, pittin

corrosion are that may be expiping and fittiSystems in PWexample, steafeedwater nozheat-affected secondary watpitting (IN 90-0The appropriachemistry auginspection (XINUREG-1801inspection is neffectiveness control and coan aging effecdetected, the rto determine tcorrective actiThe GALL repaddress this c

G-VIII D1-2 D1.2.1 The FAC program described in Section XI is not usually applied to valve bodies. A note stating that the applicant’s FAC program must choose bounding locations for the measurement of wall thinning in valves may need to be placed here. FAC programs generally monitor thinning in pipe locations, since valve bodies are usually much thicker than pipe walls. See NRC disp

comment G-VAppendix B, T
April 2001 B.2.7-7 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII D1-3 D1.2.1 General, Crevice, and Pitting Corrosion, delete one-time inspections from the Aging Management Program column. Revise the Further Evaluation Column to state ‘No’. Operating experience alone has shown the chemistry control program has been effective in controlling corrosion of the Feedwater Systems in plants. Feedwater chemistry parameters are well monitored and well controlled in plants. Routine maintenance on equipment has not shown any concerns over loss of material in feedwater systems. See NRC disp

comment G-VAppendix B, T.

G-VIII D1-4 D1.3.1, D1.3.2 The Flow Accelerated Corrosion

should not be the AMP for WallThinning. If wall thinning is aconcern, thickness measurementsof the pump casing should be taken.

FAC programs generally monitorthinning in pipe locations, sincevalve bodies are usually muchthicker than pipe walls.

Wall thinning othe steam turbdriven feedwamonitored by tmeasurementinternals have any thinning onot significantperformance. program detecperformance. deleted from tfor the PWR fe(D1.3.1), cond(E.3.1), and thgenerator blowThe GALL repaddress this c
NUREG-1739 B.2.7-8 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII D1-5 D1.1.1, D1.2.1, D1.3.1, D1.3.2 Entries combine General, Crevice, and Pitting Corrosion, but discussion under Aging Management Program considers only Crevice and Pitting Corrosion. Does one time inspection apply to General Corrosion as well? Should the entries be separated? Consistency General, pittin

corrosion aginexperienced band fittings in line, valves, ansuction and diassociated witOne-time inspNUREG-1801detection of loby general corchemistry progGALL report wgeneral corrosmechanism focomponents. The GALL repaddress this c

G-VIII D2-1 D2.1.1, D2.2.1, D2.3.1, D2.3.2 Does Flow Accelerated Corrosion also include the Erosion and/or Erosion-Corrosion aging mechanisms? The FAC program should not be credited for the other mechanisms. FAC is an applicable aging mechanism for the type of fluid in the components evaluated in this section. Other loss of material mechanisms may be applicable as well, and the FAC program described in the generic program does not include the other mechanisms. Flow accelera

an applicable the type of fluisystem compoin the GALL reerosion/corrosaging mechanerosion/corrosErosion is a mthat requires a evaluation in tThe GALL repaddress this c
April 2001 B.2.7-9 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII E-1 E.1.1, E.2.1, E.3.1 Under “Aging Effect” should also include loss of material. The “Aging Mechanisms” should be general, crevice and pitting corrosion. Under “References” include EPRI TR- 102134 and under “AMP” include description of water chemistry program and the following words “Alternatively, program effectiveness may be demonstrated based on industry or plant specific information.” “Evaluation and Technical Basis” should refer to Chapter XI.M11 “Water Chemistry.” Carbon steel exposed to raw water is susceptible to loss of material due to general, crevice and pitting corrosion. Industry or plant specific information may be utilized to demonstrate that preventive measures e.g. chemistry control with addition of corrosion inhibitors, are effective in preventing the aging effect from occurring. See NRC disp

comment G-VAppendix B, T

G-VIII E-2 E.4.1– E.4.4 (serviced by open-cycle cooling water) Under “Aging Mechanism” should also include crevice and pitting corrosion. Carbon and stainless steel exposed to raw water are susceptible to loss of material due to crevice and pitting corrosion. The corrosion mechanisms may be minimized by chemistry controls. The carbon an

tubes, tubesheand shells of tand condensewater will be spitting, and creaging mechanof material wecondensate costeam generaexchangers, afeedwater beaChapter VIII oThe GALL repaddress this c
NUREG-1739 B.2.7-10 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII E-3 E.4.1– E.4.4 (serviced by open-cycle cooling water) Under “AMP” For Treated Water Side the program relies on preventive measures to minimize corrosion by monitoring and controlling chemistry based on the guidelines of EPRI-TR-102134 for secondary water chemistry in PWR’s. Under “Evaluation and Technical Basis,” add, “For evaluation and technical basis of the 10 elements of the AMP, see Chapter XI.M11, Water Chemistry.” To provide AMP for secondary side of heat exchanger. The carbon an

tubes, tubesheand shells of tand condensewater will be s(carbon steel ocrevice corrosrelies on prevebased on the gTR-102134 fochemistry in P103515 for reain BWRs, the revised to add NUREG-1801Cooling Water water side, anNUREG-1801Chemistry, for of the heat excchange in the made for the sblowdown sysThe GALL repaddress this c
April 2001 B.2.7-11 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII E-5 E.4.1–E.4.4 (serviced by closed-cycle cooling water) Under “AMP” Delete requirement for performance of functional tests per ASME OM S/G Part 2 and add “If the adequacy of the chemistry control programs cannot be confirmed over the operating history of the plant or if any unexplained downward trend in heat exchanger performance is identified that cannot be remedied by maintenance of an open-cycle system, it may be necessary to selectively perform functional testing of the affected heat exchangers.” NRC Generic Letter 89-13. The aging ma

relies on preveminimize corroinhibitors and chemistry moninspection and evaluations baof EPRI-TR-10cooling water inspections fothan chemistrycollection and the potential pof structural inheat transfer cand/or depositensure that thcomponents ssystem are peacceptably. Thperformance oASME OM S/G in the AMP “CWater” (XI.M2Vol. 2). The GALL repaddress this c
NUREG-1739 B.2.7-12 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII E-6 E.4.1–E.4.4 (serviced by closed-cycle cooling water) Under “AMP” For Treated Water Side the program relies on preventive measures to minimize corrosion by monitoring and controlling chemistry based on the guidelines of EPRI-TR-102134 for secondary water chemistry in PWR’s. Under “Evaluation and Technical Basis,” add, “For evaluation and technical basis of the 10 elements of the AMP, see Chapter XI.M11, Water Chemistry.” To provide AMP for secondary side of heat exchanger. See NRC disp

comment G-VB, Table B.2.7

G-VIII E-7 E.5.1 A separate line item should be created for SS Condensate Storage Tanks. The aging effects would be pitting and crevice corrosion. The AMA would be a plant specific activity based on plant design and management philosophy. Hence further evaluation is warranted. Existing line item is for stainless steel and carbon steel (-coated) tanks. However, the aging mechanisms exclude general corrosion, which would be applicable to carbon steel only. Stainless stee

tanks exposed environment apitting and cresuch conditioncondensate stsubject to genBecause tanks different matedifferent aging line item has bcondensate st“Water Chemi“One-time InsXI.M32 in NURthe appropriatchange was mfeedwater syscondensate sttank in the GAThe GALL repaddress this c
April 2001 B.2.7-13 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII E-8 E.5.1 Under “AMP” add the following: “Alternatively, program effectiveness may be demonstrated based on industry or plant specific information.” Industry or plant specific information may be utilized to demonstrate that preventive measures e.g. chemistry control with addition of corrosion inhibitors, are effective in preventing the aging effect from occurring. The suggested 

storage tanks water environmchemistry auginspection (XINUREG-1801inspection is neffectiveness control and coan aging effecdetected, the rto determine tcorrective actithe option of calternative plaThe GALL repaddress this c

G-VIII E-9 E.5.1 (tank aboveground, external surface) Under “AMP” and “Evaluation and Technical Basis,” substitute with “Plant Specific program.” External corrosion of above ground carbon steel tanks should be addressed on a plant specific basis. Refer to Chapter XI.M7 comments. “Above Groun

(XI.M29 in NUprovides one athe external coground carbon applicant has conducting an specific prograThe GALL repaddress this c

G-VIII E-10 E.5.1 (Tank buried, external surface) Under “AMP” and “Evaluation and Technical Basis,” substitute with “Plant Specific program.” Nuclear industry experience dictates external corrosion of buried components should be addressed on a plant specific basis. Refer to Chapter XI.M8 comments. See NRC disp

comment G-XAppendix B, T
NUREG-1739 B.2.7-14 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII E-11 E.6.1 Under “Aging Mechanism” add general corrosion. Carbon steel exposed to treated water is susceptible to general corrosion. The carbon st

as piping and and strainer ascondensate clexposed to treof their suscepcorrosion, this was included. The GALL represult of this c

G-VIII E-12 E.4.1-E.4.4 Combine entries for General Corrosion. General Corrosion is listed as an aging mechanism in two entries for these items. This is an unnecessary duplication and is confusing because different programs are credited. General corro

mechanism of condensate coserviced by boclosed-cycle cline entries webecause the Adifferent for CC(XI.M20 and X1801, Vol. 2). revised by addthat referenceaugmented by (XI.M2 and XIVol. 2) for the the heat exchaThe GALL repaddress this c

G-VIII E-13 E.5.1 Clarify meaning of “Corrosion.” Mechanism is referred to ambiguously. In remainder of Report, corrosion mechanisms are delineated as General, Crevice, Pitting, etc. The term corro

specifically staand crevice coThe GALL repaddress this c
April 2001 B.2.7-15 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII F-1 F.1.1, F.1.2, F.2.1, F.3.1 Aging Management Program (AMP) column: Add the following at the end of the paragraph: “Alternatively, demonstration of an effective Chemistry Control Program by documented plant and or industry operating/maintenance experience also constitute acceptable verification.” Crevice and pitting corrosion occur most frequently in areas of low flow such as joints and connections or points of contact between metals and non-metals. These conditions would typically be found in component internals and flanged connections (such as those associated with valves and pumps), and thus, would be identified during routine or corrective maintenance where disassembly was performed. It should be noted that ASME XI requires a visual examination to determine the condition of Class 1 valve and pump internals at least once each Inspection Interval. When significant corrosion or failed parts are identified on safety related components, the utility corrective action programs require the identification of root cause and in many cases standard metallurgical analyses are employed to define the underlying aging mechanisms. Lack of evidence of crevice or pitting corrosion-related problems in these plant documents provides verification of an effective chemistry control program. General, pittin

corrosion occucomponents sgenerator blowand fittings ancasing exposetreated water. Section XI reqexamination to condition of Cinternals at leainspection interelevant to GAdiscussing Nocomponents. Levidence of crcorrosion does of the effect of The applicant conducting an specific prograThe GALL repa result of this 
NUREG-1739 B.2.7-16 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII F-2 F.4.1 through F.4.4 Eliminate Buildup of deposit due Biofouling as an Aging mechanism for all heat exchanger components except heat exchanger tubes. Buildup of deposit due to biofouling is an aging effect which impacts heat transfer intended function, and is thus documented only for heat exchanger tubes. Buildup of deposit does not affect pressure boundary, except for MIC, which is addressed under loss of material. Biofouling affe

performance aintegrity. Flow considered an covered under basis and showithin the scopHowever, biofomaterial, whicboundary and requires aging This position dLicense Renewstates that the for heat exchascope of licenbiofouling of hrequire aging The GALL repfollows to add1. Delete all hecomponents ethe material codeposits due t2. For all pipinother than heaall line items fodue to biofouli3. For all pipinincluding heat material due to included as an pressure boun
April 2001 B.2.7-17 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII F-2 (cont.) 4. The aging m

XI.M20 “OpenSystem” was rreference to fl

G-VIII F-3 F.4.1-F.4.4 Remove reference to Stainless Steel in entry for General Corrosion. Stainless Steel is not susceptible to General Corrosion. Blowdown hea

by closed-cyclconsist of SS tCS channel heThe SS tubes general corrosThe GALL repaddress this cthat only CS csubject to this that both SS aare subject to corrosion agin
NUREG-1739 B.2.7-18 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII G-1 G.1.1 The Flow Accelerated Corrosion is not valid Aging Mechanism for Auxiliary Feedwater. Delete this entry. Flow Accelerated Corrosion (FAC) is listed as an Aging Mechanism for the AFW Piping. FAC of this piping is not plausible because the temperature of the water is near ambient temperature and the system is typically in standby. The AFW pumps take suction from a Condensate Storage Tank that is not heated. Industry experience indicates that FAC is not plausible for cold water systems with good chemistry control and infrequent operation. Therefore, FAC is not plausible for this piping and this entry should be removed. This position was accepted in the CCNPP SER. The flow acce

(FAC) of auxillines of recircugenerators witconcern. In plagenerators (WD4, D5, and E portion of the diverted to the line via a prehduring normal a portion of thline between sthe bypass line experiences Fportion of the ahas experiencthinning becauReference: NRFlow-Induced Feedwater Pipconcern for AFin plants with pgenerators. The GALL repa result of this 
April 2001 B.2.7-19 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII G-2 G.1.1, G.1.2 Revise Environment from ‘<90oC ...Steam Generator’ to be just ‘Treated Water’. The temperatures as stated are confusing. The temperatu

convey a senswater’s generathe preheated temperatures, temperatures environment. Tnow denoted swater. The GALL repaddress this c

G-VIII G-4 G.1.1, G.1.2 Delete entry for Biofouling. The only passive intended function for the components in question is the pressure boundary function. Buildup of Deposit/Biofouling does not affect the components’ ability to accomplish this intended function, so this Effect/Mechanism should not be considered. See NRC disp

comment for GAppendix B, T

G-VIII G-5 G.4.1 Clarify meaning of “Corrosion.” Mechanism is referred to ambiguously. In remainder of Report, corrosion mechanisms are delineated as General, Crevice, Pitting, etc. See NRC disp

comment for GAppendix B, T
NUREG-1739 B.2.7-20 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII G-6 G.5.1-G.5.3 Remove reference to Stainless Steel in entry for General Corrosion. Stainless Steel is not susceptible to General Corrosion. AFW bearing 

turbine pumps closed-cycle awater and are water, open wenvironments. or tubesheets general corrosThe GALL repaddress this cthat only CS csubject to this that both SS aare subject to corrosion agin
April 2001 B.2.7-21 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII G-7 G.1.1, G.1.2 (1) Entry for piping combines General, Crevice, and Pitting Corrosion, but discussion under Aging Management Program considers only Crevice and Pitting Corrosion. (2) Does one time inspection apply to General Corrosion as well? (3) Should the entries be separated? (4) Also, later entries for pumps and valves do not include General Corrosion. (5) Why is General Corrosion not an AERM (aging effect requiring management) for these entries given same materials and environment? Consistency (1 and 2) The 

chemistry auginspection (XINUREG-1801to address gencrevice corrosinspection appcorrosion as w(3) Since the apitting, and creidentically “losthree aging mhandled in the the same AMP augmented by (4 and 5) AFW valve bodies acarbon steel ageneral, pittingcorrosion. The and valves wegeneral corrosaging effect. The GALL repaddress this c4, and 5.
NUREG-1739 B.2.7-22 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII H-1 H.1.1 Revise Structure and Component “Carbon Steel Components (PWR’s) to read “Carbon Steel Components and Closure Bolting (PWR’s). Bolting is not a component; as such it should not be called out separately in other sections in chapter VIII. Chapter XI.M5, “Boric Acid Corrosion” applies. There is no need to distinguish bolting from other pressure boundary external surfaces relative to boric acid corrosion. GALL VIII, Sec

Steel Componfor degradatiostructures and including closuSection XI treaas a componeinspection of iline item for BAsurfaces refercarbon steel ccontain boratecomponents ccoolant are adsections of ChThe GALL repaddress this c
April 2001 B.2.7-23 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII H-2 H.1.1 Delete reference to ASME section XI in program description for BAC. Implementation of the Boric Acid Corrosion Program at the sites has nothing to do with ASME Section XI. This program is performed independent of Section XI for the identification of boric acid corrosion. Most utilities perform this inspection at the start of the outage to identify problems so that they may be repaired while off-line. Leakage identified during the performance of pressure tests and hydrostatic tests are handled per the ASME Code requirements. The Boric Acid 

Program is baLetter 88-05, wprogram to mocoolant boundleakage. ASMindependent ocorrosion progrequirement to during the pertests and hydrconsiders the inspections to boric acid corrhas removed Section XI from The GALL repaddress this c

G-VIII H-3 H.1.1 Atmospheric corrosion is only applicable to carbon steel components associated with portions of systems operating below 212oF. Since moisture is necessary for general, pitting and any other forms of atmospheric corrosion, the external surfaces of carbon steel components, which operate above 212oF, are not susceptible to loss of material due to corrosion. Several carbo

the Steam and System are extemperatures are therefore scorrosion. Corare delineated report as geneatmospheric), The GALL repaddress this c
NUREG-1739 B.2.7-24 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII H-4 H.1.1 Delete reference to XI.S8, “Coating Program” under Aging Management Program Column for atmospheric corrosion. Plant specific review should be performed. The use of coatings is a preventive measure to minimize or preclude the loss of material due to corrosion. Loss or degradation of coatings does not result in loss of material, and thus is not considered an aging effect. Programs credited for monitoring loss of material typically constitute periodic visual inspections of component external surfaces for signs of corrosion or loss of material. As programs credited vary between plant sites, a plant specific review should be performed. The external s

PWR carbon ssubjected to ahumidity resulcaused by genterm “atmosphreplaced with be consistent Chapters V anaging manageto be evaluateReference to ACoating MonitMaintenance Premoved. The GALL repaddress this c
April 2001 B.2.7-25 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII H-5 H.2.1 (1) Delete “Air, Moisture, Humidity and Leaking Fluid” under Environment Column for Closure Bolting. Replace with “Air, Leaking Chemically treated Borated Water.” (2) Delete “Atmospheric Corrosion” under Aging Mechanism column and replace with “Boric Acid Corrosion.” Replace information in References column, Aging Management Program column and Evaluation and Technical Basis column with that provided in H.1.1 for Boric Acid Corrosion. Most carbon or low alloy steel bolting is in a dry environment and coated with a lubricant, thus general corrosion of bolting has not been a major concern in the industry. Corrosion of fasteners has only been a concern where leakage of a joint occurs, specifically, when exposed to aggressive chemical attack such as that resulting from borated water leaks. Aging effect requiring management should be loss of mechanical closure integrity due to aggressive chemical attack (boric acid corrosion). (1) Closure bo

or high-tempesystems is expMoisture, HumFluid.” Chemicwater is applic(2) Boric acid closure bolting first line item fCarbon Steel Cbolting also exatmospheric c“atmospheric creplaced with be consistent Chapters V anrepresents botclosure boltingThe GALL repaddress this c
NUREG-1739 B.2.7-26 April 2001 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII H-6 H.2.1 Delete Aging Effect/Mechanism “Loss of Pre-load due to Stress Relaxation.” Loss of pre-load of mechanical closures can occur due to settling of mating surfaces, relaxation after cyclic loading, gasket creep, and loss of gasket compression due to differential thermal expansion. The effects of these mechanisms are the same as that of a degraded gasket; that is, the potential for leakage of internal fluid at the mechanical joint. Since the ASME code does not consider gaskets, packing, seals, and O-rings to perform a pressure retaining function, these components are typically not considered to support an intended function and not within the scope of license renewal. Thus, with the exception of Class 1 components and those cases where a gasket or seal is utilized to provide a radiological barrier, the aging mechanisms associated with loss of pre-load, described above are not considered to require management. Class 1 components credit ISI Inspection to address loss of pre- load due to stress relaxation. See NRC disp

comment for GAppendix B, T
April 2001 B.2.7-27 NUREG-1739 Table B.2.7: Disposition of NEI Comments on Chapter VIII of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-VIII H-7 H.2.1 Delete Aging Effect/Mechanism “Crack Initiation/Growth” due to Cyclic loading, Stress Corrosion Cracking. Although there have been a few instances of cracking of bolting in the industry due to SCC, these have been attributed to high yield stress materials and contaminants, such as the use of lubricants containing MoS2. For quenched and tempered low alloy steels (e.g., SA193 Grade B7) used for closure bolting material, susceptibility to SCC is controlled by yield strength. Additionally, operating experience and existing data indicate that SCC failure should not be a significant issue for the bolting materials of SA193 Grade B7. See dispositio

G-VII I-7 in thiTable B.2.6.
NUREG-1739 B.2.7-28 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.8

DISPOSITION OF NEI COMMENTS

ON CHAPTER X OF GALL REPORT
B.2.8-ii

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April 2001 B.2.8-1 NUREG-1739 Table B.2.8: Disposition of NEI Comments on Chapter X of GALL Report Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

G X-1 B.3.6 GALL X Revise the title of the Chapter to be “Chapter X Programs that Support TLAAs.” The programs identified in this section are not necessarily in support of Option (iii). Cycle counting and EQ are programs that can also be used to confirm design basis assumptions in support of Options (i and ii). See NRC dis

comment S 4Table B.2.13. Options (i) anperformed prextended opefatigue analysintent of cycle is to monitor textended perassure that thexceed its allThe GALL readdress this c

G X.M1-1 B.3.6 GALL X.M1 GALL X.M1 Metal Fatigue of Reactor Coolant Pressure boundary intermingles thermal cycle counting with the addressing of reactor water effects. Delete the information in X.M1 associated with reactor water effects. Specifically: Program Description: Delete the second paragraph and the reference in the third paragraph to environmental effects. Evaluation and Technical basis: Adjust the numbered topics as follows: (2) Preventive Actions: Delete the phrase “and considering the effect of the reactor water environment, as described under program description above.” The thermal cycle count method of managing the existing fatigue design basis has been found acceptable for renewal and can be used by the majority of the industry. When reworded, the attributes in X.M1 can clearly be referenced by renewal applicants beginning near- tem. Addressing reactor water effects is less clear and has been done differently by the initial applicants. Additionally, it is the subject of ongoing industry and NRC efforts (Reference Christopher I. Grimes July 18, 2000 letter, Summary of Meeting with the Nuclear Energy Institute (NEI) to Discuss Fatigue of Metal Components for 60-year Plant The reference 

AMP is as a coutstanding teregarding Apresolution. Thfurther staff rean applicant pAppendix L. Tevaluate envifatigue is by cThe GALL readdress this c
NUREG-1739 B.2.8-2 April 2001 Table B.2.8: Disposition of NEI Comments on Chapter X of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

G X.M1-1 (cont.) (3) In the third sentence, delete “local,” revise “of the plant transient” to “of plant transients” and delete “for each transient.” (4) Detection of Aging Effects: Reword to “not applicable for a preventive management program.” (5) Monitoring and Trending: Reword to “The program should be provided for periodic assessment of actual accumulated cycles versus the design calculation values.” (6) Acceptance Criteria: Delete the phrase “considering environmental fatigue effects.” (7) Corrective Actions: Replace the second sentence with the following, “Acceptable corrective actions may include a more rigorous analysis of the component to demonstrate that the design code limit will not be exceeded, inspection coupled with appropriate flaw tolerance assessment, repair, or replacement of the component. ASME Section XI Appendix L provides methods and criteria for performing these activities.” Delete the last sentence. Operating Experience: In the last sentence, replace the phrase “in selecting the monitored locations” with “by the program.” 3. References: Delete the three references. Add a reference to NUREG-1723, Safety Evaluation Report Related to the License Life, Adams Accession No. ML003733789). Given the current state of awareness on the ways to address reactor water effects, the near-term applicants can not use X.M1 the way it is currently structured. Since the GALL report was designed to create materials that can be referenced by renewal applicants, removing the information associated with reactor water effects from the GALL and maintaining them only in the SRP-LR until a future time better satisfies this objective. Item (3): For fatigue monitoring programs, the actual transient history may be evaluated, not each specific transient. Item (7): Appendix L permits a licensee to demonstrate that a component is acceptable with regard to cumulative fatigue effects by performing a flaw tolerance evaluation of the component as an alternative to meeting the fatigue requirements of ASME Section III. The NRC has reviewed Appendix L and determined that its use is generally acceptable. Licensees should be aware that the ASME Code is considering revisions to Appendix L concerned with flaw aspect ratio and the influence of reactor water environmental effects on both fatigue usage and crack
April 2001 B.2.8-3 NUREG-1739 Table B.2.8: Disposition of NEI Comments on Chapter X of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

G X.M1-1 (Cont.) Renewal of Oconee Nuclear Station Units 1, 2 and 3 where the thermal cycle count method of fatigue management was accepted by the NRC. growth evaluations. G X.S1-1 B.3.6 GALL X.S1 Move this program description to Chapter XI. The activities described in X.S1 constitute an aging management program and do not address a TLAA. See NRC dis

comment S 4Table B.2.13. This merely pan applicant cits TLAA in ac54.21(c)(1)(iiiaddressed in time-dependethe pre-stressstressed concapplicable to operation. The GALL readdress this c
NUREG-1739 B.2.8-4 April 2001 Table B.2.8: Disposition of NEI Comments on Chapter X of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

G X.S1-2 B.3.6 GALL X.S1 Clarify regulatory meaning of the “trend line.” Under Program Description, last sentence in second paragraph begins “The goal would be to keep the trend line above the PLL,” because “if the trend line crosses the PLL, the existing prestress in the containment could go below the MRV soon after the inspection.” If the extension of the trend line crosses the PLL at some point in the future, then the second part of the sentence about not meeting the criteria “soon after the inspection” would not necessarily be true. Therefore, “trend line” needs to be clarified in this case as to whether it means the trend line only including the last data point, or the extension of the existing data trend line. Depending up

the trend line trend line couto 10 years. Tauxiliary verb merits. The trSRP, GALL a50.55a(b)(2)(50.55a(b)(2)(regression linline) reflecting lift-off data. Tpartially correin all cases thtrend line croexisting pre-scontainment MRV soon afwhich will not of 10 CFR 5010 CFR 50.55The GALL readdress this c
APPENDIX B, SECTION B.2.9

DISPOSITION OF NEI COMMENTS

ON CHAPTER XI OF GALL REPORT
B.2.9-ii

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April 2001 B.2.9-1 NUREG-1739 Table B.2.9-1: Disposition of NEI Electrical Comments on Chapter XI of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G2 XI.E1 XI.E1 Paragraph 1 XI.E2 Paragraph 1 In the first and second sentences of paragraph 1, replace “nominal plant” with “plant design.” “Nominal plant environment” is a vague term that does not describe any values normally maintained at a station. “Design environments” are defined at plants and are the values to which actual environments can be compared. The term “nom

environment” does not descvalues normalstation. GALL Chapter E2 were revisecomment by re“nominal plant term “plant demore clearly denvironments 
NUREG-1739 B.2.9-2 April 2001 Table B.2.9-1: Disposition of NEI Electrical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G2 XI.E2 XI.E2 Paragraph 1 XI.E3 Paragraph 1 Add the following sentence: in G2-XI.E2 - after sentence 3 in paragraph 1 in G2-XI.E3 – before the last sentence in paragraph 1 “An adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service condition for the cable.” The term “adverse localized environment” is used in the first paragraph but is not defined. The term “adv

environment” is not defined description. GALL Chapter and E3 were rcomment by infollowing definEPRI TR-1096descriptions: “An adverse lois a condition that is significathe specified sthe cable. An aenvironment is appreciably inaging of a comimmediate advoperability.” Also, EPRI TRin the list of reprogram.
April 2001 B.2.9-3 NUREG-1739 Table B.2.9-1: Disposition of NEI Electrical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G2 XI.E3 XI.E3 Paragraph 1 Replace sentence 2 of paragraph 1 with the following sentence: “When an energized medium- voltage cable is exposed to wet conditions for which it is not designed, water treeing or a decrease in dielectric strength of the conductor insulation could occur. Section XI.E3, Paragraph 1, sentence 2 implies that any medium-voltage cable that is not designed for submergence is subject to water treeing or a decrease in dielectric strength of the conductor insulation. There are levels of moisture exposure lower than total submergence for which a cable could be designed to withstand without being subject to water treeing or a decrease in dielectric strength. Also, the DOE/Sandia Cable AMG states that the growth and propagation of water trees is “somewhat unpredictable” so it is not a sure thing that water treeing will occur even with the “right” conditions. Sentence 2 should instead reflect that when a medium-voltage cable is exposed to wet conditions for which it is not designed it could be subject to water treeing or a decrease in dielectric strength of the conductor insulation. Note that this 

sentence 3 of August 2000 vsentence 2. There are leveexposure lowesubmergence could be desigwithout being treeing or a destrength. Therchange is accincorporated. GALL Chapter revised to add
NUREG-1739 B.2.9-4 April 2001 Table B.2.9-1: Disposition of NEI Electrical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G2 XI.E4 XI.E4 Delete program XI.E3 and reference the Boric Acid Corrosion Program (XI.M5). Section XI.E3, paragraph 1, sentence 2 states: “The program described herein is an augmentation of the Boric Acid Corrosion Program ...” This program as described is part of a plant’s Boric Acid Corrosion Program in that visual inspections of electrical equipment are performed along with the visual inspections of mechanical equipment and structures. Using “augmentation” implies that electrical equipment is not included in a plant’s current Boric Acid Corrosion Program. Since this program is just a part of the Boric Acid Corrosion Program (XI.M5) it is not logical to have pieces of the same program appear in two places in the GALL report. Suggest deleting program XI.E4 in electrical and just referencing program XI.M5 for this aging effect. Note that this 

program XI.E4 version, and nThe Boric Acid (XI.M5 in AuguGALL) has bespecifically inccomponents in AMP XI.M10 i2. The program described in AAugust 2000 vincorporated inis not necessaseparate progthe same agincomponents. GALL Chapter deleted to addThe Boric Acid (XI.M10 in NUnow referencechanges were Volume 1, and 3.6.
April 2001 B.2.9-5 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM1 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel SRP-LR Section 3, Table 3.1-1 shows that aging management activities to address the loss of fracture toughness due to thermal aging embrittlement of Class 1 and Class CS cast austenitic stainless steel (CASS) components in BWR and PWR plants are adequate. The SRP-LR refers to Chapter XI, Section XI.M1, for discussion of the adequacy of the aging management activities. However, when the loss of fracture toughness is due to a combination of thermal aging embrittlement and neutron irradiation embrittlement (reactor vessel internals) are the aging management activities called into question. This discussion is contained in Section XI.M2. The Gall report also contains important findings in this regard. For example, the GALL report states that “The reactor vessel internals receive a visual inspection in accordance with Category B-N-3 of Subsection IWB, ASME Section XI. This inspection is not sufficient to detect the effects of loss of fracture toughness due to thermal aging and neutron irradiation embrittlement of cast austenitic stainless steel (CASS) reactor vessel internals.” The GALL report also states that The license renewal technical issue related to CASS component thermal aging embrittlement is closed with respect to the screening criteria used to determine the potential significance of thermal aging embrittlement for CASS reactor coolant system and reactor vessel internals components. The only remaining issues are related to the adequacy of activities to manage the potential loss of fracture toughness caused by thermal aging embrittlement. Almost all of the ASME Code Section XI inservice inspection activities have been found to be acceptable, with the exception of three items. First, the visual (VT-3) examinations for reactor internals have been found to be inadequate, and supplemental (e.g., VT-1 or enhanced VT-1) examinations are required. This item will be subsumed under the license renewal technical issue concerning VT-1 versus VT-3 examinations. Second, the Examination Category B-J inspections for piping welds have been found to be inadequate, with supplemental volumetric inspections of limiting base metal locations required. This item might be acceptable to the industry, since it is demonstrably likely that the limiting The Aging Ma

(AMPs) relateEmbrittlemenStainless SteAugust 2000 relocated as A1801, Vol. 2) and Neutron EmbrittlemenStainless SteAugust 2000 relocated as A1801, Vol. 2) SAW/SMAW criteria for CAIndustry needcorrelation of growth resistafor thermally ato 40% delta feach section, the following: susceptibility to thermal agbased on casmolybdenum ferrite. In AMP thermal aging CASS) For “pcomponents, accomplished enhanced volplant- or comtolerance evainspection or demonstrate 
NUREG-1739 B.2.9-6 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM1 (cont.) “The reactor coolant system components are inspected in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, Subsection IWB. This inspection is not sufficient to detect the effects of loss of fracture toughness due to thermal aging embrittlement of cast austenitic stainless steel (CASS) components.” The SRP-LR and the GALL report accept the industry screening criteria (i.e., casting method, Mo content, delta ferrite content) for susceptibility of CASS components to thermal aging embrittlement, with one minor exception. The exception concerns the comparison of SAW/SMAW crack growth resistance curves with thermally aged CASS crack growth resistance curves. The industry finds the comparison valid out to 40 % delta ferrite, while the NRC staff will not accept the comparison for delta ferrite greater than 25 %. The NRC staff want flaw evaluation for piping with >25% ferrite to be performed on a case-by-case basis using fracture toughness data provided by the applicant. However, for potentially susceptible components, the industry and the base metal locations can be shown to be within the 0.5-inch zone on either side the welds being examined under the current Examination category B-J procedures. Third, the acceptability of the existing SAW/SMAW flaw acceptance criteria for CASS components has been found to be limited to 25 % delta ferrite. The industry finds that the available data, while sparse, shows good comparison out to delta ferrite of 40 %. The Gall report recognizes that “Cracking is expected to initiate at the surface and should be detectable by ISI.” The GALL report also recognizes that volumetric examination covers welds and extends 1/2 in. on either side of the weld and through the wall thickness. The GALL report recognizes the added importance of Examination Category B-P, which involves visual (VT-2) examination of all pressure retaining boundaries during the system leakage test (IWB-5221) and system hydrostatic test (IWB-5222). The system leakage test is conducted prior to plant startup following each refueling outage, and hydrostatic test is conducted at or near the end of each inspection interval. adequate frac

required for csusceptible to embrittlement(managing thneutron irradiCASS) for easusceptible” cmanagement through eitheexamination ocomponent bafluence to whbeen exposed applicant’s 10inspection (ISlicense renewcomponent-sdetermine its fracture toughThe GALL repto address thi
April 2001 B.2.9-7 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM1 (cont.) NRC staff disagree on some of the aging management activities. The SRP-LR and the GALL report stipulate either a supplemental examination of the some of the susceptible components or a component-specific evaluation to determine the consequences of a loss of fracture toughness. The supplemental examinations for reactor coolant system components are for base metal locations in CASS piping not covered by ASME Code Section XI Examination Category B-J. Flaw tolerance calculations can be used in lieu of these supplemental visual, surface, or volumetric examinations. The supplemental examinations for reactor vessel internals are to replace the Examination Category B-N-3 visual (VT-3) examinations. For pump casings and valve bodies, based on the assessment documented in the letter dated May 19, 2000, from Christopher Grimes, NRC, to Douglas Walters, Nuclear Energy Institute (NEI), screening for susceptibility to thermal aging is not required. The existing ASME Section XI inspection requirements, including the alternative requirements of ASME Code Case N-481 for pump casings, Therefore, while the option of flaw tolerance will be helpful in avoiding unnecessary supplemental examinations, the industry continues to assert that existing ASME Code Section XI inservice inspection activities are adequate to manage the loss of fracture toughness in CASS components caused by thermal aging embrittlement. This adequacy determination applies not only to the Examination Category B- N-3 inspections for internals components, but also to the base metal for reactor coolant system piping components subject to Examination category B-J requirements.
NUREG-1739 B.2.9-8 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM1 (cont.) are considered adequate for all pump casings and valve bodies. Also, the existing ASME Section XI inspection requirements are considered adequate for managing the effects of loss of fracture toughness due to thermal embrittlement of CASS valve bodies. G-XI.M4-1 Closed Cycle Cooling Water System Delete all information associated with the ASME OM S/G, Part 2 as it does not demonstrate chemistry effectiveness in managing aging. Chemistry is sufficient to manage the aging in this system. The Operating Experience attribute for Closed Cycle Cooling Water System should be revised to note that the applicant must provide objective evidence that the program presented in GALL is effective in managing the aging. This evidence could be provided in several different ways, such as a review of operating experience. The Closed Cycle Cooling Water System should state the following: PROGRAM DESCRIPTION The program relies on preventive measures to minimize corrosion by maintaining corrosion inhibitors based on the guidelines of EPRI TR–107396 for closed–cycle cooling water (CCCW) systems, ASME OM S/G, Part 2, provides performance and functional testing guidelines to verify the active functions of the closed cooling water system to demonstrate chemistry effectiveness. Monitoring parameters such as flows, temperatures, and pressures does not manage the loss of material of system components nor will it provide indication that loss of the component function is imminent. As a result, this standard is not effective in maintaining the passive function of the system components nor does it demonstrate chemistry effectiveness. Chemistry alone is sufficient to manage the aging effects in a closed cycle cooling system unless a review of operating experience pertaining to the applicant’s program notes otherwise. A review of operating experience should demonstrate program effectiveness The aging ma

relies on prevminimize corrinhibitors and chemistry moinspection anevaluations bof EPRI-TR-1cooling water inspections fothan chemistrcollection and the potential pof structural inheat transfer and/or deposwill ensure thaand componeCCCW system function acceThe GALL repdelete referenPart 2 and the performance ASME OM S/
April 2001 B.2.9-9 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M4-1 (cont.) EVALUATION AND TECHNICAL BASIS (1) Scope of Program:

A

CCCW system is defined as part ofthe service water system that is notsubject to significant sources ofcontamination, one in which waterchemistry is controlled, and one inwhich heat is not directly rejected toa heat sink. The program describedin this section applies only to such asystem. If any one or more of theseconditions are not satisfied, thesystem is to be considered open–cycle cooling water system and isaddressed in XI.M3 of this chapter.The staff notes that if the adequacyof cooling water chemistry controlcan not be confirmed, the systemshould be treated as an open-cyclesystem and Action III of GL 89-13for open-cycle systems shouldimplemented. Action III wouldrequire an inspection andmaintenance program for piping andcomponents in the CCCW system toensure that corrosion, erosion, andprotective coating failure cannotdegrade the performance of safetyrelated systems serviced by CCCW.(2) Preventive Actions: Theprogram relies on maintainingsystem corrosion inhibitorconcentrations within specified limitsof EPRI TR–107396 to minimizecorrosion.

or the need for further actions toprove effectiveness. A couple ofindustry events do not providesignificant proof that chemistry isineffective at the applicant’s plantand requires further actions unlessthose events occurred at theapplicant’s plant.

“Closed-Cyc(XI.M21 in NVol. 2).
NUREG-1739 B.2.9-10 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M4-1 (cont.) (3) Parameters Monitored/Inspected: The program includes monitoring and control of cooling water chemistry corrosion inhibitor concentrations the specified limits of EPRI TR–107396 to minimize corrosive effects of the aggressive environment. (4) Detection of Aging Effects: Water chemistry manages corrosion by controlling the environment and requires no detection of aging effects. Monitoring and Trending: The frequency of sampling water chemistry varies from continuous, daily, weekly, or as needed, based on plant operating conditions. Acceptance Criteria: Corrosion inhibitors concentrations are maintained within the limits specified in the EPRI water chemistry guidelines for CCCW. (7) Corrective Actions: Corrosion inhibitor concentrations outside the allowable limits are returned to acceptable range within the time period specified in the EPRI water chemistry guidelines for CCCW. (8 & 9) Confirmation Process and Administrative Controls: Site QA procedures, review and approval processes, and administrative controls are implemented in accordance with requirements of
April 2001 B.2.9-11 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M4-1 (cont.) Appendix B to 10 CFR Part 50 and will continue to be adequate for the period of license renewal. As discussed in the appendix to this report, the staff finds 10 CFR Part 50, Appendix B, acceptable in addressing confirmation process and administrative controls. (10) Operating Experience: Degradation of closed-cycle cooling water systems due to corrosion product buildup [Licensee Event Report (LER) 93-029-00] or through- wall cracks in supply lines (LER 91-019-00) have been observed in operating plants. The operating experience indicates that the controlling system chemistry with corrosion inhibitors is effective in managing the effects of aging. REFERENCES EPRI TR-107396, Closed Cooling Water Chemistry Guidelines, Electric Power Research Institute, Palo Alto, CA, November 1997. NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, July 18, 1989. NRC Generic Letter 89-13, Supplement 1, Service Water System Problems Affecting Safety- Related Equipment, April 4, 1990. LER #93-029-00, Inoperable Check Valve in the Component Cooling
NUREG-1739 B.2.9-12 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M4-1 (cont.) System as a Result of a Build-Up of Corrosion Products between Valve Components, December 13, 1993. LER #91-019-00, Loss of Containment Integrity due to Crack in Component Cooling Water Piping, October 26, 1991. G-XI.M4-2 Closed Cycle Cooling Water System The LER numbers listed in the reference list are not valid numbers. The numbers are not standard LER numbers. Searches were not able to find these LERs. The reference

verified to be these LERs aLICENSEE ELER #: 93-02NUMBER: 05Check Valves Cooling SysteBuild-Up of Cbetween ValvEVENT DATEDATE: 12/13/9312270020, (http://scss.or

LICENSEE ELER #:91-019NUMBER: 05Containment in ComponenEVENT DATEDATE: 9/26/99110010058, (http://scss.orThe GALL repa result of this 
April 2001 B.2.9-13 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

XI-M5-1 XI.M5 Revise first sentence of element (1) Scope of Program to read “The program covers any carbon steel and low alloy steel structures and components” Both types of steel are affected. This addition makes the sentence more technically correct. The AMP for 

(XI.M5 in Augrelocated to X1801, Vol. 2) steel and low-or componenreactor water The GALL repaddress the clow-alloy steecomponents i

XI-M5-2 XI.M5 Remove all references to ISI in Program Description and elements (4) and (7). NRC has approved responses to GL 88-05 that both include ASME XI visual examinations and those that don’t. (In most cases, ISI will be one aspect of the 88-05 program.) If 88- 05 program was deemed adequate without inclusion of ISI inspections, it should be adequate for aging management because adequate substitutes for the ISI aspect would have been included. GL 88-05 neither refers to nor requires ISI. Option should be with individual applicant as to whether to include ISI as one aspect of their 88-05 response. This position was accepted in NUREG-1705. Also, program information for elements (1), (5), and (10) does not seem to consider ISI as a separate aspect. The boric acid 

sufficient by itas to prevent corrosion on tCS componeXI inspections independent ocorrosion AMstartup followoutage. The GALL reprevised to addrevising the bAMP (XI.M10 Vol.2) to deleperform inseraccordance w
NUREG-1739 B.2.9-14 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

XI-M6-1 XI.M6 Revise second sentence of element (1) Scope of Program to read “Pump casings and valve bodies retaining pressure in these high energy systems are bounded by the piping inspections performed for the program.” This revision more accurately reflects the scope of the program as defined by NSAC-202L-R2 since the pumps and valves are not actually part of the original UT scope. The scope of 

Aging Manag(XI-M17 in NUwas revised tbodies retainihigh-energy scovered by thof pump casinthe GALL repthinning will aperformance the plant mainThe GALL repaddress this c

G-XI.M7-1 Delete generic program for “Outer Surfaces of Above Ground Carbon Steel Tanks” in its entirety. External corrosion of above ground carbon steel tanks should be addressed on a plant specific basis based upon the different monitoring programs credited by the industry and the differences in tank design utilized. The loss of material due to corrosion of external surfaces of carbon steel components (including tanks) is addressed by a variety of different industry programs. Some tanks may be included in the Maintenance Rule Structures Monitoring Program, while other tank inspections may be governed by the Fire Protection Program or other existing programs. Additionally, the potential aging effects on the external surface of the bottom of tanks are greatly dependent on the design of the tank. The program 

“Above Groun(XI.M29 in NUand it providefor the externground carboGALL report waddress this capplicant has conducting an specific progr
April 2001 B.2.9-15 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M7-1 (cont.) Some tanks are designed with a solid concrete foundation, which supports the floor of the tank. These tanks utilize a layer of asphalt or other material between the tank bottom and the concrete to eliminate high point bearing and to preclude moisture intrusion. Other designs utilize a concrete ring wall to support the walls of the tank and the tank bottom sits on compacted oil impregnated sand. Some tanks utilize a layer of grout between the tank bottom and the ring header to preclude moisture intrusion. As such, the environments and resulting potential aging effects associated with tanks are dependent upon site specific design considerations. Therefore, potential aging effects on external surfaces of above ground carbon steel tanks should be addressed on a plant specific basis. G-XI.M8-1 Delete generic program for “Outer Surface of Buried Piping and Components” in its entirety. Nuclear industry experience dictates external corrosion of buried piping should be addressed on a plant specific basis. Aging effects associated with buried piping are highly dependent upon site specific considerations such as aggressiveness of soil/fill environment, materials used, and condition of protective coatings. Because Bell hole examinations have the potential of damaging The AMP “Bu

Surveillance” 1801, Vol. 2) buried carbon the Buried PipSurveillance Astandards) is industry standacceptable mthe AMP “BurSurveillance” 1801, Vol. 2) 
NUREG-1739 B.2.9-16 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M8-1 (cont.) coatings when unearthing pipe, they are not typically conducted at nuclear plants. Additionally, the most common failures are due to localized pinhole degradations in the coatings. However, when specific components are unearthed for repairs (e.g., a fire protection post indicator isolation valve), the condition of the external coatings on adjacent unearthed piping is typically inspected as a good practice. Plants which have experienced external aging effects with buried piping have taken actions to address their specific issues, including replacement of piping when deemed necessary. Therefore, potential aging effects on external surfaces of buried piping and components should be addressed on a plant specific basis. “Buried Piping 

(XI.M34, NURwhich inspectfrequency for piping considexperience thcrediting the iis dug up for afrequency and experience coplant specific The GALL repaddress this cnew alternativand Tanks SuNUREG-1801

G-XI.M9-1 Fuel Oil Chemistry The ASTM Standard D270 does not exist in the ASTM Standards from 1996 through 2000. We believe that this standard should be replaced with ASTM D4057. Unable to find the ASTM Standard D270. The title in the reference list matches the title D4057. The “Fuel Oil 

(XI.M30 in NUwas revised aASTM D 270 D 4057-95(20for Manual Saand Petroleum The GALL repaddress this c
April 2001 B.2.9-17 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M9-2 Fuel Oil Chemistry If ASTM Standard D270 should be D4057, then the second sentence in the Parameters Monitored/ Inspected is incorrect. D4057 provides guidance for obtaining a sample; it does not define fuel oil specifications. Fuel oil specifications are outlined in D975. A review of ASTM Standard D4057 did not reveal any fuel oil specifications. Standard D4057 only provides guidance for obtaining samples. The “Fuel Oil 

(XI.M30 in NUwas revised aStandard D 4sampling and 975 for guidaspecificationsThe GALL repaddress this c

G-XI.M9-3 Fuel Oil Chemistry ASTM D975 does not specify microbiological limits for fuel oil as stated in the Acceptance Criteria attribute of the program. A review of ASTM 975 did not reveal any limits for microbiological limits in fuel oil. In addition, the industry is not aware of a standard that specifies microbiological limits for fuel oil. The “Fuel Oil 

(XI.M30 in NUwas revised aASTM D 975 microbiologicand the approsediment D 2D 2276.were Standards D used for detesediment confuel. For deteparticulates, m

Method A, is The GALL repaddress this c

G-XI.M9-4 Fuel Oil Chemistry Statements for verification of program effectiveness should be deleted from the Program Description and Detection of Aging Effects attributes. Statements concerning demonstration of program effectiveness should be in the Operating Experience attribute as defined by Appendix A of the Chemistry alone is sufficient to manage the aging effects in the fuel oil system unless a review of operating experience pertaining to your program notes otherwise. A review of operating experience should demonstrate program effectiveness or the need for further actions, such as inspections, to The “Fuel Oil 

(XI.M30 in NUwas revised asuggested by incorporated. needed to verthe fuel oil chmanagement the absence o
NUREG-1739 B.2.9-18 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M9-4 (cont.) SRP-LR. In addition, the statements should be clarified to note that other means of demonstrating effectiveness other than inspection, such as operating experience review, are available. In addition, the Fuel Oil Chemistry is sufficient to manage aging in the fuel oil tanks and should be written as follows: PROGRAM DESCRIPTION The program includes a combination of surveillance and maintenance procedures. Fuel oil quality is maintained by monitoring and controlling fuel oil contamination in accordance with the guidelines of ASTM Standards D975, D4057, D1796, and D2709. Exposure to fuel oil contaminants, such as water and microbiological organisms, is minimized by verifying the quality of existing fuel oil and new oil before its introduction into the storage tanks. EVALUATION AND TECHNICAL BASIS (1) Scope of Program: The program is focused on managing the conditions that cause general, pitting, and microbiologically- induced corrosion of the diesel fuel tank internal surfaces; it reduces the potential of exposure of the tank internal surface to fuel oil contaminated with water and prove effectiveness. A few industry events do not provide significant proof that chemistry is ineffective at applicant’s plant and requires further actions unless those events occurred at applicant’s plant. Because the 

option of condplant-specific The GALL repto address the comment.
April 2001 B.2.9-19 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M9-4 (cont.) microbiological organisms. (2) Preventive Actions: The quality of fuel oil is maintained by additions of biocides to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibitors to mitigate corrosion. Coatings, if used, prevent or mitigate corrosion by protecting the internal surfaces of the tank from contacting with water and microbiological organisms. (3) Parameters Monitored/Inspected: The AMP monitors fuel oil quality and the levels of water and microbiological organisms in the fuel oil, which cause loss of material of the tank internal surface. ASTM standard D975 defines fuel oil specifications and standard D4057 defines sampling requirements. The ASTM standards D1796, and D2709, provide guidance to quantify insoluble particulate contamination in diesel fuel. These are the principle parameters relevant to tank structural integrity. (4) Detection of Aging Effects: Degradation of the diesel fuel oil tank cannot occur without exposure of the tank internal surfaces to contaminants in the fuel oil, such as water and microbiological organisms. Compliance with diesel fuel oil
NUREG-1739 B.2.9-20 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M9-4 (cont.) standards in item 3 above and periodic multilevel sampling provides assurance that fuel oil contaminants are below acceptable levels. (5) Monitoring and Trending: Water and biological activity or particulate contamination concentrations are monitored and trended at least quarterly. Based on industry operating experience, quarterly sampling and analysis of fuel oil provide for timely detection of conditions conducive to corrosion of the internal surface of the diesel fuel oil tank before the potential loss of its intended function. (6) Acceptance Criteria: ASTM standard D 975 specifies acceptance criteria for the limits of water content and sediment in the diesel fuel oil. (7) Corrective Actions: Specific corrective actions are implemented in accordance with the plant quality assurance (QA) program. For example, corrective actions are taken to prevent recurrence when the specified limits for fuel oil standards are exceeded or when water is drained during periodic surveillance. Also, when the presence of biological activity is confirmed, a biocide is added to fuel oil. As discussed in the appendix to this report, the staff finds 10 CFR Part 50, Appendix B, acceptable in
April 2001 B.2.9-21 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M9-4 (cont.) addressing corrective actions. (8 & 9) Confirmation Process, and Administrative Controls: Site QA procedures, review and approval processes, and administrative controls are implemented in accordance with requirements of Appendix B to 10 CFR Part 50 and will continue to be adequate for the period of license renewal. As discussed in the appendix to this report, the staff finds 10 CFR Part 50, Appendix B, acceptable in addressing confirmation process and administrative controls. (10) Operating Experience: The operating experience at some plants has included identification of water in the fuel, particulate contamination, and biological fouling. However, no instances of fuel oil system components failures attributed to contamination have been identified. This operating experience indicates that maintaining monitoring and controlling fuel oil quality is effective in managing the effects of aging. REFERENCES ASTM D 975-98b, Standard Specification for Diesel Fuel Oils, The American Society of Testing Material, West Conshohocken, PA. ASTM D 4057-95, Standard Method of Sampling Petroleum and
NUREG-1739 B.2.9-22 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M9-4 (cont.) Petroleum Products, The American Society of Testing Material, West Conshohocken, PA. ASTM D 1796-97, Standard Test Method for Water and Sediment in Fuel Oils by the Centrifuge Method, The American Society of Testing Material, West Conshohocken, PA. ASTM D 2709-96, Standard Test Method for Water and Sediment in Middle Distillate Fuels by Centrifuge, The American Society of Testing Material, West Conshohocken, PA. G-XI.M10-1 Delete the 4th sentence of element 4 in the Evaluation and Technical Basis that states “This program of functional testing, ...in accordance with 10 CFR Part 50, Appendix R.” System testing, maintenance and inspection in accordance with NFPA should be adequate. Not all sections of Appendix R are applicable to all plants, depending on the date the plant was licensed, commitments to Appendix A of BTP APCSB 9.5-1, or NRC acceptance of plant fire protection features as documented by the staff in comprehensive fire protection SER’s issued before Appendix A to BTP APCSB 9.5-1 was published. Moreover, Appendix R primarily addresses design and personnel requirements necessary to assure safe shutdown capabilities. With respect to system testing, maintenance and inspections, Appendix R includes only general requirements. The reference

Evaluation anthe “Fire WatXI.M10 (XI.MVol. 2) “This implemented CFR part 50, deleted. The Aensure no sigor biofouling hbased fire properiodic flushperformance inspections aThe GALL repaddress this c

G-XI.M10-2 In the program description, replace the last 3 sentences to state the following: “In addition to NFPA Meeting applicable NFPA commitments and the additional internal inspections of system There is evide

programs, NFdetect MIC, c
April 2001 B.2.9-23 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M10-2 (cont.) commitments, internal inspections are performed on system components when disassembled to identify evidence of loss of materials due to corrosion and biofouling. Also, system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.” components when disassembled along with maintaining the system at normal operating pressure provide the assurance that the system intended functions are maintained. This is demonstrated by the element 10, Operating Experience write-up, where the GALL report states, “Water based fire protection systems designed, inspected, tested and maintained in accordance with the NFPA standards have demonstrated reliable performance for at least 80 years.” prior to a loss 

function. The requirements the detection loss of the intlicense renewwas revised tinspections foensure that cohave not causthinning and thead operabiperiod of exterevised progrread: In additstandards, whcontain progrsubjected to fsubjected to fmaximum desbefore the peoperation (anthereafter). In sprinkler headby using the gSection 2.3.3states “where in place for 50 replaced or refrom one or mshall be submtesting laboratesting.” It alsperform this syears after the testing. Finall
NUREG-1739 B.2.9-24 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M10-2 (cont.) protection sup

located aboveto water also disassembled internally oncoutage. The ptesting and ininspections is corrosion, MICeffects are msystem functiElement 10 wthe reference since no comhave operated element now based fire prodesigned, insmaintained in NFPA standareliable perforThe program Water SystemNUREG-1801modified to ad

G-XIM11-1 E&TB Item 7 Delete the reference to the “appendix to this report.” It is unclear what this statement means. A more clear reference can be used if desired. Element 7 “C

“Reactor Wat(XI.M2 in NURrevised to cla“appendix to tThe GALL repaddress this c
April 2001 B.2.9-25 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M11-2 Water Chemistry Statements for verification of program effectiveness should be deleted from the Program Description and Detection of Aging Effects attributes. Statements concerning demonstration of program effectiveness should be in the Operating Experience attribute as defined by Appendix A of the SRP-LR. In addition, the statements should be clarified to note that other means of demonstrating effectiveness other than inspection, such as operating experience review, are available. Chemistry alone is sufficient to manage aging and the program should be revised as follows: PROGRAM DESCRIPTION The water chemistry program for BWRs relies on monitoring and control of reactor water chemistry based on the EPRI guidelines in TR- 103515. The EPRI document TR- 103515 has three sets of guidelines, one for primary water, one for condensate and feedwater, and one for control rod drive mechanism cooling water. The water chemistry program for PWRs relies on monitoring and control of reactor water chemistry based on the EPRI guidelines in TR-105714 for primary water chemistry and TR-102134 for Chemistry alone is sufficient to manage the aging effects unless a review of operating experience pertaining to your program notes otherwise. A review of operating experience should demonstrate program effectiveness or the need for further actions, such as inspections, to prove effectiveness. A few industry events do not provide significant proof that chemistry is ineffective at applicant’s plant and requires further actions unless those events occurred at applicant’s plant. The proposed 

“Reactor WatNUREG-1801NEI is not sigthe version suAugust 2000, inspection in Aging Effectsis needed to vof water chemconfirm the aeffect. If an agthe results are determine the actions. At the NEI said that appropriate laalternative to Although the any NEI inputThe GALL repaddress the cstatement indalternatives bmaintenance 
NUREG-1739 B.2.9-26 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M11-2 (cont.) secondary water chemistry. The water chemistry programs are generally effective in removing impurities in primary and secondary water systems. EVALUATION AND TECHNICAL BASIS (1) Scope of Program: The program includes periodic monitoring and control of known detrimental contaminants such as chlorides, fluorides (PWRs only), dissolved oxygen, and sulfate concentrations below the levels known to result in loss of material. Water chemistry control is in accordance with the EPRI guidelines of TR-103515 Rev. 3, for water chemistry in BWRs, TR-105714 Rev. 3, for primary water chemistry in PWRs, and TR-102134 Rev. 3 for secondary water chemistry in PWRs, or later revisions or updates of these reports as approved by the staff. (2) Preventive Actions: The program includes specifications for chemical species, sampling and analysis frequencies, and corrective actions for control of reactor water chemistry. System water chemistry is controlled to minimize contaminant concentration and mitigate loss of material due to crevice and pitting corrosion.
April 2001 B.2.9-27 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M11-2 (cont.) (3) Parameters Monitored/Inspected: Concentration of corrosive impurities listed in the EPRI guidelines discussed above, and which include chlorides, fluorides (PWRs only), sulfates, dissolved oxygen and hydrogen peroxide, are monitored to mitigate corrosion. Water quality (pH and conductivity) is also maintained in accordance with the guidance. (4) Detection of Aging Effects: Water chemistry manages corrosion by controlling the environment and requires no detection of aging effects. (5) Monitoring and Trending: The frequency of sampling water chemistry varies from continuous, daily, weekly, or as needed, based on plant operating conditions. Whenever corrective actions are taken to address an abnormal chemistry condition, increased sampling is utilized to verify the effectiveness of these actions. (6) Acceptance Criteria: Maximum levels for various contaminants are maintained below the system specific limits based on the limits specified in the EPRI water chemistry guidelines (see item 10, below). Any evidence of the presence of an aging effect or unacceptable water chemistry results is evaluated and its root
NUREG-1739 B.2.9-28 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M11-2 (cont.) cause identified and the condition corrected. (7) Corrective Actions: When measured water chemistry parameters are outside the specified range, corrective actions are taken to bring the parameter back within the acceptable range in the time period specified in the EPRI water chemistry guidelines. As discussed in the appendix to this report, the staff finds 10 CFR Part 50, Appendix B, acceptable in addressing corrective actions. (8) Confirmation Process: Following corrective actions, additional samples are taken and analyzed to verify that the corrective actions were effective in returning the concentrations of contaminants such as chlorides, fluorides, sulfates, dissolved oxygen/hydrogen peroxide to within the acceptable ranges. (9) Administrative Controls: Site QA procedures, review and approval processes, and administrative controls are implemented in accordance with requirements of Appendix B to 10 CFR Part 50 and will continue to be adequate for the period of license renewal. Operating Experience: The EPRI guidelines documents have been developed based on plant
April 2001 B.2.9-29 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.M11-2 (cont.) experience and have been shown to be effective over time with their widespread use. REFERENCES EPRI TR-105714, PWR primary Water Chemistry Guidelines- Revision 3, Electric Power Research Institute, Palo Alto, CA, Nov. 1995. EPRI TR-102134, PWR Secondary Water Chemistry Guideline-Revision

3, Electric Power Research Institute,Palo Alto, CA, May 1993.EPRI TR-103515, BWR WaterChemistry Guidelines-Revision 3,Normal and Hydrogen WaterChemistry, Electric Power ResearchInstitute, Palo Alto, CA, February1994.
NUREG-1739 B.2.9-30 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM12-1 1-10 The aging management activities appear to ignore the activities that licensees take to ensure that aging of in-scope, but non-safety related, bolting does not inhibit the intended function of the system or component. Following the EPRI guidelines was not required in the Generic Letter (91-17); however, if licensees have examined their bolting practices and have determined that their programs are adequate, then they should only have to say so in their application. Inspection of bolting in non-safety applications will not prove effective in preventing loss of preload or SCC in some cases. These two effects are most properly managed through original design and torquing. The Bolting In

(XI.18 in NURacknowledgelicensees take in-scope, but bolting. The laElement (1) in AMP state thatechnical bassafety related for material sebolting preloainspection (ISmaintenance, structural inteare outlined in include EPRI exception notsafety-related 104213 replaEPRI NP-506The GALL repto address thi

G-XIM12.2 SRP-LR Tables 3.2-1 3.3-1 3.4-1 and 3.5-1 GALL Sections V.D1.1.7 V.D1.2.2 V.D1.3.1 V.D1.4.2 V.D1.5.5 This is a listing of many of the locations where bolting or the Bolting Integrity Program is specifically mentioned. Any discussion on bolting or the alone should be deleted and replaced with a general discussion on closure set integrity in the SRP-LR. No specific, individual listing of bolting is needed. Also the Bolting Integrity Program is not a real plant program. The These comments should serve to complement other comments associated with mechanical and structural bolting. Other comments have been made to delete bolting as a specific component for review. Bolting is one part of a multi-part closure set that also includes mating surfaces and could contain gaskets. The function of concern is loss of closure integrity and not bolt integrity. This aging pro

“Bolting Integ(XI.M18 in NUwhich covers scope of licenconsidered to component beuniquely identit is a small coreview could categorized ucategory. Bec
April 2001 B.2.9-31 NUREG-1739 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM12.2 (cont.) V.E.2 VII.A3.1.1 VII.A3.2.2 VII.A3.3.2 VII.A3.4.3 VII.A3.5.3 VII.A3.6.1 VII.D.1.2 VII.D.2.2 VII.D.3.2 VII.D.4.2 VII.D.5.2 VII.E1.1.2 VII.E1.2.2 VII.E1.3.2 VII.E1.4.2 VII.E1.5.2 VII.E1.6.2 VII.E1.7.5 VII.E1.8.5 VII.E1.9.1 VII.E1.10.1 VII.E3.2.2 VII.I.2 VIII.B1.1.2 VIII.H.2 appropriate attributes for managing closure integrity will be contained within other plant programs, a number of which are already covered in GALL. Specific details in Comment 3 identify the shortcomings of XI.M12, Bolting Integrity as written. treats individu

component aof individual bThis AMP is rand the GALL modified to ad
NUREG-1739 B.2.9-32 April 2001 Table B.2.9-2: Disposition of NEI Mechanical Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XIM12-4 GALL XI.M12 Delete the XI.M12 Bolting Integrity and all associated references from GALL and SRP-LR. Along with the major perspective issue described in Comment 2 on whether bolting is a component or part of a component, here are some specific problems with the Bolting Integrity write-up and supporting evidence why the program write-up should be deleted: Scope says the program covers all bolting within the scope of license renewal, yet structural bolting is not covered within other program attributes. Also, the program as called out only addresses nuclear class I (RCPB) bolting, mainly 2” and larger. Chapter IV addresses RPV and RPV internals and associated AMP’s. Parameters Monitored/Inspected says the program monitors effects of aging on the intended function of closure bolting. Bolting does not have a license renewal intended function. Bolting is part of a closure set that has a closure integrity or structural support function. This is a fundamental issue. of Aging Effects says ASME Section XI is a fine program to manage bolting falling within its purview. We agree for those items falling within the scope of ASME, so the Bolting Integrity write-up is extraneous. The “Bolting I

(XI.M18 in NUcovers all boltlicense renew(EPRI TR-104earlier report Bolting PractiManual for NuMaintenance ASME Sectiostructural boltattribute Deteis concerned, program is noThe GALL repaddress the csentence to th104213, BolteApplication G
April 2001 B.2.9-33 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G.XI.S1-1 Eval & Tech Basis (1) Scope of Program Change item number 3 to “...provided IWE-1232 and IWE- 5220 are met...” Editorial The proposed 

more concise appropriate pGALL XI.S1 wthis comment

G.XI.S1-2 XI.S1 Scope of Program Industry concerns regarding inaccessible areas have not been addressed. Consider adding the following paragraph “Plant-specific evaluation of such inaccessible areas should begin with an assessment of environmental conditions, such as severe weathering, aggressive groundwater, and impinging flow of groundwater, that could lead to accelerated aging effects in inaccessible areas with little or no effect in accessible areas. Guidelines for quantitative assessment of severe environmental conditions are provided in Section III.A.1.1 of the GALL.” Plant-specific actions to address inspection of inaccessible areas are beyond Code requirements. Detailed guida

inaccessible aincorporated containment sdiscussion of pertains to inabeen deleted XI.S2. With thNUREG-1611 management of containmendirectly addreGALL XI.S1 aimplementatioaccordance wrespectively. GALL Chapteand XI.S2 wethis comment
NUREG-1739 B.2.9-34 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G.XI.S1-3 Eval & Tech Basis (3) (3) Parameters Monitored or Inspected Clarify that the “Volumetric” examination method is ultrasonic thickness measurements. Revise the Category E-C table entry to “Visual VT-1, Ultrasonic Thickness Measurements.” Misleading characterization of Examination Category E-C. The term “Vo

Table IWE-25avoid confusithe table descCategory E-Chas been cha(Ultrasonic ThMeasuremenbecause it modescribes the examination sGALL XI.S1 wthis comment

G-XI.S1-4 Eval & Tech Basis (4) (4) Detection of Aging Effects Revise sentence as follows: “An expedited examination of containment is required by 10 CFR 50.55a in which an inservice (baseline) examination specified for the first period of the first inspection interval must be performed by September 9, 2001.” The added words (underlined) come directly from 10 CFR 50.55a and are included for clarification purposes. The proposed 

reflects the re10 CFR 50.55GALL XI.S1 wthis comment

G.XI.S1-5 Eval & Tech Basis (4) (4) Detection of Aging Effects Clarify that the “Volumetric” examination method is ultrasonic thickness measurements. Revise the next-to-last sentence to “Selected areas, such as containment surfaces requiring augmented examination (E-C) require ultrasonic thickness measurements.” Misleading characterization of Examination Category E-C. See NRC Dis

Comment G.XTable B.2.9-3
April 2001 B.2.9-35 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S1-6 Eval & Tech Basis (8) (8) Confirmation Process While the write-up for IWE is fairly comprehensive, the key provision for aging management in IWE is missing in the text. Please add to the text “IWE-1240 requires augmented examinations of containment surface areas subject to degradation. A VT-1 examination is required for these areas in lieu of the VT-3 examination specified for examination category E-A in Table IWE-2500-1.” IWE-1240 is the key to aging management in Section XI-IWE. The proposed 

appropriate in Detection of A(4) already hafor augmenteselected areaaccurately refthe evaluation been revised requires augm(Examination containment sto degradatiois required whaccessible frovolumetric (ulmeasuremenrequired for aonly one sideGALL XI.S1 wthis comment
NUREG-1739 B.2.9-36 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G.XI.S2-1 Eval & Tech Basis, (1) Scope of Program Industry concerns have not been addressed. Consider adding the following paragraph “Plant-specific evaluation of such inaccessible areas should begin with an assessment of environmental conditions, such as severe weathering, aggressive groundwater, and impinging flow of groundwater, that could lead to accelerated aging effects in inaccessible areas with little or no effect in accessible areas. Guidelines for quantitative assessment of severe environmental conditions are provided in Section III.A.1.1 of the GALL.” Plant-specific actions to address inspection of inaccessible areas are beyond Code requirements. See NRC Dis

Comment G.XAppendix B, T

G-XI.S2-2 Eval & Tech Basis, (2) (2) Preventive Action Delete the reference to a “credited coating program” (second sentence). Concrete coatings are very plant specific based on external environment. Some plants in harsh climate have metal covers over the containment in lieu of coatings. Coatings are generally not used on interior containment concrete surfaces within the scope of IWL. Reliance on c

manage aging relied upon duoperating termmonitors and coatings shouupon for licen(2) has been coating progrfor managing concrete surfacontinued durextended opeGALL XI.S2 wthis comment
April 2001 B.2.9-37 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S2-3 Eval & Tech Basis, (3) (3) Parameters Monitored or Inspected Change “ultimate strength” to “ultimate tensile strength” in sentence on tendon wires are also tested for... To match the ASME Code (IWL- 2523.2). (Editorial) The proposed 

reflects the wGALL XI.S2 wthis comment

G-XI.S2-4 Eval & Tech Basis (4) 5th line (4) Detection of Aging Effects Clarify the inspection intervals for sites with two plants as specified in IWL-2421. The following paragraph needs to be added: “For sites with multiple plants, the examination requirements for the concrete containments may be modified if the containments utilize the same prestressing system and are essentially identical in design, if post-tensioning operations for each subsequent containment constructed at the site were completed not more than 2 years apart, and if the containments are similarly exposed to or protected from the outside environment. When the above conditions are met, the inspection dates and examination requirements may be as follows. For the containment with the first Structural Integrity Test, all examinations required by IWL-2500 shall be performed at 1, 3, and 10 years and every 10 years thereafter. Only the examinations required by IWL-2524 and IWL-2525 need be performed at 5 and 15 years and To address the inspection interval for sites with multiple units. The evaluatio

the 1992 editiand the 1995 addenda, in alatest revision These editionwith multiple pThese editionwith two plantfollowing sentAttribute (4): “plants, the scinspection is pGALL XI.S2 wthis comment
NUREG-1739 B.2.9-38 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S2-4 (cont.) every 10 years thereafter. (2) For each subsequent containment constructed at the site, all examinations required by IWL- 2500 shall be performed at 1, 5, and 15 years and every 10 years thereafter. Only the examinations required by IWL-2524 and IWL-2525 need be performed at 3 and 10 years and every 10 years thereafter.” G-XI.S2-5 Eval & Tech Basis, (3) (5) Monitoring and Trending Delete second sentence that states trending is required. Not a requirement of IWL. Although tren

requirement orequired by 10 [or (viii) in the the regulationevaluation of surveillances for the same group indicateloss such thawould be less design prestrebefore the nean evaluation and reported GALL XI.S2 waddress this c

G-XI.S2-6 Page XI-S6 Under Attribute (3), delete “wear” from the sentence on tendon anchorage and wires are visually examined.... Code does not state wear. The proposed 

reflects the wGALL XI.S2 wthis comment
April 2001 B.2.9-39 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S3-1 Page XI-S11 Under monitoring and trending, at the end of the last sentence add that trending is possible, but not required. To address th

(5) Monitoring been deleted GALL XI.S3 wthis comment

G-XI.S4-1 Appendix J, Eval & Tech Basis The “Evaluation and Technical Basis” for the Appendix J Program needs to acknowledge the requirements for the Containment Inspection as discussed in 10 CFR 50 Appendix J, V.A., particularly the sentence: “...to uncover any evidence of structural deterioration which may affect either the structural integrity or leak-tightness.” Prior to the mandatory inspections under ASME XI-IWE and IWL, Appendix J inspections were performed (and continue to be performed) and provide the operating experience for containment aging. The GALL rep

discussion reJ containmendiscussion of Experience” fIWL (XI.S2) Amandatory insof IWE and IWsuperceded thinspections, tTechnical BasAMP (XI.S4) rate testing re50 Appendix JGALL XI.S4 waddress this c

G-XI.S5-1 XI.S5, Introduction, and Evaluation & Technical Basis, items 1 and 6 Delete references to A-46 program. Change the discussion in items 1 and 6 of the Evaluation and Technical Basis to refer to masonry walls within the scope of license renewal. Reference to A-46 program is inappropriate because the evaluation of masonry walls is not a defined element of the USI A-46 program. The appropriate reference is to “those masonry walls within the scope of license renewal.” Masonry walls 

evaluated durprogram that function consof 10 CFR Pain the scope opurpose of thA-46 program and reviewerswalls that servnecessary to are also withirenewal.
NUREG-1739 B.2.9-40 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S5-1 (cont.) At the meetin

NEI pointed oissue and it is address LR sissue is more addressed in Consequently“Structural Coan Aging ManSRP-LR-LR, sentence was example, if a structure or cin the plant’s safe shutdowthe resolution reviewer shoustructure or cincluded withirenewal.” XI.S5 Attributwere revised A-46. XI.S5 Arevised to incMR inspection operating expGALL XI.S5 wthis comment
April 2001 B.2.9-41 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S5-2 XI.S5, Evaluation & Technical Basis Under item 4, Detection of Aging Effects: Delete the following two sentences “Unreinforced masonry walls that have not been contained by bracing require the most frequent inspection because the development of cracks may invalidate the evaluation basis. These walls are to be inspected at every refueling outage.” There is no regulatory requirement to perform this inspection at every refueling outage. The wording cited constitutes a backfit of requirements. Requirements for inspection of unreinforced masonry walls are plant-specific, and will generally be contained in either a Masonry Walls Program or the Structures Monitoring Program (SMP) for the Maintenance Rule. Inspection intervals associated with the SMP, for instance, vary significantly. The sentence

be inspected outage,” was XI.S5, AttribuAging Effectsdevelopment schedule that loss of intendinspections is there. The insresponsibility GALL XI.S5 wthis comment

G-XI.S5-3 XI.S5, Introduction There is no need to include “NUREG-1557 identifies IE Bulletin 80-11 and IN 87-67 as an acceptable basis...” Stand alone comments about IE Bulletin 80-11 and IN 87-67 are adequate by themselves. Reference to 

extraneous hedeleted. GALL XI.S5 wthis comment
NUREG-1739 B.2.9-42 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S5-4 XI.S5, Introduction The following wording should be used: Since the issuance of the IEB 80-11 and IN 87-67, the NRC promulgated 10 CFR 50.65, the Maintenance Rule. Masonry walls may be inspected as part of the Structures Monitoring Program (XI-S6) conducted for the Maintenance Rule. In these cases, the Maintenance Rule evaluation (XI-S6) for license renewal applies and no further explanation is required. For plants with a separate masonry wall program, the following evaluation and technical basis is provided: Provides for use of existing Structures Monitoring Program and a method for using other plant specific programs. NEI’s propose

incorporated Description foProgram (XI.Ssentence, “In Maintenance for license renfurther explanTo clarify the structures mo(XI.S6) to agimasonry wallsDescription fostipulate that incorporate thin XI.S5 when manage aging general, a StrProgram to mRule does noof seismic II/I function. This for license renwalls within threnewal are nscope of a StProgram. The that all masonscope are inccredit for a StProgram. GALL XI.S5 wthis comment
April 2001 B.2.9-43 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S5-5 XI.S5, Evaluation & Technical Basis Masonry Wall Inspection: Scope of Program: The scope of the program includes those masonry walls within the scope of license renewal. Preventive Actions: No specific preventive actions are required. Parameters Monitored/Inspected: Visual inspection by a qualified individual is sufficient to identify cracking of masonry walls. Detection: A visual inspection performed using the guidance of IEB 80-11 and IN 87-67 provides reasonable assurance that the aging effect of cracking will be identified prior to loss of the component intended function. Monitoring and Trending: There are no monitoring and trending processes associated with this program Acceptance Criteria: Acceptance criteria are no visual indication of cracking of masonry walls, which would invalidate the evaluation basis in response to IEB 80-11. (10)Operating Experience: Incorporation of lessons learned from the implementation of IE Bulletin 80-11, USI A-46, and the There is no need to include USI A- 46 program here. It is addressed in Operating Experience. The program is a visual inspection and no preventive actions are identified. The staff has found this acceptable. Cracking is the primary parameter. Frequency does not need to be specified here. Frequency is per the current licensing basis. The NRC staff has found this acceptable. Do not expand criteria previously established. This NEI prop

previously suFor the Augusthis proposal because it lacneeded to cleattributes of amasonry wallsGALL XI.S5 waddress this cAlso see NRC Comment G-XTable B.2.9-3
NUREG-1739 B.2.9-44 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S5-5 (cont.) MR Inspection should assure the structural integrity of all masonry walls important to safety are adequately managed. This should ensure the structural integrity of the masonry walls within the scope of license renewal is adequately managed for the period of extended operation. Delete Note. Note has been incorporated in text above in Introduction. G-XI.S6-1 XI-S6 Evaluation & Technical Basis (3) Delete the following statements: “For concrete structural elements, parameters to be monitored or inspected include cracking, spalling, scaling, erosion, corrosion of reinforcing steel, settlements, and deformations. A more complete description of parameters for inclusion in this AMP is presented in ACI 349.3R-96. For steel liners and for joints, coatings, and waterproofing membranes (if any of these three items are relied upon to manage the effects of aging), ACI 349.3R-96 also specifies a description of the parameters to be monitored or inspected. For structural steel elements (including connections), parameters to be monitored or inspected include corrosion, cracking, erosion, discoloration, wear, pitting, gouges, dents, and other signs of surface irregularities. ANSI/ASCE 11-90 provides details for some of these NEI 96-03 is a more appropriate reference than ACI 349.3, as it was the guidance document actually used by applicants to develop the Structures Monitoring Program for the Maintenance Rule. For example, under acceptance criteria ACI 349.3 specifies acceptance criteria more stringent than the ASME Code. Any reference to ACI 349.3 should state that ACI 349.3 provides guidance on acceptance criteria that may be used. ANSI/ASCE 11-90 is not widely used by the industry to define inspection attributes for structural steel elements. EPRI NP-5380 is an inappropriate reference as it is primarily applicable to construction, not ongoing maintenance of welds. It is not typically the source of industry inspection activities regarding welds. The quoted te

However, the not appropriahas not been for license rento NEI dated September 24intent, the deswas revised t349.3R-96 anare examples standards whdevelop or demonitored/insto EPRI NP-5because it doinservice inspComparable rmade to Attribaddress NEI cand G-XI.S6-Table B.2.9-3GALL XI.S6 w
April 2001 B.2.9-45 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S6-1 (cont.) parameters to be monitored or inspected. For welds, additional details on parameters to be monitored or inspected are provided in EPRI NP-5380.” Insert “Specification of parameters to be monitored or inspected should be linked to aging effects. Guidance for parameters monitored/inspected is provided in NEI 96-03.” Leave last sentence as is. EPRI NP-5380 does not address operating inspections of welds. EPRI NP-5380 provides guidelines for construction. The document states that cracks are not permitted. Information on welds should not be identified here. this commentG-XI.S6-2 XI-S6 Evaluation & Technical Basis (4) Delete the following statements: “As specified in ACI 349.3R-96, “the visual inspection should include all exposed surfaces of the structure, joints and joint material, interfacing structures and materials (e.g., abutting soil), embedments, and attached components such as base plates and anchor bolts.” ANSI/ASCE 11-90 specifies that inspection of the physical condition may sometimes require the use of simple physical assistance such as cleaning, scraping, and sounding. Details on detection methods for concrete; steel liners; and joints, coatings, and waterproofing material (if relied upon to manage the effects of aging) are specified in ACI 349.3R-96. Details on detection methods for structural steel (includ- ing connections) are specified in ASNI/ASCE 11-90. Additional details on detection methods for welds are NEI 96-03 is a more appropriate reference than ACI 349.3, as it was the guidance document actually used by applicants to develop the Structures Monitoring Program for the Maintenance Rule. For example, under acceptance criteria ACI 349.3 specifies acceptance criteria more stringent than the ASME Code. Any reference to ACI 349.3 should state that ACI 349.3 provides guidance on acceptance criteria that may be used. ANSI/ASCE 11-90 is not widely used by the industry to define inspection attributes for structural steel elements. EPRI NP-5380 is an inappropriate reference as it is primarily applicable to construction, not ongoing maintenance of welds. It is not typically the source of industry See NRC Dis

Comment G-XTable B.2.9-3
NUREG-1739 B.2.9-46 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S6-2 (cont.) specified in EPRI NP-5380. The frequency for the inspection of structures shall be dependent upon the structure, environment, and past performance; however, the frequency shall be no more than ten years. This frequency is in agree- ment with inspection intervals specified in ACI 349.3R-96 for concrete structures and recom- mendations given in NUREG-1522.” Replace with: “Guidance for detection is provided in NEI 96-03.” inspection activities regarding welds. EPRI NP-5380 does not address operating inspections of welds. EPRI NP-5380 provides guidelines for construction. The document states that cracks are not permitted. Information on welds should not be identified here. G-XI.S6-3 XI-S6 Evaluation & Technical Basis (6) Delete the following statements: “For concrete structures (including steel liners and joints, coatings, and waterproofing material, if relied upon to manage the effects of aging), Chapter 5 of ACI 349.3R-96 specifies acceptance criteria. Acceptance criteria are specified for 1) acceptance without further evaluation, 2) acceptance after review, and 3) conditions requiring further evaluation. For example, acceptance without further evaluation for concrete is passive cracks in concrete less than 0.4 mm (0.015 in.) in maximum width. Acceptance criteria for visual examination of welds are specified in EPRI NP-5380.” Replace with: “Guidance for acceptance criteria is provided in NEI 96-03 is a more appropriate reference than ACI 349.3, as it was the guidance document actually used by applicants to develop the Structures Monitoring Program for the Maintenance Rule. For example, under acceptance criteria ACI 349.3 specifies acceptance criteria more stringent than the ASME Code. Any reference to ACI 349.3 should state that ACI 349.3 provides guidance on acceptance criteria that may be used. EPRI NP-5380 is an inappropriate reference as it is primarily applicable to construction, not ongoing maintenance of welds. It is not typically the source of industry inspection activities regarding welds. EPRI NP-5380 does not address operating inspections of welds. EPRI See NRC Dis

Comment G-XTable B.2.9-3.
April 2001 B.2.9-47 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S6-3 (cont.) NEI 96-03.” NP-5380 provides guidelines for construction. The document states that cracks are not permitted. Information on welds should not be identified here. G-XI.S6-4 XI-S6 Evaluation & Technical Basis (7) Change to “The Structures Monitoring Program should be conducted under 10 CFR 50 Appendix B (Quality Assurance) for Corrective Action, or an existing quality assurance program developed for the Maintenance Rule Program.” Reg. Guide 1.160 Revision 2 recognizes that the Maintenance Rule program includes non-safety related structures and does not require that the licensee develop paper work for BOP to meet the requirements of 10 CFR 50 Appendix B requirements. Non-safety re

components tfunction, in accriteria providare within the management components ian applicant’s Program, 10 Capplies. In adQA programs Maintenance be evaluated GALL. To refeAttributes (7), addressed by 10 CFR Part Alternatively, applicant has a plant-specifaddressing thdescribed in tGALL report. GALL XI.S6 waddress this c
NUREG-1739 B.2.9-48 April 2001 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S6-5 XI-S6 Evaluation & Technical Basis (8) Change to “The Structures Monitoring Program should be conducted under 10 CFR 50 Appendix B (Quality Assurance), for Confirmation, or an existing quality assurance program developed for the Maintenance Rule Program.” Reg. Guide 1.160 Revision 2 recognizes that the Maintenance Rule program includes non-safety related structures and does not require that the licensee develop paper work for BOP to meet the requirements of 10 CFR 50 Appendix B requirements. See NRC Dis

Comment G-XAppendix B, T

G-XI.S6-6 XI-S6 Evaluation & Technical Basis (9) Change to “The Structures Monitoring Program should be conducted under 10 CFR 50 Appendix B (Quality Assurance), for Administrative Controls, or an existing quality assurance program developed for the Maintenance Rule Program.” Reg. Guide 1.160 Revision 2 recognizes that the Maintenance Rule program includes non-safety related structures and does not require that the licensee develop paper work for BOP to meet the requirements of 10 CFR 50 Appendix B requirements. See NRC Dis

Comment G-XAppendix B, T

G-XI.S7-1 Page XI.S7 Add the following Note to the end of the “Introduction” Section: “For plants not committed to RG 1.127, inspection of Water-Control Structures should be inspected under the Maintenance Rule Structural Monitoring Program.” The NRC should recognize that some of the older plants are not committed to RG 1.127 under their CLB. Therefore, applicable water- control structures would be inspected under the Maintenance Rule Structural Monitoring Program. Aging manag

structures undmonitoring princlude the atXI.S7 to adopconclusion fosentence has Program Desplants not comwater-control included in thProgram (XI.Spertaining to ware to incorpodescribed herGALL XI.S7 wthis comment
April 2001 B.2.9-49 NUREG-1739 Table B.2.9-3: Disposition of NEI Structural Comments on Chapter XI of GALL Report (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

G-XI.S7-2 Page XI.S7 Change the second sentence under Item (6) “Acceptance Criteria” to read as follows: “Although not required, acceptance criteria based on the ‘Evaluation Criteria’ provided in Chapter 5 of ACI 349.3R are acceptable as an option. ACI 349.3R is not mandatory since this document is not part of the Current Licensing Basis of most operating plants.” Item (6) “Acceptance Criteria” identifies ACI 349.3R as an acceptable standard for acceptance criteria to determine the adequacy of observed aging effects for water- control concrete structures. Although Industry does not object to using this standard as a reference, the NRC should recognize that it is not identified within the CLB for operating plants, and therefore should not be considered as a mandatory standard for RG 1.127 inspections under License Renewal. GALL XI.S7, 

Acceptance Crevised to indrequired, Chaprovides acceacceptable. GALL XI.S7 wthis comment

G-XI.S8-1 Page XI.S23 Delete the Protective Coating Monitoring and Maintenance Program. This Aging Management Program is not credited for loss of material due to corrosion of steel. This AMP can 

managing loscorrosion of cinside containDisposition of 10 in AppendGALL XI.S8 waddress this c
NUREG-1739 B.2.9-50 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.10

DISPOSITION OF NEI COMMENTS

ON CHAPTER 1 OF SRP-LR
B.2.10-ii

This Page Intentionally Left Blank
April 2001 B.2.10-1 NUREG-1739 Table B.2.10: Disposition of NEI Comments on Chapter 1 of SRP-LR Comment Number Item Number Comment/Proposed Change Basis For Comment NR

S-1-1 B.3.7 General NEI 95-10 should be added as a reference in each section. This provides the reviewer with insight to the industry recommended process. The SRP-LR 

95-10, as appSRP-LR was comment by to NEI 95-10 

S-1-2 B.3.7 1.1.3.2 This section should include the 20-year criteria of 1.1.2.2. Consistency. 10 CFR 54.1

application fobe submitted before expiraoperating liceacceptance odocketing. Thprovision of 1not affect the sufficient appAn applicatiodocketing witoperation remcurrent licenswithin 10 CFoperation beyperiod if the scomplete woThe SRP-LR this commenclarifying the and Table 1.

S-1-3 B.3.7 Table 1.1-1 In Item I.4 the 20-year criteria should be moved to Item II Timeliness Provision. Consistency. See NRC dis

comment S-1Table B.2.10
NUREG-1739 B.2.10-2 April 2001 Table B.2.10: Disposition of NEI Comments on Chapter 1 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

S-1-4 B.3.7 Table 1.1-1 Delete III.1.A.a.and b. III.1.A.is adequate and consistent with rule requirements. The sufficiency review should verify compliance with the regulation only. Items III.1.A.

retained in Tadescriptions boundaries fostructures disItem III.1.A.arequired by 1NRC staff anwith the first have establisinformation is verify the comacceptability structures anto an AMR (Tmethod used (Table III.1.BThe SRP-LR this commenclarifying the and Table 1.

S-1-5 B.3.7 Table 1.1-1 Revise Table 1.1-1, Section III.1.C.b. to read: “Identification of aging effects requiring management based on materials, environment, operating experience, etc.” Section III.1.C.b. states “Identification of applicable aging effects based on materials, environment, operating experience, etc.” An “applicable aging effect” is not defined. Suggest substituting the term “aging effects requiring management” as used in NEI 95-10. See NRC dis

comment SATable B.2.14
APPENDIX B, TABLE B.2.11

DISPOSITION OF NEI COMMENTS

ON CHAPTER 2 OF SRP-LR
B.2.11-ii

This Page Intentionally Left Blank
April 2001 B.2.11-1 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-1 General NEI 95-10 should be added as a reference in each section. This provides the reviewer with insight to the industry recommended process. NEI 95-10 is i

in the SRP-LR“Scoping and Methodology.The SRP-LR address this c

S-2-2 2.1.3 Item 3 In the second sentence replace “accident” with “events.” Remove the sentence beginning with “however, events such as fire,” and the next sentence and replace with “Design basis events are defined as conditions of normal operations, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure the functions in 54.4(a)(1). See the Branch Technical position beginning on page A.1-1 of the SRP-LR, specifically the design basis event discussion on page A.1-2 in the second paragraph of item 6.” Events not specifically identified in 50.49(b)(1)(ii) are listed – fire, floods, storms, earthquakes, tornadoes and hurricanes. The paragraph should correlate exactly with the definition in 50.49(b)(1)(ii). Additionally SSCs required for compliance with the commission’s regulations for fire protection are in scope under 54.4(a)(3). The word “ac

by the word “epopulation of would be a su50.49(b)(1)(ii)earthquakes, hurricanes ar

design basis anticipated opcurrently used not addressed (Accident Anaconsistent wit§50.49(b)(1)(The SRP-LR, bulleted-paraaddress this cabove paragr

S-2-3 2.1.3 Delete item 4. The LR Rule is deterministic not probabilistic. In 60FR22468: “... [The Commission concludes that it is inappropriate to establish a licensee renewal scoping criterion... that relies on plant-specific probabilistic analyses. Therefore, within the construct of the final rule, PRA techniques are of very limited use for license renewal scoping.” While the LR 

the CommissRule also statprobabilistic museful, on a phelping to assimportance of components taging managehelping to dra
NUREG-1739 B.2.11-2 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-3 (cont.) Further, the guidance in item 4 focuses on drawing “ attention to specific vulnerabilities (e.g. results of an IPE or IPEEE).” These evaluations are not parts of the CLB. Staff review of these documents may not provide the information it is seeking. The IPE and IPEEE reports reflect the estimated core damage frequency for the plant configuration at the time the evaluation is performed. These reports also may contain recommendations to modify the plant, revise procedures, or develop training to further reduce the estimated core damage frequency. Some plant modifications may reduce the frequency of initiating events and others may improve the reliability of credited mitigation systems. The IPE and IPEEE reports do not change the CLB by themselves. The plants must perform complete 50.59 reviews and may or may not implement the recommended modifications. Those modifications that are implemented will be reflected in plant drawings, FSAR changes, or technical specification changes, as appropriate. The staff is already reviewing these latter documents, which provide more current information than that which may be contained in the IPE and IPEEE reports. vulnerabilities 

or IPEEE).” addresses the paragraph in SRP-LR whic

the reviewer ainformation athe applicant’The SRP-LR address this c
April 2001 B.2.11-3 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-4 2.1.3 Delete item 5. The LR Rule is deterministic not probabilistic. In 60FR22468: “... [The Commission concludes that it is inappropriate to establish a licensee renewal scoping criterion... that relies on plant-specific probabilistic analyses. Therefore, within the construct of the final rule, PRA techniques are of very limited use for license renewal scoping.” Staff review of the probabilistic documents may not provide the information it is seeking. The IPE and IPEEE reports reflect the estimated core damage frequency for the plant configuration at the time the evaluation is performed. These reports also may contain recommendations to modify the plant, revise procedures, or develop training to further reduce the estimated core damage frequency. Some plant modifications may reduce the frequency of initiating events and others may improve the reliability of credited mitigation systems. The IPE and IPEEE reports do not change the CLB by themselves. The plants must perform complete 50.59 reviews and may or may not implement the recommended modifications. Those modifications that are implemented will be reflected in plant drawings, FSAR changes, or technical specification changes, as See NRC disp

comment S-2Table B.2.11.
NUREG-1739 B.2.11-4 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-4 (cont.) appropriate. The staff is already reviewing these latter documents which provide more current information than that which may be contained in the IPE and IPEEE reports. S-2-5 2.1.3.1 Add the following as the last sentence in the first paragraph of 2.1.3.1: “Usually plants will already have a list of those systems, structures, and components identified for compliance with other regulations in the plants CLB that contain identical scoping criteria, such as NRC Regulatory Guide 1.29 or 10CFR100, Appendix A.” This change gives credit to work already completed by the applicant and reviewed and approved by the NRC under 10 CFR Part 50. Such credit would make the staff review more efficient. The NRC staff indicated agreement with a change containing this concept at a public meeting about the SRP-LR on July 18, 2000. LR applicants 

existing lists ocompliance wdemonstrate have been saThe SRP-LR, revised to addadding a sent

paragraph. S-2-6 2.1.3.1.2 Revise the last paragraph of Section 2.1.3.1.2 to read: “It is important to note that the scoping criterion under 10 CFR 54.4(a)(2) specifically applies to those functions ‘identified in paragraph (a)(1)(i), (ii), and (iii)’ of 10 CFR 54.4 and does not apply to those functions identified in 10 CFR 54.4(a)(3).” The last paragraph states, “On the basis of the staff’s experience to date, it is important to clarify that the scoping criterion under 10 CFR 54.4(a)(2) specifically applies to those functions ‘identified in paragraph (a)(1)(i), (ii), and (iii)’ of 10 CFR 54.4. An applicant need not extend this requirement to the scoping criteria under 10 CFR 54.4(a)(3), as is discussed below.” The way this is written (On the basis of the staff’s experience...) it implies that staff judgement was necessary to determine that §54.4(a)(2) does not apply to §54.4(a)(3) and that based on staff judgement this could The rule as w

the scoping re54.4(a)(2) do extended into 10 CFR 54.4(The SRP-LR, was revised tcomment by rparagraph.
April 2001 B.2.11-5 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-6 (cont.) change (...to date...) in the future. As the regulation is clear, there is no judgement necessary. S-2-7 2.1.3.1.3 In the third paragraph remove “and operate within.” Also in the fifth paragraph remove “or operation within.” The regulation does not state “demonstrate compliance with and operation within the Commission’s regulations.” 10 CFR 50.54

the scope of ton in safety aevaluations to that demonstthe Commissthe five specifThe SRP-LR, 

and 5th parag

address this cwording with t

S-2-8 2.1.3.1.3 In the third full paragraph excluding the quote, remove “based on the applicant’s design specifications for the diesel,” The example in this paragraph regarding the diesel goes beyond the rule and conflicts with other sections of the SRP-LR when it refers to the design specifications for the diesel. The 3rd paragraph further down has more appropriate wording,”that is, whose functions were credited in the analysis or evaluation.” See NRC disp

comment S-2Section B.2.1The SRP-LR, 

full paragraph address this cwording with t

S-2-9 2.1.3.1.3 Restate the third sentence of fifth paragraph to read: “For example, if a nonsafety-related diesel generator is only relied upon to remain functional to demonstrate compliance with the Commission SBO regulations, an applicant need not consider the following SSCs:” This comment clarifies provides a firmer statement. See NRC disp

comment S-2Table B.2.11. The SRP-LR, 

paragraph wathis comment with that of th
NUREG-1739 B.2.11-6 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2–10 2.1.3.2.1 Revise the last paragraph of Section 2.1.3.2.1 to read: “10 CFR 54.21(a)(1)(i) explicitly excludes instrumentation, such as pressure transmitters, pressure indicators, and water level indicators, from an aging management review. The applicant does not have to identify pressure retaining boundaries of this instrumentation because 10 CFR §54.21(a)(1)(i) excludes this instrumentation without exception, unlike pumps and valves. Further, instrumentation is sensitive equipment and degradation of the pressure retaining boundary of the instrumentation would be readily determinable by the extensive surveillance and testing. If an applicant determines that certain structures and components listed in Table 2.1-5 as meeting 10 CFR 54.21(a)(1)(i) does not meet that requirement for its plant, the reviewer reviews the applicant’s basis for that determination. The last paragraph of Section 2.1.3.2.1 states: “10 CFR 54.21(a)(1)(i) explicitly excludes instrumentation, such as pressure transmitters, pressure indicators, and water level indicators, from an aging management review. If an applicant determines that certain structures and components listed in Table 2.1- 5 as meeting 10 CFR 54.21(a)(1)(i) do not meet that requirement for its plant, the reviewer reviews the applicant’s basis for that determination.” The same paragraph in the SRP-LR Working Draft, September 1997, stated: “10 CFR 54.21(a)(1)(i) explicitly excludes instrumentation, such as pressure transmitters, pressure indicators, and water level indicators, from an aging management review. The applicant does not have to identify pressure retaining boundaries of this instrumentation because 10 CFR §54.21(a)(1)(i) excludes this instrumentation without exception, unlike pumps and valves. Further, instrumentation is sensitive equipment and degradation of the pressure retaining boundary of the instrumentation would be readily determinable by the extensive surveillance and testing.” Instrumentatio

transmitters, and water levexcluded from aging manageCFR 54.21(a)pressure retahave to be ideposition since determined by surveillance aThe SRP-LR, paragraph wathis comment with that of th
April 2001 B.2.11-7 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2–10 (cont.) REFERENCE: Letter from Dennis M. Crutchfield of NRC to Charles H. Cruse of Baltimore Gas and Electric, dated April 4, 1996. This documented NRC position taken regarding instrumentation would be helpful for future NRC reviewers and should be retained in the SRP-LR. S-2-11 Table 2.1-1 Delete “Probabilistic Risk Assessment summary report.” The LR Rule is deterministic not probabilistic. In 60FR22468: “... [The Commission concludes that it is inappropriate to establish a licensee renewal scoping criterion... that relies on plant-specific probabilistic analyses. Therefore, within the construct of the final rule, PRA techniques are of very limited use for license renewal scoping.” The PRA is not part of the CLB. Staff review of this document may not provide the information it is seeking. The PRA report reflects the estimated core damage frequency for the plant configuration at the time the evaluation is performed. This report also may contain recommendations to modify the plant, revise procedures, or develop training to further reduce the estimated core damage frequency. Some plant modifications may reduce the frequency of initiating events and others may improve the reliability of credited mitigation See NRC disp

comment S-2Table B.2.11.
NUREG-1739 B.2.11-8 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-11 (cont.) systems. The PRA report does not change the CLB by themselves. The plants must perform complete 50.59 reviews and may or may not implement the recommended modifications. Those modifications that are implemented will be reflected in plant drawings, FSAR changes, or technical specification changes, as appropriate. The staff is already reviewing these latter documents, which provide more current information than that which may be contained in the PRA report. S-2-12 Table 2.1-1 Delete “Emergency operating procedures.” EOPs are not sources of information regarding evaluations or analyses for design basis events or regulated events. EOPs were d

analyzed plan

and accidents NUREG-0737requirementssome transiennot bound by EOPs nonethvaluable sourregarding botits design basThe SRP-LR address this c
April 2001 B.2.11-9 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2–13 Table 2.1-2 Revise the third sentence under Commodity Groups to read: “The basis for grouping structures and components can be determined by such characteristics as similar function, similar design, similar materials of construction, similar aging management practices, or similar environments.” Sentence 3 does not consider a grouping based on similar function. Function is a valid basis for grouping as this is the basis for all electrical commodity groups in SRP-LR Table 2.1-5. Grouping com

similar to that based on deswith function their intended of their assocThe SRP-LR, revised to addrevising the liGroups to inccomponents b

S-2-14 Table 2.1-2 Remove the reference to NUREG 1723 in the Complex assemblies row. The staff could add an example of complex assemblies from NUREG 1705, Section 2.2.3.22.2.2. Although NUR

complex assein Appendix C Revision 0, beevaluation guSRP-LR TablSection 4.1.1The SRP-LR, revised to add

S-2-15 Table 2.1-4 Reword the fifth function as “Provide electrical connections to specified sections of an electrical circuit to deliver voltage, current or signals.” This provides a more accurate description of the function of cable. Clarification o

electrical cabThe SRP-LR, function underevised to addnoted. S-2–16 Table 2.1-5 Delete motor items 65 and 66. These motors are examples of the motor commodity group and are already included in the Motors, Generators commodity group. Inconsistency 

10, Rev. 3. The SRP-LR revised to addadopting NEI 
NUREG-1739 B.2.11-10 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-17 Table 2.1-5 Remove entry 107 for terminal blocks. Entry 77 should say “Annunciators” and Entry 98 should say “Regulators” The notes regarding references for entries 83, 86, 92, 105 should refer to NRC letters, which provided the passive/active determination for these components. For entry 83 it should be letters from C.I. Grimes to D.J. Walters dated September 19, 1997and November 19, 1999. For entry 86 it should be the letter from C.I. Grimes to D.J. Walters dated April 27, 1999. For entry 92 it should be the letter from C.I. Grimes to D.J. Walters dated September 19, 1997. For entry 105 it should be the letter from C.I. Grimes to D.J. Walters dated September 19, 1997. Terminal blocks are included in entry 79. The second comment corrects the table. The third clarifies references. See NRC disp

comment S-2Table B.2.11. S-2-18 Table 2.1-5 Revise this Item 89 to read: “Surge Arresters (e.g., switchyard surge arresters, lightning arresters, surge suppressers, surge capacitors, protective capacitors, reactors)” Surge arresters that are separate components have applications other than just high-voltage. Suggest dropping “High-voltage” from the name of the commodity group. In continuing license renewal electrical work reactors, another type of surge arrester, was identified that would be helpful to have in the list of examples. See NRC dispcomment S-2Table B.2.11.
April 2001 B.2.11-11 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-19 Table 2.1-5 Change Item 96 to read: “Radiation Monitors (e.g., area radiation monitors, process radiation monitors)” and change the passive determination to “No”. Change Item 85 to read: “Elements, RTDs, Sensors, Thermocouples, Transducers (e.g., conductivity elements, flow elements, temperature sensors, radiation sensors, watt transducers, thermocouples, RTDs, vibration probes, amp transducers, frequency transducers, power factor transducers, speed transducers, var. transducers, vibration transducers, voltage transducers)” Change Item 106 to read: “Transmitters (e.g., differential pressure transmitters, pressure transmitters, flow transmitters, level transmitters, radiation transmitters, static pressure transmitters)” The original SRP-LR table had the three items; Radiation Sensors, Radiation Monitors and Radiation Transmitters listed as separate items. Radiation Sensors was the only item associated with a pressure boundary in the table. Combining these three separate items is not consistent with the rest of the table under Electrical and I&C in combining into commodity groups. See NRC disp

comment S-2Table B.2.11.
NUREG-1739 B.2.11-12 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2–20 2.2.3 Revise second sentence of Section 2.2.3, Paragraph 1 to read: “Should the reviewer request additional information from the applicant regarding why a certain system or structure was not identified by the applicant as within the scope of license renewal for the applicant’s plant, the reviewer should provide a plant specific CLB reference and the specific scoping criterion under which the reviewer believes the system or structure scopes in.” The second sentence of Section 2.2.3, Paragraph 1 states: “Should the reviewer request additional information from the applicant regarding why a certain system or structure was not identified by the applicant as within the scope of license renewal for the applicant’s plant, the reviewer should provide a brief description of why the reviewer believes that this particular system or structure could be potentially within the scope of license renewal.” The above guidance of providing a brief statement is vague and may not prevent an applicant from having to “prove the negative”. The “brief statement” guidance should be expanded to instruct the reviewer to provide a plant specific CLB reference for the system and the specific scoping criterion under which the reviewer believes the system scopes in. It is the responsibility of the reviewer to explain why they believe a specific system or structure that the applicant scoped out is in the scope of license renewal. If the reviewe

certain system within scope irequests addithe applicant provide the apdescription of viewed as witlicense renewThe SRP-LR, 

paragraph wathis comment
April 2001 B.2.11-13 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-21 2.2.3.1 The last three full paragraphs: these were added since last draft and refer to components, rather than systems and structures. They seem out of place. They should go in the screening section. If the intention was to add these paragraphs here, they should refer to systems and structures. Consistency with the purpose of the section. This section o

concerned wistructures not word “compo“systems and The SRP-LR, was revised tcomment by cthird from the noted and dethe last parag

S-2-22 2.3.3.1 Remove this section. This change makes this section consistent with 2.4. The Rule does not require an applicant to identify structures and components in the scope of license renewal in an application. An application must contain an identification of structures and components that require aging management review. Please see pages 60 and 61 of NEI 95-10, revision 2, for industry guidance regarding contents of the Scoping and Screening sections of a License Renewal Application. The SRP-LR should focus on the actual expected contents of an application. Clarification o

regard to the structures and identified in aThe SRP-LR this comment to be consisterevising subsSection 2.3 tthe comment
NUREG-1739 B.2.11-14 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-23 2.3.3.2 In the first paragraph remove the second sentence. A license renewal application will not contain a list of components in the scope of license renewal. Please see pages 60 and 61 of NEI 95-10, revision 2, for industry guidance regarding contents of the Scoping and Screening sections of a License Renewal Application. The SRP-LR should focus on the actual expected contents of an application. Clarification o

regard to the structures and identified in aThe SRP-LR, revised to addeliminating ththird sentence Section 2.4 to Section 2.3. S-2-24 2.3.3.2 Paragraph 2 states “Although Table 2.1-5 is extensive, it is not all inclusive. Thus, the reviewer should use other available information sources, such as prior application reviews, to determine whether a component is subject to an aging management review.” Sections 2.4 and 2.5 do not contain these words. This statement should be removed from Section 2.3. A combination of Table 2.1-5 and other NRC guidance should be sufficient. Inclusion of a component by a license renewal applicant is not indicative of the need for a following applicant to include a similar component as the current licensing bases and scoping and screening methodologies of the two applicants may be different. Scoping is plaon a plant’s Cfor a different be different in components iit under the ruThe SRP-LR, revised to addrevising the 2replacing the and by adding Sections 2.4 a

S-2-25 2.5.1 Remove the third paragraph as system level scoping is addressed in section 2.2. The third paragraph reiterates information already provided in section 2.2. This section is addressing components requiring aging management review; therefore, this paragraph is not needed for the reviewer. Section 2.5 is 

and has a diffSection 2.2, tis not a mere in Section 2.2The SRP-LR address this c
April 2001 B.2.11-15 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-26 2.5.1 In the fourth paragraph indicate that the “plant spaces” approach may be used. It is not required. The License Renewal Rule does not require use of SAND96-0344. An applicant may use another method that complies with rule requirements. An applicant m

meet the requincluding the approach. The SRP-LR, 

paragraph wathis comment “an applicant may”. S-2-27 2.5.1 Revise the last sentence of the fifth paragraph to read: “For the above example, if the applicant identified elevated temperatures in a particular area within the turbine building, the applicant may elect to further refine the scope in this particular area by identifying electrical equipment that is not subject to an aging management review and excluding this equipment from the aging management review. In this case, the excluded electrical equipment would be reported in the application as not subject to an aging management review.” (Colaianni, Duke) The last sentence in Section 2.5.1, paragraph 5, does not follow the way scoping in a specific area would be reported in the application when using the plant spaces approach. The space approach starts with the assumption that all passive long- lived electrical and I&C components subject to an aging management review. During the aging management review when a plant area that could be adverse to equipment is identified, the specific equipment in the area is identified in order to eliminate all equipment that does not meet the scoping criteria. In most cases this eliminates all electrical equipment in the area from the scope of review. Since a scoping evaluation was performed to exclude equipment from the aging management review, the excluded equipment would be reported in the application in a manner such as, “All non-EQ cables and connections are subject to an aging management The example 

did not propespaces’ approThe SRP-LR, 

paragraph wathis comment sentence.
NUREG-1739 B.2.11-16 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-27 (cont.) review excluding cables and connections used for the nonsafety- related thermocouples in the in-core instrumentation system.” S-2-29 2.5.1.1 and 2.5.1.2 Delete Sections 2.5.1.1 and 2.5.1.2. Also delete the sentence before 2.5.1.1. Sections 2.5.1.1 and 2.5.1.2 are not duplicated in the Mechanical Systems and Structures sections (2.3 and 2.4 respectively) and it seems to be a duplication of the material covered in Section 2.5.3, Review Procedures. Clarification o

to be consisteand 2.4.. The SRP-LR, 2.5.1.2 were rcomment by dand the senteSection 2.5.1

S-2-30 2.5.3 Revise the third paragraph to read: “Equipment in the EQ (10 CFR 50.49) program has a qualified life and is replaced at the end of its qualified life. With a qualified life, EQ equipment does not meet the ‘long- lived’ screening criteria and is not subject to an aging management review. However, the qualified life analyses that provide the basis for a 40-year or greater qualified life are TLAAs for license renewal. The staff reviews the applicant’s EQ TLAA evaluation separately following the guidance in Section 4.4 of this standard review plan.” “The scope of 10 CFR 50.49 electric equipment to be included within 10 CFR 54.4(a)(3) is that ‘long-lived’ (qualified life of 40-years or greater) equipment already identified by licensees under 10 CFR 50.49(b), which specifies certain electric equipment important to safety.” The scope of §50.49 (EQ) equipment to be included within §54.4(a)(3) is all EQ equipment, not just EQ equipment with a 40-year or greater qualified life. The sentence implies that the ‘long- lived’ screening criteria applies only to SSCs that are subject to replacement based on a qualified life or specified time period equal to or greater than 40 years. There is no basis for this limitation of the §54.21(a)(1)(ii) criteria in either 10 The SRP-LR, 

paragraph is intent of 10 CThe SRP-LR address this c
April 2001 B.2.11-17 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-30 (cont.) CFR 54 or in the accompanying Statement of Considerations. “An applicant may identify EQ equipment separately for TLAA evaluation and not include such equipment as subject to an aging management review under 10 CFR 54.21(a)(1).” Equipment in the EQ program has a qualified life and is replaced at the end of its qualified life. With a qualified life EQ equipment does not meet the long-lived screening criteria and is not subject to an AMR. The sentence is misleading in that no EQ equipment is required to be included in the list of components subject to an AMR. Much of the information in this paragraph is TLAA evaluation specific and may confuse future reviewers as to the difference between ‘long-lived’ screening and TLAA evolution regarding EQ equipment.
NUREG-1739 B.2.11-18 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S-2-31 2.5.3.1 Revise this section. This change makes this section consistent with 2.4 and 2.3 as revised. The Rule does not require an applicant to identify structures and components in the scope of license renewal in an application. An application must contain an identification of structures and components that require aging management review. See NRC dis

comment S-2Section B.2.1The SRP-LR this comment 2.5.3.1 consisand 2.4. S-2-32 2.5.3.2 Delete the last sentence of paragraph 2, Section 2.5.3.2. The last sentence of paragraph 3 states, “An applicant should justify omitting a component that is within scope of license renewal at their facility and is listed as ‘passive’ in Table 2.1-5.” This information is not required by 10 CFR 54 to be provided in the application, but would be available for on-site inspection at the applicant’s facility. An applicant is required to list in the application components subject to an aging management review and describe and justify the methodology, but not to justify why any specific component is not subject to an aging management review. The informatirequired by 10 on-site. The SRP-LR, paragraph wathis comment sentence.
April 2001 B.2.11-19 NUREG-1739 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC D

S-2-33 2.1.2 Second bullet: should say “systems, structures, and components” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-34 2.1.3.2.2 The quote from the SOC should in the middle read “... with a specified time period is deemed ...” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-35 2.1.6 Reference 11 is a duplicate of reference 8. Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-36 Table 2.1-3 Change column heading “Subject” to “Issue.” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-37 2.2.3.1 The fourth full paragraph says “internal functions”, should instead say “intended functions.” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-38 2.2.3.1 In the sixth paragraph beginning “An applicant may...” Insert “that” between “indicating” and “the” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-39 2.3.1 In the fifth paragraph beginning “Mechanical components...” delete “(or must).” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 
NUREG-1739 B.2.11-20 April 2001 Table B.2.11: Disposition of NEI Comments on Chapter 2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC D

S-2-40 2.3.3.2 In the first paragraph the third line from end should read, “...AMR, components that perform...” Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-41 2.4.1 The items in the third bullet are components rather than structures and should be included in the sentence following the bullets. Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-42 2.4.3.1 The fourth paragraph from end and last paragraph say essentially the same thing. Editorial Comment Clarification 

consistencyThe SRP-Laddress this 

S-2-43 2.5.1 In the second paragraph insert “to” after “staff” in the fifth line from end. Editorial Comment Clarification 

consistencyThe SRP-Laddress this 
APPENDIX B, TABLE B.2.12

DISPOSITION OF NEI COMMENTS

ON CHAPTER 3 OF SRP-LR
B.2.12-ii

This Page Intentionally Left Blank
April 2001 B.2.12-1 NUREG-1739 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-1 SRP-LR 3.1 SRP-LR Section 3.1.1 Areas of Review, describes “connected systems.” Statements describing the “connected systems” should be deleted. SRP-LR 3.1 covers the aging management review of the reactor coolant systems. Connected systems are not part of the review of the reactor coolant system. The section S

reactor vessethe reactor coconnected sysystems up to containment iincluded in thClass 1 compprograms togreport. The titchanged to be GALL report. LR 3.5 was aconsistent witand III. The SRP-LR a portion of thin above para

S3.1-2 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Inservice Inspection GALL Section I applies. The presentation of the Inservice Inspection program in the GALL is different than any other program evaluated in the GALL that is relied upon for license renewal. What specifically is an applicant supposed to do that allows this program to be credited without further review? Chapter 1 of t

“Application odoes not give element inserprogram. XI.MInservice InspIWB, IWC, an1801, Vol. 2 dISI is acceptaevaluation is aevaluation coThe SRP-LR address this c
NUREG-1739 B.2.12-2 April 2001 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-3 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Water Chemistry GALL Section XI.M.11 applies. Refer to comments on Aging Management programs. See NRC disp

comments G-G-XI.M11-2 in Table B.2.9-2The SRP-LR this comment with the GALL 

S3.1-4 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Minimization and Control of SCC Delete this program from all locations in all documents. For PWRs, this topic is discussed in GALL IV.A2.1.3. Regulatory Guide 1.65 is referenced within this GALL entry. Regulatory Guide 1.65 entitled, “Materials and Inspections for Reactor Vessel Closure Studs,” which was published in 1973 was reviewed by the B&W Owners Group during the licensing of BAW- 2251, “Demonstration of the Management of Aging Effects for the Reactor Vessel.” In a letter to the NRC staff dated April 1, 1997 (Project No.683), the B&WOG addressed Regulatory Guide 1.65 in response to RAI # 14. In brief, the B&WOG concluded that all recommendations (i.e., examination methods and acceptance standards) of the RV studs in Regulatory Guide 1.65 have been superceded by the current examination requirements specified in the 1989 Edition of ASME Section XI. The examination requirements specified in ASME Section XI, Examination Category B- See NRC disp

comments G-Appendix B, TReferences to requirements Guide 1.65 wGALL report aNEI comment Appendix B aHowever, the Regulatory GGALL Chapteprograms weSRP-LR for mof SCC as a rThe SRP-LR address this c
April 2001 B.2.12-3 NUREG-1739 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-4 (cont.) G-1 are sufficient to manage that potential for IGSCC of the RV studs during the period of extended operation. S3.1-5 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Fatigue Monitoring Program GALL Section X.M1 applies. Refer to comments on Aging Management programs. The SRP-LR 

this comment monitoring prbecause it is Table 4.3-2. S3.1-6 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Bolting Integrity GALL Section XI.M.12 applies. Refer to comments on Aging Management programs. See NRC dispcomments G-G-XIM12-4 in Table B.2.9-2The SRP-LR address this c

S3.1-7 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Reactor Vessel Surveillance GALL Section XI.M.13 applies. Refer to comments on Aging Management programs. There were n

Chapter XI, pThe SRP-LR address this c

S3.1-8 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Boric Acid Corrosion GALL Section XI.M.5 applies. Refer to comments on Aging Management programs. See NRC disp

comments G-G-XIM5-2 in tTable B.2.9-2The SRP-LR this comment with the GALL 

S3.1-9 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Thermal Aging and neutron irradiation embrittlement (CASS) GALL Section XI.M.2 applies. Refer to comments on Aging Management programs. There were n

Chapter XI, pThe SRP-LR address this c
NUREG-1739 B.2.12-4 April 2001 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-10 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Flow Accelerated Corrosion GALL Section XI.M.6 applies. Refer to comments on Aging Management programs. See NRC disp

comment G-XAppendix B, TThe SRP-LR this comment with the GALL 

S3.1-11 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Quality Assurance GALL Appendix A and SRP- LR Appendix A.2 apply. Refer to comments on Aging Management programs. Quality Assur

Management Components Technical Pos(Appendix A.2 review plan.) The SRP-LR address this c

S3.1-12 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Vessel Closure Head Penetrations Delete the requirement for further review of this program in SRP- LR 3.1.2.2.7. GALL Section IV A2.2.1 applies. The applicable GALL section states “No Further Evaluation Recommended” as does Table 3.1- 1 of the SRP-LR. Actions will be taken by the applicant to address this topic within the bounds of the program. There is no fu

necessary for pressure houthe GALL rep3.1.2.2.7 does The SRP-LR address this cno further eva
April 2001 B.2.12-5 NUREG-1739 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-13 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Steam Generator Tube Integrity GALL Sections IV D1.2.1, D1.2.3, D2.2.1, and D2.2.2 apply. Refer to comments on Aging Management programs. See NRC disp

comments G-IVD1-8 in this Table B.2.3. There were nitem numbers D2.2.2 The SRP-LR this comment changes consthe Steam GeProgram. S3.1-14 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Loose Part monitoring Delete this program from all locations in all documents. ASME Section XI, Examination Category B-N-3 has been found to be acceptable to manage loss of prestress by the staff in previous reviews. (i.e., BAW-2248, NUREG- 1723). Operating experience provided in GALL IV B2.1.7 does not support the assertion that loose parts monitoring is an effective program to detect loss of preload from stress relaxation. See NRC dispcomment G-IVTable B.2.3. Iconsidered inOconee SERThe SRP-LR address this c
NUREG-1739 B.2.12-6 April 2001 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-15 SRP-LR 3.1 AMPs Evaluated in the GALL report that are Relied on for License Renewal – Neutron Noise monitoring Delete this program from all locations in all documents. ASME Section XI, Examination Category B-N-3 has been found to be acceptable to manage loss of prestress by the staff in previous reviews. (i.e., BAW-2248, NUREG- 1723). Operating experience provided in GALL IV B2.1.7 does not support the assertion that neutron noise monitoring is an effective program to detect loss of preload from stress relaxation. See NRC disp

comment G-IVTable B.2.3. Iconsidered inOconee SERThe SRP-LR address this c

S3.1-16 SRP-LR 3.1 SRP-LR 3.1.2.2.2 addresses loss of material due to pitting and crevice corrosion in the steam generator shell assembly and refers to IN 90- 04. GALL Sections (IV D1.1.3, 1.1.4, 2.1.4) apply. This requirement should be deleted. IN 90-04, Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Generators was issued to alert licensees to problems related to cracking of the upper shell-to-transition cone girth welds in certain steam generators. The aging mechanism is related to the weld itself. The cracking was found during a scheduled ISI. While a common factor was general corrosion pitting on the inside surface of the SGs, the cracks were initiated at the welds not in the base metal. IN 90-04 does not appear to support the GALL/SRP-LR conclusion that further evaluation is necessary. General corrosion pitting of base metal remote from the weld is not likely to result in a loss of component intended function. See NRC disp

comment GIV Appendix B, TThe SRP-LR address this c
April 2001 B.2.12-7 NUREG-1739 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-17 SRP-LR 3.1 SRP-LR 3.1.2.2.3, 2nd paragraph should be revised to read as follows: “Appendix H of 10 CFR 50, Section III.B.3 requires staff review of the plant surveillance program for the period of licensed operation.” While it is true that the GALL recommends staff approval, the more correct reason is that such review and approval is required by the regulations. Staff review is 

surveillance plicensed operThe SRP-LR this comment 3.1.2.2.3, seccomment. S3.1-18 SRP-LR 3.1 SRP-LR 3.1.2.2.3, 3rd paragraph states that the GALL report recommends an enhanced inservice inspection to detect tight cracks and supplemental examinations for crevice regions of reactor pressure vessel beltline shell and nozzles. Contrary to what the SRP-LR states, there are no such recommendations in the GALL report. This statement should be deleted. The pertinent GALL report locations for the reactor vessel beltline shell and nozzles are IV.A2.5 and IV A2.3. Both sections address loss of fracture toughness. Neither section identified the recommendation for further evaluation nor the basis for such an issue. The third para

LR 3.1.2.2.3 renhanced ISI examinations with GALL anTherefore, the removed from consistent witThe SRP-LR this comment

S3.1-19 SRP-LR 3.1 SRP-LR 3.1.2.2.4 states that unanticipated thermal and mechanical loading can cause crack initiation and growth. This requirement should be deleted. SRP-LR A.1.2.1 discusses the process to determine applicable aging effects. Item number 6 specifically states that “abnormal events need not be postulated specifically for license renewal.” Unanticipated thermal and mechanical loading is an abnormal event that is outside the design of the plant. See NRC disp

comments G-G-IVC2-5 in ATable B.2.3. GALL was revwording “unanthermal and mThe SRP-LR, revised to addconsistent witGALL report.
NUREG-1739 B.2.12-8 April 2001 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-20 SRP-LR 3.1 SRP-LR Sections 3.1.2.2.4 and 3.1.2.2.7 SRP-LR States that GALL recommends enhanced inspection and one-time inspections for small bore piping. The statement needs to be revised to state: GALL recommends one-time inspections for small bore piping. GALL Chapter IV item C2.1.5 applies to this comment. This GALL section does not recommend enhanced inspections. It only recommends the one-time inspection. The words “e

were removed on Page C2-9under “Aging Programs.” A destructive exnondestructivthat permits insurfaces of thconducted to has not occurcomponent inmaintained duperiod is the rGALL for smaThe SRP-LR, 3.1.2.2.7, werthis comment

S3.1-21 SRP-LR 3.1 Section 3.1.2.2.7 indicates that further evaluation is recommended of CRD nozzles (page 3.1-5). This statement should be deleted. GALL IV A2.2.1 also indicates that there are actions for the applicant to take but that no further evaluation is recommended by the staff. Also Table 3.1-1, PWR, CRD nozzle item (page 3.1-20) indicates that no further evaluation is recommended. Program M11

and PenetratiChapter XI of that meets threquired to prevaluation. Tamodified to reexisting progrThe SRP-LR this comment
April 2001 B.2.12-9 NUREG-1739 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-22 SRP-LR 3.1 Section 3.1.2.2.7 indicates that further evaluation is required to address the potential for cracking of cladding remote from the welds (GALL D1.1.9). This statement needs to be deleted. The GALL basis for this requirement relies inappropriately on inadvertent introduction of contaminants into the RCS. This activity is an abnormal event and need not be specifically postulated for license renewal unless the event has occurred at the plant. (SRP-LR A.1.2.1) Welds and the heat-affects zones adjacent to them are inspected because they are known to be the leading indicator of potential cracks. The consideration of potential cracks beyond the welds and HAZ is not required in order to provide reasonable assurance that the intended functions will be maintained during the period of extended operation. It is true that S

item 6, indicafrom abnormapostulated splicense renewabnormal eveparticular planthe aging effecomponents fshould be conFor example, occurred in thsystem at a pcontribution oevent to aging for that plant. The SRP-LR this comment

S3.1-23 SRP-LR 3.1 Sections 3.1.3.2.2, 3.1.3.2.3, 3.1.3.2.4 and 3.1.3.2.7 need to be revised to be consistent with the equivalent revisions to the 3.1.2 sections listed above. Conforming changes, technical justification provided above. This is a conf

SRP-LR, sectto address thiit consistent wSRP-LR secti
NUREG-1739 B.2.12-10 April 2001 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-24 SRP-LR 3.1 Table 3.1-1 should be revised to include the specific GALL sections that apply to the specific component group. Merge Table 1 of GALL Volume 1 with Table 3.3-1. See Generic comments covering all aging management program summary tables. Table 1 of GA

designed as a assist the appcomponents iTable 3.1-1 wreference to twas determinnot desired. The SRP-LR address this c

S3.1-25 SRP-LR 3.1 Table 3.1-1, BWR/PWR, Reactor vessel beltline shell and welds item (page 3.1-16): Revise “Aging Management Program” entry to be “Plant Specific.” Revise “Further Evaluation Recommended” entry to be “Yes, staff review of plant reactor vessel surveillance program required (see subsection 3.1.2.2.3).” Proposed change makes entry consistent with proposed change to subsection 3.1.2.2.3. Table 3.1-1 w

with subsectioThe SRP-LR this comment consistent in 

S3.1-26 SRP-LR 3.1 Table 3.1-1, PWR, Primary Nozzles and Safe Ends (page 3.1-18), delete further revaluation item consistent with comments provided above. Technical justification provided above. Program M11

and PenetratiChapter XI of that meets threquired to prevaluation. Tawere also mois an existing The SRP-LR this comment
April 2001 B.2.12-11 NUREG-1739 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-27 SRP-LR 3.1 Table 3.1-1, BWR/PWR, Reactor Vessel closure studs and stud assembly item (page 3.1-18): Under the “Aging Management Programs” delete “Minimization and control of SCC” consistent with comments provided above. Technical justification provided above. Tables 3.1-1 

consistent witand/or the GAThe GALL repwere revised comment. S3.1-28 SRP-LR 3.1 Table 3.1-1, PWR, Upper and lower internals assembly (Westinghouse) item (page 3.1-21). Credit for neutron noise monitoring program should be deleted. Technical justification provided above. Tables 3.1-1 consistent witand/or the GAThe GALL repwere not reviscomment. S3.1-29 SRP-LR 3.1 Table 3.1-1, PWR, Upper and lower internals assembly (Westinghouse) item (page 3.1-21). Credit for loose part monitoring program should be deleted. Technical justification provided above. Table 3.1-1 awith section 3GALL report. The GALL repwere not reviscomment. S3.1-30 SRP-LR 3.1 Table 3.1-2, delete the “Minimization and control of SCC” program summary (page 3.1-22). Conforming change to proposed change noted above. Tables 3.1-1 consistent witand/or GALL. The GALL repwere not reviscomment. S3.1-31 SRP-LR 3.1 Table 3.1-2, delete the “Loose part monitoring” program summary (page 3.1-26). Conforming change to proposed change noted above. Tables 3.1-1 consistent witand/or the GAThe GALL repwere not reviscomment.
NUREG-1739 B.2.12-12 April 2001 Table B.2.12-1: Disposition of NEI Comments on Chapter 3, Section 3.1, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.1-32 SRP-LR 3.1 Table 3.1-2, delete the “Neutron noise monitoring” program summary (page 3.1-26). Conforming change to proposed change noted above. Tables 3.1-1 

consistent witand/or the GAThe GALL repwere not reviscomment. S3.1-33 SRP-LR 3.1 Table 3.1-2, delete summary of Steam Generator Tube Integrity program as this program is already required by technical specifications. Technical specifications are part of the facility operating license and are approved and issued by the NRC staff. A description of the Steam Generator Tube Integrity program is contained in Chapter 5 of the facility technical specifications. Due to the hierarchy of regulatory documents, requirements contained in the technical specifications supercede any statements contained in the FSAR. A tube integriadded to Chareport, that inrequirements Specification. 3.1-2 were mwording in SRand/or the GAThe GALL repwere revised comment.
April 2001 B.2.12-13 NUREG-1739 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-1 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Bolting Integrity GALL Section XI.M.12 applies. Refer to comments on Aging Management programs. See NRC disp

comments G-G-XIM12-4 in Table B.2.9-2

S3.2-2 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Boric Acid Corrosion GALL Section XI.M.5 applies. Refer to comments on Aging Management programs. See NRC disp

comments G-M5-2 in this AB.2.9-2. S3.2-3 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Closed Cycle cooling water system GALL Section XI.M.4applies. Refer to comments on Aging Management programs. See NRC dispcomments G-G-XI.M4-2 in Table B.2.9-2

S3.2-4 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Flow accelerated corrosion (FAC) program GALL Section XI.M.6 applies. Refer to comments on Aging Management programs. See NRC disp

comment G-XAppendix B, T
NUREG-1739 B.2.12-14 April 2001 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-5 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Inservice Inspection GALL Section I applies. The presentation of the Inservice Inspection program in the GALL is different than any other program evaluated in the GALL that is relied upon for license renewal. What specifically is an applicant supposed to do that allows this program to be credited without further review? Applicant sho

report, Chapt“ASME, SectiInspection, Sand IWD” in Nfor the evaluainspection pro(NUREG-180through 3.2.1crediting an ajust referring justifications rGALL report iChapter I of G“Application odoes not give element inserprogram but tSRP-LR, SecThe SRP-LR address this cGALL report, modified by u
April 2001 B.2.12-15 NUREG-1739 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-7 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Open-cycle cooling water system GALL Section XI.M.3 applies. Refer to comments on Aging Management programs. The commen

management received by thother NEI comaging managein a subseque02, 2001, conclosed indicatcomments on program M3. SRP-LR was this comment

S3.2-8 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Protective Coating monitoring and maintenance program GALL Section XI.S.8 applies. Refer to comments on Aging Management programs. See NRC disp

comment G-XAppendix B, T

S3.2-9 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Thermal aging embrittlement of CASS AMP. GALL Section XI.M.1 applies. Refer to comments on Aging Management programs. See NRC disp

comment G-XAppendix B, T

S3.2-10 SRP-LR 3.2 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Water Chemistry GALL Section XI.M.11 applies. Refer to comments on Aging Management programs. See NRC disp

comment G-XG-XI.M11-2 iTable B.2.9-2

S3.2-11 SRP-LR 3.2 Section 3.2.2.2.2 Crack Initiation and Growth Due to SCC Delete this Inservice Inspection. Inservice inspections do not include tanks within the scope of inspection so it is inappropriate to credit in this instance. See additional comments concerning the water chemistry program. See NRC disp

comment G-VAppendix B, TSRP-LR was comment by d3.2.2.2.2 as in and modifying 3.2.2 accordin
NUREG-1739 B.2.12-16 April 2001 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-12 SRP-LR 3.2 Section 3.2.2.2.4 Local Loss of Material Due to Pitting and Crevice Corrosion Delete this item. No objective evidence has been provided in the GALL report Sections VA 2.1, 5.1, VC 2.1, 2.2 to support the requirement to perform additional inspections. See additional comments concerning the water chemistry program. The one-time 

to verify that tprogram is adthe aging effeaging mechancrevice corrosLR 3.2.2.2.4. the GALL reprequire one-tiplant specific reasonable chchemistry proentering exteoperation. Thsupported by which pitting inside surface carbon steel cto secondary generator girtfeedwater nozSRP-LR was this comment
April 2001 B.2.12-17 NUREG-1739 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-13 SRP-LR 3.2 Section 3.2.2.2.5 Local Loss of Material Due to MIC Delete this item. No objective evidence has been provided in the GALL report Section VC.2.1 to support the requirement to perform additional inspections. See NRC disp

comment S3.Appendix B, TThis proposainspection to microbiologiccorrosion is pLR 3.2.2.2.5, objective evid“MIC of ContaSystem” and Sourcebook fPower Plants SRP-LR was this comment

S3.2-14 SRP-LR 3.2 Section 3.2.2.2.6 Changes in Properties Due Elastomer Degradation BWR item This elastome

structural seashould be addaging manageplant -specific that this elastgas treatmenBWR componSRP-LR was this comment

S3.2-15 SRP-LR 3.2 Section 3.2.2.2.7 Loss of Iodine Retention Capacity Due to Moisture Absorption Delete this item. Charcoal absorber filter media should be considered to be a consumable. See SRP-LR Table 2.1-3. See NRC disp

comment G-VAppendix B, TSRP-LR was comment by dsection 3.2.2.
NUREG-1739 B.2.12-18 April 2001 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-16 SRP-LR 3.2 Section 3.2.2.2.8 Buildup of Deposit from Biofouling Delete this item. No objective evidence has been provided in the GALL report Sections VC.2.1, VC.2.2 to support the requirement to perform additional inspections. See NRC disp

comment G-VAppendix B, TSRP-LR was comment by dsection 3.2.2.

S3.2-17 SRP-LR 3.2 Section 3.2.2.2.9 Local Loss of Material Due to Erosion Delete this item. No objective evidence has been provided in the GALL report Section VD.1.2.3 to support the requirement to perform additional inspections. Local loss of 

has been verevidenced by Because this plant specific report was momanagement component’s reference. SRP-LR was this comment was as stated 
April 2001 B.2.12-19 NUREG-1739 Table B.2.12-2: Disposition of NEI Comments on Chapter 3, Section 3.2 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.2-18 SRP-LR 3.2 Table 3.2-1, page 3.2-13, BWR/PWR, Closure bolting in high- pressure or high-temperature systems This component description is not consistent with the scope of the actual program. It should be “Class 2 bolting greater than 2 inches in diameter”. See generic comments concerning the Bolting Integrity Program. See NRC disp

comments G-G-XIM12-4 in Table B.2.9-2The scope of includes volubolting greateas mentioned scope also ininspection of components dThis will inclubolting smallediameter. SRP-LR was this comment

S3.2-19 SRP-LR 3.2 Section 3.2-3, Tables 3.2-1 and 3.2-2, and the applicable GALL sections need to be revised as necessary to reflect changes made above. Conforming changes The SRP-LR 

this comment changes to STables 3.2-1 the applicable reflect changeto the NEI coAppendix B, T
NUREG-1739 B.2.12-20 April 2001 This Page Intentionally Left Blank
April 2001 B.2.12-21 NUREG-1739 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-2 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Bolting Integrity GALL Section XI.M.12 applies. Refer to comments on Aging Management programs. See NRC dispo

comments G-XIG-XI.M12-4 in tTable B.2.9-2. S3.3-3 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Boraflex Monitoring GALL Section VII A2.1.1 applies. Refer to comments on Aging Management programs. See NRC dispoG-VII A2.1.1 in Table B.2.6. S3.3-4 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Boric Acid Corrosion GALL Section XI.M.5 applies. Refer to comments on Aging Management programs. See NRC dispocomments G-XIG-XI.M5-2 in thTable B.2.9-2. S3.3-5 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Closed Cycle cooling water system GALL Section XI.M.4 applies. Refer to comments on Aging Management programs. See NRC dispocomments G-XIG-XI.M4-2 in thTable B.2.9-2. S3.3-6 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Compressed air inspection and maintenance GALL Section VII D.1.1 applies. Refer to comments on Aging Management programs. See NRC dispoG-VIID-2 in this Table B.2.6. S3.3-7 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Fire Protection GALL Section VII.G applies. Refer to comments on Aging Management programs. See NRC dispocomments G-VIG-VIIG-12 in thiTable B.2.6. S3.3-8 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Fire Water System GALL Section XI.M.10 applies. Refer to comments on Aging Management programs. See NRC dispocomments G-XIG-XI.M10-2 in tTable B.2.9-2. S3.3-9 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Fuel oil Chemistry GALL Section XI.M.9 applies. Refer to comments on Aging Management programs. See NRC dispocomments G-XIG-XI.M9-4 in thTable B.2.9-2.
NUREG-1739 B.2.12-22 April 2001 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-10 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Inservice Inspection GALL Section I applies. The presentation of the Inservice Inspection program in the GALL is different than any other program evaluated in the GALL that is relied upon for license renewal. What specifically is an applicant supposed to do that allows this program to be credited without further review? Chapter 1 of GA

“Application of tnot give specificinservice inspec“ASME, Section Inspection, Suband IWD” in NUdoes. In places acceptable, no fnoted in the furtThe SRP-LR waaddress this com

S3.3-11 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Open-cycle cooling water system GALL Section XI.M.3 applies. Refer to comments on Aging Management programs. There were no N

GALL report, chThe SRP-LR waaddress this com

S3.3-12 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Outer surface of aboveground carbon steel tanks GALL Section XI.M.7 applies. Refer to comments on Aging Management programs. See NRC dispo

G-XI.M7-1 in thTable B.2.9-2. S3.3-13 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Outer surface of buried piping and components GALL Section XI.M.8 applies. Refer to comments on Aging Management programs. See NRC dispoG-XI.M8-1 in thTable B.2.9-2. S3.3-14 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Overhead and gantry cranes inspection and maintenance GALL Section VII B.1.1 applies. Refer to comments on Aging Management programs. See NRC dispoG-VII B.1.1 in thTable B.2.6.
April 2001 B.2.12-23 NUREG-1739 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-15 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Protective coating monitoring and maintenance GALL Section XI.S.8 applies. Refer to comments on Aging Management programs. Because the co

does not directly function, coating Protective CoatMaintenance pran aging mechaAMP for auxiliarare covered undrule. The SRP-LR wathis comment. S3.3-16 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Structural Monitoring GALL Section XI.S.6 applies. Refer to comments on Aging Management programs. See NRC dispocomments G-XIG-XI.S6-6 in thiTable B.2.9-3. S3.3-17 SRP-LR 3.3 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Water Chemistry GALL Section XI.M.11 applies. Refer to comments on Aging Management programs. See NRC dispocomments G-XIG-XI.M11-2 in tTable B.2.9-2. S3.3-18 SRP-LR 3.3 Section 3.3.2.2.1 Loss of Material from General, MIC, Galvanic, Pitting, and Crevice Corrosion See generic comments concerning water chemistry program. No objective evidence has been provided in GALL VII A3.2.1 that supports this additional inspection. See NRC dispocomments G-XIG-XI.M11-2 in tTable B.2.9-2.
NUREG-1739 B.2.12-24 April 2001 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-19 SRP-LR 3.3 Section 3.3.2.2.2 Hardening, and Cracking from Material Degradation No objective evidence has been provided in GALL VII A3.3.3, F1.1.3, and F2.1.3 that supports this additional inspection. Page 5.18-16 (S

System) of BG&term exposure oresult in water ablistering, hardecracking. Exposresult in degradproperties such hardness etc.” Taging effects/melastomer lining BG&E LR. The SRP-LR waaddress this com

S3.3-20 SRP-LR 3.3 Section 3.3.2.2.4 Crack Initiation and Growth from SCC

2nd paragraph is inconsistent with

Table 3.3-1 and GALL report whichalso refer to “unanticipated cyclicloading” for this item.Inconsistency needs to becorrected.3rd paragraph concerns SCC that

could occur in external surfacesadhered with electrical tape. Thisitem should be deleted.

Unanticipated cyclic loadingshould not be considered anaging effect that needs to bemanaged for the period ofextended operation. This is anabnormal event per SRP-LR A.1.No objective evidence in GALL VIIE1.4.1 provided to support thatthis is an aging effect. Also, perSRP-LR A1, abuse due to humanactivity is an abnormal event andaging effects from such abuseneed not be postulated for licenserenewal.

See NRC dispocomments G-VIG-VIIE1-11 in thTable B.2.6.See NRC dispocomments G-VIthis Appendix B
April 2001 B.2.12-25 NUREG-1739 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-21 SRP-LR 3.3 Section 3.3.2.2.5 Loss of Material from MIC, Galvanic, Pitting, and Crevice Corrosion, Wear and Erosion/Corrosion Moist air required. Movement required in order to have mechanical wear. See NRC dispo

G-VIID-2 in this Table B.2.6. S3.3-22 SRP-LR 3.3 Section 3.3.2.2.6 Loss of Iodine Retention Capacity from Moisture Absorption Delete this item. Charcoal absorber filter media should be considered to be a consumable. See SRP-LR Table 2.1-3. See NRC dispoG-VIIF1-3 in this Table B.2.6. S3.3-23 SRP-LR 3.3 Section 3.3.2.2.7 Loss of Material from General, Galvanic, Pitting, and Crevice Corrosion RCP Oil Collection Tank inspection at ONS. See NRC dispocomments G-VIin this Appendix 
NUREG-1739 B.2.12-26 April 2001 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-24 SRP-LR 3.3 Section 3.3.2.2.8 Induced cracking from vibration and wall thinning from Erosion/Corrosion Vibration induced cracking should be deleted. Erosion /corrosion should be deleted. Unanticipated cyclic loading should not be considered an aging effect that needs to be managed for the period of extended operation. This is an abnormal event per SRP-LR A.1. Vibration induced cracking is a design problem not an aging management issue. GALL Section VII H2.1.1 and H2.1.2 apply. No objective evidence is provided that supports the determination that either of these aging effects is of concern for the period of extended operation. Erosion / corrosion is plant specific and can be managed by the Flow Accelerated Corrosion program. However, the operating experience described in GALL XI.M6 does include any incidents with Diesel engine cooling water systems. See NRC dispo

G-VIIH2-6 in thiTable B.2.6. See NRC dispoG-VIIH2-12 in thTable B.2.6. S3.3-25 SRP-LR 3.3 Section 3.3.2.2.9 Loss of Material from corrosion or Buildup of Deposits from Biofouling Delete this item. No objective evidence in GALL H1.4.1 provided to support that this is an aging effect. See NRC dispoG-VIIH1-6 in thiTable B.2.6.
April 2001 B.2.12-27 NUREG-1739 Table B.2.12-3: Disposition of NEI Comments on Chapter 3, Section 3.3, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S3.3-26 SRP-LR 3.3 Table 3.3-1, page 3.3-13, Diesel engine cooling water system item Delete entire line item. Unanticipated cyclic loading should not be considered an aging effect that needs to be managed for the period of extended operation. This is an abnormal event per SRP-LR A.1. Vibration induced cracking is a design problem not an aging management issue. Consistent with comments made on SRP-LR 3.3.2.2.8. See NRC dispo

G-VIIH2-6 in thiTable B.2.6. S3.3-27 SRP-LR 3.3 Table 3.3-1, page 3.3-14, BWR, Closure Bolting item. The Bolting integrity program as written cannot manage the effects of aging identified in this item. Another program or activity must be provided. The bolting integrity program only includes ASME Class 1 bolting and ASME Class 2 bolting greater than 2 inches in diameter. See NRC dispoS3.2-18 in this ATable B.2.12-2. S3.3-28 SRP-LR 3.3 Table 3.3-2, page 3.3-18, Fuel Oil Chemistry Delete the statement concerning ASTM Standards. Required ASTM Standards are also in ITS Section 5.5, Programs. See NRC dispocomments G-XIG-XI.M9-4 in thTable B.2.9-2.
NUREG-1739 B.2.12-28 April 2001 This Page Intentionally Left Blank
April 2001 B.2.12-29 NUREG-1739 Table B.2.12-4: Disposition of NEI Comments on Chapter 3, Section 3.4, of SRP-LR Comment Number Item Number Proposed Change Justification For Proposed Change NRC 

S3.4-1 SRP-LR 3.4 Section 3.4.1 Areas of Review For PWRs, the boundary between the secondary side systems and the steam generator needs to be clearly defined. SRP-LR, Sec

to state “The the steam gefollowing the gof this StandaSection 3.4 of the secondary generator. SRP-LR,Sectto address thi

S3.4-2 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Bolting Integrity GALL Section XI.M.12 applies. Refer to comments on Aging Management programs. See NRC disp

comments foG-XIM12-4 in Section B.2.9

S3.4-3 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Boric Acid Corrosion GALL Section XI.M.5 applies. Refer to comments on Aging Management programs. See NRC disp

comments foG-XI-M5-2 in Section B.2.9

S3.4-4 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Closed Cycle cooling water system GALL Section XI.M.4 applies. Refer to comments on Aging Management programs. See NRC disp

comments foG-XI.M4-2 in Section B.2.9

S3.4-5 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Flow accelerated corrosion (FAC) program GALL Section XI.M.6 applies. Refer to comments on Aging Management programs. See NRC disp

comment for Appendix B, S

S3.4-6 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Open-cycle cooling water system GALL Section XI.M.3 applies. Refer to comments on Aging Management programs. No comments 

GALL Section cooling water No NRC disp

S3.4-7 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Outer surface of above ground carbon steel tanks GALL Section XI.M.7 applies. Refer to comments on Aging Management programs. See NRC disp

comment for Appendix B, S
NUREG-1739 B.2.12-30 April 2001 Table B.2.12-4: Disposition of NEI Comments on Chapter 3, Section 3.4, of SRP-LR (continued) Comment Number Item Number Proposed Change Justification For Proposed Change NRC 

S3.4-8 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Outer surface of buried piping and components GALL Section XI.M.8 applies. Refer to comments on Aging Management programs. See NRC disp

comment for Appendix B, S

S3.4-9 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Protective coating monitoring and maintenance GALL Section XI.S.8 applies. Refer to comments on Aging Management programs. See NRC disp

comment for Appendix B, S

S3.4-10 SRP-LR 3.4 AMPs Evaluated in the GALL Report that are Relied on for License Renewal – Water Chemistry GALL Section XI.M.11 applies. Refer to comments on Aging Management programs. See NRC disp

comments foG-XI.M11-2 in Section B.2.9

S3.4-11 SRP-LR 3.4 Table 3.4-1, page 3.4-9, BWR/PWR, Closure bolting in high-pressure or high-temperature systems This component description is not consistent with the scope of the actual program. It should be “Class 2 bolting greater than 2 inches in diameter.” GALL Section XI.M.12 applies. Refer to comments on Aging Management programs. See NRC disp

comment for Appendix B, S

S3.4-12 SRP-LR 3.4 Table 3.4-2, page 3.4-12, the summary for Inservice Inspection should be deleted. Inservice Inspection is not relied upon to manage the effects of aging summarized in table 3.4-1. The Inservice 

not relied on teffects in SRPThe SRP-LR this comment Inspection fro
April 2001 B.2.12-31 NUREG-1739 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-1 B.3.8 S3.5 Generic Comment Since this section deals with AMR, a discussion needs to be included on determining aging effects. If a discussion is not provided, include a pointer to A1.2.1. Editorial clarification. Aging effects a

aging manageAppendix A, Saddition of poito other topicsthe details reqitself to heightThe license redocuments weaddress this c

S-3.5-2 B.3.8 S3.5 Generic Comment This section contains a lot of information from the GALL. Many changes have been recommended to the information in the GALL. The GALL should be corrected first, and then the changes to this section should be made accordingly. For example, 3.5.2.2.1.2, discusses porous concrete sub foundations. The industry has recommended that this information be deleted from GALL since it is not generic to all sites and was not applicable to the two sites, which have received, extended licenses. Therefore, the GALL should change and this section should change. The information in the GALL and this section need to be consistent. Editorial. This is an edit

consistency of documents. The license redocuments wethis comment ensure consis
NUREG-1739 B.2.12-32 April 2001 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-3 B.3.8 3.5.1 Suggest adding the following sentence next to last paragraph: “Where GALL report has referenced a code (e.g. ACI 201.2R-77) as a technical basis for concluding that aging management is not required if it was constructed in accordance with that particular code, the staff will accept the deviation as long as the intent of that code has been satisfied and that referenced code is not the code of record for that particular plant”. Older plants, which were not constructed per referenced code, should be able to reference a code if the intent of the code has been satisfied. See NRC disp

NMC-1 and ACthis NUREG. S-3.5-4 B.3.8 3.5.1 Page 3.5-1 Add a sentence to the paragraph to address older vintage plants. Proposed wording: For older vintage plant, the information related to the structures and component supports is plant specific, and is contained in various Sections and Appendices of the UFSAR. Second sentence of the first paragraph states: “for a recent vintage plant, the information related to the structures and component supports is contained in Chapter 3”. The rest of the paragraph does not address older vintage plants. See NRC dispACRS-Chen-1 NUREG. S-3.5-5 B.3.8 S3.5.1.3 Generic Comment The second sentence states that “If an applicant does not rely on a particular program for license renewal, or if the staff should review each such aging management program to which the GALL report does not apply”. The statement should begin with: If an applicant does not rely on a program in GALL. Provide clarification to address program not in GALL. See NRC dispNMC-2 and NNUREG.
April 2001 B.2.12-33 NUREG-1739 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-6 B.3.8 S3.5.1.4 Generic Comment The second sentence states that: “If an applicant has identified particular components subject to aging management review for its plant, ...” The statement should begin with: If an applicant has identified particular components subject to aging management review for its plant which are not addressed in GALL. Provide clarification for components not addressed in GALL. The SRP-LR w

this comment. also made to tchapter 3 of Sconsistency. S-3.5-7 B.3.8 S3.5.1.4 Generic Comment Add statement: Not all aging effects in GALL require aging management at all plants. Provide clarification. What happens if an applicant does not identify an aging effect that is in GALL? See NRC dispNMC-8 in Tab

S-3.5-8 B.3.8 S3.5.2.1 Generic Comment Provide more guidance so that an applicant or reviewer will know what is required. The second sentence in this section states that the applicant should “... provide the information necessary to adopt the finding...” There is not enough guidance provided in this section for an applicant or a reviewer to know what is required. See NRC disp

NMC-2 in Taband also NEI-5 Table B.2.15. S-3.5-9 B.3.8 S3.5.2.1 Generic Comment Provide more guidance so that an applicant or reviewer will know what is required. The third sentence in this section states that the applicant should “...also verify that the approvals set forth in the GALL report for generic programs apply to the applicant’s programs”. There is not enough guidance provided in this section for either an applicant or reviewer to know what is required. See NRC dispNMC-2 in Tab

S-3.5-10 B.3.8 S3.5.2.2 Generic Comment Information included in this section should be compared to the final GALL report to ensure that any changes are incorporated. The industry has recommended several changes to the GALL. These changes should be incorporated in both the GALL and SRP-LR. See NRC disp

S.3.5-2 of this Table B.2.12-5
NUREG-1739 B.2.12-34 April 2001 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-11 B.3.8 3.5.2.1 Pg. 3.5-3 Generic Comment This paragraph requires the applicant to provide information such that the Staff can establish acceptability of the program as described and evaluated in GALL. According to GALL Volume 1 and paragraph 3.5.1.1, if the applicant’s program corresponds to GALL evaluated GALL Generic Program no further staff review is required. Clarify the requirement of paragraph 3.5.2.1. If the applicant’s program corresponds to the GALL evaluated Program, then any information required in the LRA is a duplication. It should suffice to reference GALL as stated in Volume 1. The Staff can audit the credited program to confirm it corresponds to GALL. See NRC disp

NMC-2 in Tab

S-3.5-12 B.3.8 3.5.2.2.2.1 Pg. 3.5-4 The title “Aging of Supports not covered”. should be “Aging of Structures not covered”. Paragraph content discuss structures. Supports are discussed in 3.5.2.2.3. Section 3.5.2.2

concerns structhe title should The SRP-LR, was revised to by revising its Other license documents weconsistency. S-3.5-13 B.3.8 3.5.2.2.2.2 Pg. 3.5-5 Aging management of Inaccessible Areas. This paragraph requires further evaluation of Class 1 structures, concrete and structural steel, in inaccessible areas. GALL only requires further evaluation of structural steel and not concrete. Revise the paragraph to be consistent with GALL. Aging management of concrete structures is not required if the evaluation and technical basis described in GALL are met. See NRC dispcomments G-Ithis Appendix 
April 2001 B.2.12-35 NUREG-1739 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-14 B.3.8 3.5.2.2.3.2 Pg. 3.5-5 The paragraph states fatigue is a TLAA for Groups B1.1, B1.2, & B1.3 components supports. Delete B1.2 & B1.3. ANSI B31.1-B31.7 requires no fatigue analyses for supports. ASME III fatigue requirements apply to supports ASME class 1 piping. If the code of r

fatigue analysanalysis is a Tto B1.1, B1.2, The SRP-LR, was revised to by inserting a CLB fatigue an

S-3.5-15 B.3.8 S3.5.3.1 Generic Comment Provide more guidance. The third sentence of the first paragraph of this section states: “If the applicant has provided the information necessary to adopt the finding of program acceptability...” There is not enough guidance provided in this document for either an applicant or review to know what is required. See NRC disp

NMC-2 in Tab
NUREG-1739 B.2.12-36 April 2001 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-16 B.3.8 S3.5.3.1 Generic Comment The fifth sentence states that the “The reviewer also verifies that the applicant has stated that the applicable aging effects and industry and plant-specific operating experience had been reviewed by the applicant and are evaluated in the GALL report”. Since the GALL did not necessarily evaluate plant-specific operating experience, the sentence should be changed to the following: The reviewer also verifies that the applicant has stated that the applicant had reviewed the applicable aging effects and are evaluated in the GALL report. The reviewer verifies that the applicant stated that industry and plant-specific operating experience had been reviewed and no additional aging effects were identified beyond those evaluated in the GALL report. Provides clarification on how to handle plant-specific operating experience and industry experience. See NRC disp

NMC-8 in TabAlso see additevaluating elemanagement Appendix A.1, Review.” S-3.5-17 B.3.8 3.5.3.1 Pg. 3.5-6 Generic Comment This paragraph requires the applicant to provide information such that the Staff can establish acceptability of the program as described and evaluated in GALL. According to GALL Volume 1 and paragraph 3.5.1.1, if the applicant’s program corresponds to GALL evaluated GALL Generic Program no further staff review is required. Clarify the requirement of paragraph 3.5.3.1. If the applicant’s program corresponds to the GALL evaluated program, then any information required in the LRA is a duplication. It should suffice to reference GALL as stated in Volume 1. The Staff can audit the credited program to confirm it corresponds to GALL. See NRC dispNMC-2 in Tab
April 2001 B.2.12-37 NUREG-1739 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-18 B.3.8 S3.5.3.1 Generic Comment Add statement: Not all aging effects in GALL require aging management at all plants. The next to last sentence in the first paragraph states that “the reviewer verifies that the applicant has identified those aging effects for the structures and component supports that are contained in the GALL report as applicable to its plant”. Not all aging effects are applicable to all plants. For example, settlement is not applicable for sites located on bedrock. See NRC disp

NMC-8 in Tab

S-3.5-19 B.3.8 S3.5.3.2.1.1 Delete the information on inaccessible areas. The requirement for inaccessible areas goes beyond what is required by ASME and 50.55a. See NRC disp

G-IIA1-1 in thiTable B.2.1.
NUREG-1739 B.2.12-38 April 2001 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-20 B.3.8 S3.5.3.2.1.7 Information in this section disagrees with information in the GALL. The SRP-LR states that, “However, the report notes that VT-3 inspection may not be sufficient to detect cracks”. The GALL states, “For cracking due to cyclic loading of penetration sleeves and penetration bellows, VT- 3 visual inspection may not detect fine cracks (one option may be to perform VT-1 visual inspections”. In both documents, the conclusions should be changed to determine that VT-3 is adequate. In this section and throughout both documents, the adequacy of visual VT-3 examination is called into question for the detection of cracking. In particular, GALL Section III.B1.1.1 determines that VT-3 is inadequate for detection of cracking in Class 1 piping and component supports and GALL Section III.B1.2.1 finds this to be true for Class 2 and 3 piping and component supports, as well. The conclusions reached in this section go beyond what is current in the code. Licensee should not have to go beyond Code requirements without justification. VT-3 should be found to be adequate for detection of “crack-life indications” in at least three circumstances: When the structure or component can tolerate “mature cracks”. This should be the case for Class 1, 2, and 3 component supports, where mature cracks are needed to jeopardize the load-carrying function of the component or support. When pressure-containing component is subject to both visual examination and pressure testing capable of detecting localized, small- capacity leakage. This should be the case for bellows, sleeves, and penetrations subjected to Appendix J Type B and C tests. Situations where proximity to the component or structure surface is not an issues, so that visual acuity, lighting, and character recognition is essentially identical for VT-1 and VT-3. See NRC disp

comments G-Ithis Appendix 

S-3.5-21 B.3.8 3.5.3.2.2.1 Pg. 3.5-9 The title “Aging of Supports not covered”. should be “Aging of Structures not covered”. Paragraph content discuss structures. Supports are discussed in 3.5.3.2.3. See NRC disp

S-3.5-12 in ApTable B.2.12-5
April 2001 B.2.12-39 NUREG-1739 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-22 B.3.8 3.5.3.2.2.2 Pg. 3.5-10 Aging management of Inaccessible Areas. This paragraph requires further evaluation of Class 1 structures, concrete and structural steel, in inaccessible areas. GALL only requires further evaluation of structural steel and not concrete. Revise the paragraph to be consistent with GALL. Aging management of concrete structures is not required if the evaluation and technical basis described in GALL are met. See NRC disp

S-3.5-13 in thiTable B.2.12-5

S-3.5-23 B.3.8 3.5.3.2.3.2 Pg. 3.5-11 The paragraph states fatigue is a TLAA for Groups B1.1, B1.2, & B1.3 components supports. Delete B1.2 & B1.3. ANSI B31.1-B31.7 requires no fatigue analysis for supports. ASME III fatigue requirements apply to supports ASME Class 1 piping. See NRC disp

 S-3.5-14 in thTable B.2.12-5

S-3.5-24 B.3.8 3.5.3.2.3.1 The industry disagrees with the conclusions reached in GALL on reduction in concrete capacity due to vibration loads. This information should be deleted. Vibration induced cracking is not a license renewal aging effect and should be deleted. Vibration induced cracking is expected to occur during the current term and be corrected. This type of aging is random and is corrected as discovered with inspections of similar locations and configurations to ensure the event is location specific or a one-time event. See NRC disp

G-IIIB1-2 in thTable B.2..
NUREG-1739 B.2.12-40 April 2001 Table B.2.12-5: Disposition of NEI Comments on Chapter 3, Section 3.5, of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NRC 

S-3.5-25 B.3.8 Table 3.5-1 Generic Process Issue Delete Table 3.5-1. This table adds no value. In addition, there are now 4 places where information would have to be changed if it was determined that the conclusions in GALL were not correct. For example, the industry disagrees with the conclusion for aggressive chemical attack on PWR containments. This information is incorrect in (1) the GALL, (2) SRP-LR Section 3.5.2.2.1.1, (3) SRP-LR Section 3.5.3.2.1.1, and (4) Table 3.5-1. The purpose o

provide a sumconclusions frreport to help review. Withoureviewer would and may devefor each reviewand consistensummary as gThere are six s1, 3.3-1, 3.4-1SRP-LR Chaprequested remnot consistent existing tables The SRP-LR waddress this c

S-3.5-26 B.3.8 Table 3.5- Dissimilar metal welds should be deleted from the component column. Dissimilar metal welds are optional per 50.55a. See NRC disp

G-IIA3-1 in thiTable B.2.1. S-3.5-27 B.3.8 Table 3.5-2 Page 3.5-20 In Table 3.5-2 (referenced in Section 3.5.3.5), on page 3.5-20, replace the “Monitoring of Leak in Fuel Storage Facility” with “Liner Integrity” and revise the Program Description to describe the Water Chemistry Program. Make SRP-LR consistent with proposed GALL revision of comment in GALL section IIIA, page IIIA5-9. See NRC dispG-IIIA5-1 in thTable B.2.2.
APPENDIX B, TABLE B.2.13

DISPOSITION OF NEI COMMENTS

ON CHAPTER 4 OF SRP-LR
B.2.13-ii

This Page Intentionally Left Blank
April 2001 B.2.13-1 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.1-1 SRP-LR 4.1-4.7 Delete qualifying term “plant- specific”. This comment should be noted throughout Chapter 4 of the SRP-LR. In the first paragraph of section 4.1, the second sentence, and the second paragraph, first sentence, use of the term “plant-specific” incorrectly limits the scope of TLAAs, and adds nothing to the discussion. For example, a CE- generic surge line fatigue calc. (most certainly not plant-specific) was determined to be a TLAA for CCNPP. It may be correct to say, “the list of TLAAs is plant specific”. NEI comment 

“plant-specificTLAAs is planA TLAA may is more propeof TLAAs is pproposed chaclearer. The SRP-LR this comment

S 4.1-2 SRP-LR 4.1.1 Delete the last sentence in the first paragraph. The last sentence in paragraph 1 states, “The listing of TLAAs should provide sufficient detail to identify the type of calculations and a summary result of calculations.” Providing a summary result of a calculation that is a TLAA goes beyond the listing requirements of 10 CFR 54.21(c)(1). Details of an analysis would only be necessary for the demonstration portion if demonstration methods (i) or (ii) were chosen for a TLAA. No such details as the type of calculation or a summary of results are required if demonstration method (iii) is chosen. The information reviewed in SRP-LR 4.1.1 should at most be no more than a table of contents of the NEI comment 

sentence, “Thshould provididentify the tya summary reThe results of calculation is demonstratiochosen and thresults of anlaare not requirmethod (iii) is The SRP-LR this comment
NUREG-1739 B.2.13-2 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.1-2 (cont.) TLAA Chapter. Each TLAA will be addressed in its own Chapter 4 section. The last sentence of paragraph 1 is just not needed. S 4.1-3 SRP-LR 4.1.1 In the first paragraph of the section add a sentence to the end as follows, “A listing of specific calculation numbers is not required.” A specific listing of the individual calculations will not be provided. Rather, a listing of the categories of calculations identifying a topical area will be identified. Sufficient information as requested for each category of calculations will be provided. For example, containment liner fatigue is a ‘category’ of calculations. Several calc numbers may have been used for this category. See NRC disp

comment S 4Table B.2.13. S 4.1-4 SRP-LR 4.1.1 SRP-LR Section 4.1.1, 3rd paragraph should be revised to read: “an applicant must provide a list of plant-specific exemptions granted under 10 CFR 50.12 that are based on TLAA.” Part 54 limits exemptions to only those granted under 50.12. NEI comment

Section 4.1.1should be revapplicant musplant-specific under 10 CFR on TLAA.” According to list of plant-spis granted pumust be provchange makeThe SRP-LR this comment
April 2001 B.2.13-3 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.1-5 SRP-LR 4.1.3 In the paragraph that starts “The reviewer should use the plant Updated Final Safety Analysis Report ---” add two sentences as follows, “Sections 4.2 through 4.6 identify typical types of TLAAs for most plants. Information on the licensee’s methodology for identifying TLAAs may also be useful in identifying calculations that did not meet the six criteria below.” The reviewer should start with the plant CLB as stated. The use of Tables 4.1-2 and 4.1-3 may start the reviewer on the wrong track as stated in the next comment. Inserting this wording allows the reviewer to quickly retrace the efforts of the licensee in identifying TLAAs so the reviewer may discover potential omissions. NEI comment 

sentences in starts “The replant Updated Report ---” to through 4.6 idTLAAs for moon the licenseidentifying TLuseful in idendid not meet tThis commenthat the staff the plant curr(CLB.) The SRP-LR this comment

S 4.1-6 SRP-LR 4.1.3 In the paragraph that starts “The number and type of TLAAs vary ---,” delete the remainder of the paragraph that starts with the sentence, “Table 4.1-2 provides a list ---.” Also, delete Tables 4.1-2 and 4.1-3. The use of Tables 4.1-2 and 4.1-3 start the reviewer from the wrong place. The search for possible TLAAs should start from the licensees CLB and the reviewer’s knowledge of the six criteria. Of particular concern in retaining these SRP-LR tables, would be the need for each licensee to address each of the items in the tables to preclude questions on the topics listed. The licensee’s efforts start from the CLB, not from the tables. The reviewer should have a reasonable basis for believing that a TLAA exists. This will come from a review of the CLB, not from a review of these tables. NEI recomme

4.1-2 and 4.1tables may mreviewer. Examples listand 4.1-3 are not a list of retables may hethe right trackmisleading. The SRP-LR address this c
NUREG-1739 B.2.13-4 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.1-7 SRP-LR 4.1.3 SRP-LR Section 4.1.3, page 4.1-3, statements in the first two examples on the page should be revised to read as follows: “A review of the code and standard reveals that an analysis or calculation is required. Some of these calculations or analyses will be TLAAs.” Similarly, revise the statement in the

2nd example to read: “In response to

a generic letter, licensee submitteda letter to the NRC committing toperform an analysis orcalculation...”

TLAA is a term that is unique to Part54. Codes and standards do not inand of themselves require a TLAA.Codes and standards often requirean analysis or calculation which ifthe criteria of §54.3 are met then aTLAA exists.Commitments in response togeneric letters would not necessarilybe a TLAA unless all criteriacontained in §54.3 were met.

The proposed paragraph is clarify the inteThe SRP-LR this commentHowever, in tthe sentence calculation or related to timeanalyses.The SRP-LR address this c

S 4.2-1 SRP-LR 4.2,

4.3, 4.4, 4.5,4.6, 4.7

In each of these SRP-LR Sections,there is a statement in the ReviewProcedures section, FSARSupplement discussion that beginswith: “The staff expects to impose alicense condition in the renewedlicense, if granted, ...”

It is not clear why this statement isincluded in the review proceduresection. It is true information butdoes not seem to have anything todo with the FSAR summary review.Perhaps it should be relocated ordeleted.This statement begins a newthought and if it needs to stay in thissection of the SRP-LR, then itshould be a new paragraph.Please note that this comment alsoapplies to Chapter 3 of the SRP-LR.

NEI suggests as a new parachange makeChapter 3 and regarding the introduce a nesuggested.The SRP-LR this comment
April 2001 B.2.13-5 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.2-2 SRP-LR 4.2.2.1.5 and 4.2.3.1.5 Delete these sections from the SRP-LR. The BWRVIP analysis referred to was to demonstrate the difference between the axial and circumferential welds in a BWR vessel for the purpose of eliminating circumferential weld examinations. The fluence experienced by BWRs is significantly less than PWRs and does not pose a threat to the integrity of the reactor vessel. The axial welds are examined periodically in accordance with ASME Section XI. Finally, the reactor material surveillance program and the assessment of the data monitor the level of embrittlement by evaluating the impact on upper shelf energy. See IV.A1.2.4 of GALL. NEI recomme

4.2.2.1.5 and SRP-LR. According to analyses mus60-year perioperiod. SRP-Land 4.2.3.1.5 identify that ebeltline welds and that planta program for embrittlement The SRP-LR this comment

S 4.3-1 SRP-LR 4.3.1.2 Insert the language previously provided with regard to the environmental effects of fatigue. Also include conforming changes throughout section 4.3 including deleting sections 4.3.2.2, 4.3.3.2 and the second paragraph of Table 4.3-2. Note that the previous comments suggested that this issue be addressed in Section 3 under the RCS. NOTE: Conforming changes will need to be made to the GALL report sections that reference this section and GALL Chapter X. For example, refer to GALL IV C2.1.1, C2.1.2 None of the industry comments pertaining to GSI-190 were included in the August 2000 version of the SRP-LR. The alternative method to address EAF was not included. Chapter X of the GALL now contains a Fatigue Management Program description (comments are provided below in comments labeled G X.M1-1). Environmental effects are not a TLAA and should not be addressed in the TLAA section. The industry has not closed on a long- term strategy for dealing with environmental effects so the language proposed in the original comments provides the flexibility for NEI states tha

effects are nonot be addresEnvironmentaconservatism calculation, wissues are relseparated. The SRP-LR 

address this c
NUREG-1739 B.2.13-6 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.3-1 (cont.) Fatigue. The language related to environmental effects should be deleted. A new line item related to environmental effects should be added and a site-specific program should be identified with further evaluation set to yes. applicants to propose methods for addressing the issue. S 4.3-2 SRP-LR 4.3.1.2 SRP-LR Section 4.3.1.2 Generic Safety Issue, in the opening paragraph describes the concern that the effects of reactor coolant environment on the fatigue life of components were not adequately addressed by the code of record. This statement is in contrast to the 12/26/99 Thadani letter (Reference 11, SRP-LR Section 4.3) that allows the use of the same code of record for advanced reactor designs, but questions its validity for currently licensed plants. Because Reference 11 provides a confident foundation for the fatigue design basis of the next generation of nuclear plants, it is unclear how this same basis is a cause for concern for the existing plants. Resolution o f this disagreement needs to be clearly articulated. The concern over the fatigue design of the existing plants casts a shadow on the viability of the fatigue design in the next generation of plants. Metal fatigue is a physical issue for both existing and future designs. The apparent conflict in NRC positions should be resolved to assure continuity in plant design. This commen

specific recomchange to the address ALWapplication folicense. The SRP-LR 

address this c
April 2001 B.2.13-7 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.3-3 SRP-LR 4.3.1.2 SRP-LR Section 4.3.1.2 Generic Safety Issue, in the last full paragraph, uses the phrase “the nature of age-related degradation” to indicate the potential for an increase in the frequency of pipe leaks. Please define “nature of age- related degradation.” The phrase “nature of age-related degradation” has no meaning in the context written. Since it is being used as a justification for further action, the phrase needs to be more fully defined to assist the reviewer. NEI recomme

phrase; “natudegradation” The phrase is GSI-190 closeobjection to efrom the SRP

The SRP-LR this comment

S 4.3-4 SRP-LR 4.3.1 SRP-LR Section 4.3.1, “Areas of Review” does not seem to include fatigue analyses associated with the RCP Flywheel. Confirm that the RCP flywheel fatigue analyses should not be included under Section 4.3 and that it will be considered plant specific and included under Section 4.7. NEI indicated 

not discuss ththe RCP flywAccording to June 15, 2000paragraph wa4.3.1, “The mreview includereview of in sanalyses, reacracking analinternals fatighigh energy libreak, RCP flbellows.” This helpful to the The SRP-LR this comment
NUREG-1739 B.2.13-8 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.3-5 SRP-LR 4.3.1.1.3 SRP-LR Section 4.3.1.1.3 lists metal bellows designed to ASME NC- 3649.4 (e)(3). SRP-LR Section 4.6.1 also lists penetration bellows as within the “Area of Review” for Section 4.6. Bellows should be addressed in only one section. Clarify which section of the SRP-LR addresses metal bellows. SRP-LR addr

two separate that metal beaddressed in See NRC dispcomment S 4Table B.2.13. The SRP-LR this comment

S 4.3-6 SRP-LR 4.3.2.1.1.2 (Typical for other sections) The last sentence should be revised to read “The resulting CUF remains less than unity for the period of extended operation.” There is a Code requirement to design for a CUF below one, but a CUF below one during operation is not a Code requirement. This comments applies throughout Section 4.2 where the Code is tied with the period of extended operation. NEI recomme

statement regresulting CUF unity for the poperation” in SRP-LR. The proposed helpful. The SRP-LR this comment

S 4.3-7 SRP-LR 4.3.2.1.2.1 4.3.2.1.2.2 These two paragraphs should be revised to read as follows: 4.3.2.1.2.1 The existing fatigue strength reduction factors remain valid because the number of cycles would not be exceeded during the period of extended operation. 4.3.2.1.2.2 The fatigue strength reduction factors have been re-evaluated based on an increased number of assumed thermal cycles and The allowable full cycle thermal stresses calculated during design are adjusted based on fatigue strength reduction factors. If the actual number of full range thermal cycles (e.g. 7000 cycles) remains valid for the 60-year term, then (i) is satisfied. If the fatigue strength reduction factor is increased but the design basis allowable is still met, then (ii) is satisfied. NEI recomme

Sections 4.3.2to address fatreduction factallowable streThe proposed issue clearer The SRP-LR this comment
April 2001 B.2.13-9 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.3-7 (cont.) Table 4.3-1 to bound the period of extended operation. The adjusted fatigue strength reduction factors are such that the component design basis remains valid during the period of extended operation. S 4.3-8 SRP-LR 4.3.2.1.2.3 Also, conforming changes with 4.3.3.1.2.3 Replace the existing text with the text presented in Section 4.3.2.1.1.3. Piping that was designed to B31.1 can be managed by cycle counting the same as piping designed to ASME Section III. If this change is not accepted as proposed, then delete the second sentence of the first paragraph because there is no requirement to replace piping when the design cycles are reached. ASME XI can be applied the same as if CUF exceeds one. Also, there should be no requirement that if the pipe is replaced it be designed to last until the end of the extended period of operation. It may be economically better to replace the pipe several times during plant lifetime rather than design such that the pipe will last for the entire plant lifetime. NEI suggests 

text in 4.3.2.1presented in SNEI states thadesigned to Bby cycle counpiping designIII.” Staff believes does not preccycle countingnot aware of aapplicants plathe B31.1 cycthe staff has nsimilar to the with fatigue aSection III, ClThe SRP-LR address this c
NUREG-1739 B.2.13-10 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.3-9 SRP-LR 4.3.3.1.1.3 (typical for other sections) Insert a second sentence as follows, “Cycle counting can be used by the applicant in one of two ways. First, it may be implemented as a confirmation of design assumptions in support of options (i and ii). Secondly, it may be used as an aging management program in support of an option (iii) solution.” This may not be a disposition of fatigue TLAAs (option iii). The only time one would apply (iii) is if a CUF of 1.0 had been exceeded during the period of extended operation, or in the case of monitoring existing flaws. In that case the program could be one, which manages cracking or might involve cycle counting. Cycle counting can also be used to confirm that you are remaining within your design cycle assumptions and supports the (i) and (ii) alternatives. NEI recomme

counting can options (i) or TLAA. However, the (i) and (ii) calcbe performed extended opefatigue analysThe intent of option (iii) is tduring the extoperation to adoes not exceThe SRP-LR address this c

S 4.3-10 SRP-LR Table 4.3-2 The first sentence should begin with “The aging management program...” The phrase “In order to not exceed the design limit on fatigue usage and the number of design cycles” should be deleted. The fatigue-monitoring program does not have to prevent exceeding the number of design cycles. The purpose of the AMP is to monitor thermal fatigue to identify before the plant exceeds the limit on cycles of CUF, so that appropriate action can be taken. This can include revising the CUF calculations, inspection of the piping per ASME Section XI, or replacement of the pipe. NEI recomme

sentence in Tthat the fatigudoes not have the number oThis proposed clearer that thprevent exceedesign limit. The SRP-LR this comment
April 2001 B.2.13-11 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.4-1 SRP-LR 4.4 EQ Component Reanalysis Attributes section of GALL X.E.1 is identical to the information provided in SRP-LR Section 4.4.3.1.2 and Table 4.4-1. Suggest deleting the information from SRP-LR 4.4.3.1.2 and simply referencing the GALL report From an administrative perspective, it makes sense to only have this information in one location. Future changes would then need to be made to only one location. It also fits the objective of the overall GALL report. The story in the GALL report makes sense as told and it should remain as is and revise the SRP-LR. NEI recomme

information frHowever, the information frregarding rearelative to 10 be deleted. Tconsidered to document. The SRP-LR address this c

S 4.4-2 SRP-LR 4.4.1 At the end of the paragraph on “Areas of Review” add a new sentence as follows, “For the purposes of license renewal only those components with a service life of 40 years or greater would be TLAAs.” Please provide a statement that clarifies that only equipment qualified for 40 years or greater meets the 6 TLAA criteria. This statement was included in Chapter X of the GALL NEI states tha

only those co“qualified” life require evaluaThe proposed long as it addlife of 40 year“service” life oThe SRP-LR this comment

S 4.4-3 SRP-LR 4.4.1.2 Delete the first sentence of Section 4.4.1.2 The first sentence is a true statement, but there are a variety of other reasons that GSI-168 was generated. Highlighting this one reason and not the others implies that it is of most importance. In actuality the difference in EQ requirements between newer and older plants was eliminated as an in issue in a letter from the NRC dated 2-5-98. NEI comment

sentence in Sregarding “oldrequirements staff EQ Task not be highligThis proposed clear. The SRP-LR this comment
NUREG-1739 B.2.13-12 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.5-1 SRP-LR Chapter 4.5 Replace Chapter 4.5 with the previously submitted NEI version of Chapter 4.5. NOTE: Conforming changes will also need to be made to the GALL report. For example, in GALL section II A1.3 Loss of Prestress, the evaluation and technical basis description should be revised as follows: Delete the second sentence of the first paragraph. Revise the sentence in the second paragraph to read “...see Chapter XI.S2 and XI.Sx.” where “

x” refers to the new number

for the tendon surveillance program

The latest version of this SRP-LRchapter remains based on afundamental misconception of whatconstitutes a TLAA. Based strictlyon the definition of a TLAApresented in the Rule, the TLAA forContainment Tendon Prestressconsists ONLY of the PLL curvesthat currently are calculated out to40 years. The trend lines of theactual measurements, and anycomparison of these trend lines tothe PLL curves, DO NOT constitutea TLAA, because they are in no waybased on the forty-year operatinglife of the plant. The trend line isbased on data taken at individualpoints in time that have no relationto a forty year life, and the trend lineis compared to whatever point onthe PLL curve it intersects, not tothe point on the PLL curverepresenting 40 years.In actuality, since the TLAA forContainment Tendon Prestressconsists only of the PLL curves, theonly options for dispositioning thisTLAA should be (i), the PLL curvesare already calculated to 60 years,or (ii), we will project the PLL curvesto 60 years.The activities described in theSRP-LR under option (iii), with the

NEI recommeChapter 4.5 oNEI version ostates that bainterpretation in the Rule, thContainment consists only currently are 40 years. The actual measucomparison othe PLL curveTLAA, becausbased on the life of the planbased on data points in time to a forty yeais compared tthe PLL curve the point on trepresenting The estimatioare parts of thcalculations, twhether the liapplication is purpose of thdemonstrate dependent chactually measforces remain corresponding 
April 2001 B.2.13-13 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.5-1 (cont.) exception of projecting the PLL curves, have nothing to do with any TLAA. Rather, they constitute the Aging Management Program that the applicant will have to credit after performing the AMR of the Containment Tendons. The industry does not dispute that these activities will be required, only that they have nothing to do with dispositioning the TLAA for Containment Tendon Prestress. The Aging Management Program aspects of Containment Tendon Prestress, including comparison of the slope of the trend line to the PLL curves, will be considered in the aging management review for the Containment structure, not in this TLAA. With the current version of this SRP-LR chapter, the NRC has presented two options for disposition, (i) and (ii) that will almost certainly be rejected by applicants. This is because they require making conjectures about future equipment performance. Also, option (iii) consists of first, extending the PLL curves to 60 years (which as described above should be listed as option (ii) in its entirety and must be done anyway) and then proceeding with the Tendon Prestress activities that every a result of an 

on GALL IIA1agreed to macomparison wMRVs rather required by 150.55a(b)(2)(The SRP-LR address this c
NUREG-1739 B.2.13-14 April 2001 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.5-1 (cont.) licensee is required to perform already. For option (ii), the staff is requiring an extrapolation of data for a time-period that is in excess of the current regulatory requirement in 50.55a. In 50.55a(b)(viii)(B), the trend of data needs to be made out only through the next inspection interval (5 years). With data scatter, there is a large degree of uncertainty in extrapolating out upwards of 40 years. Developing a retensioning plan based on a lengthy extrapolation of data adds no value towards assuring the intended function of the tendons is maintained above and beyond existing regulatory requirements. In the absence of any additional TLAA considerations, licensees would continue to treat the prestress trend results in accordance with the existing regulatory requirements. The industry and NRC are not in disagreement as to the complete set of activities that must be performed for aging management and for TLAA disposition for Containment Tendons. The previous industry rewrite of this SRP-LR chapter intended to allocate those activities that, by the Rule, actually pertain to
April 2001 B.2.13-15 NUREG-1739 Table B.2.13: Disposition of NEI Comments on Chapter 4 of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

S 4.5-1 (cont.) the TLAA aspects of this issue, and relegate the remainder to the appropriate aging management review process.
NUREG-1739 B.2.13-16 April 2001 This Page Intentionally Left Blank
APPENDIX B, TABLE B.2.14

DISPOSITION OF NEI COMMENTS

ON APPENDIX A OF SRP-LR
B.2.14-ii

This Page Intentionally Left Blank
April 2001 B.2.14-1 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR Comment Number Item Number Comment/Proposed Change Basis for Comment NR

S-A.1-1 A.1.1 Under background, the statement is made that “In many instances, more than one type of aging management programs are implemented to ensure that aging effects are managed.” The sentence should be changed to: “More than one type of aging management program may be implemented to ensure that aging effects are managed.” This is not true and has not been the case with the first two approved licenses. The intent of 

inform the reone aging mamay be used effect. The pclearly states The SRP-LRparagraph wathis commensentence refefrom “In manone type of aprograms are ensure that amanaged” to aging managimplemented effects are m

SA.1 –2 SRP-LR App A.1 Currently, A.1.2.1, Applicable Aging Effects, paragraph 1 states: The determination of applicable aging effects is based on the degradations that have actually occurred and those that potentially could cause structure and component degradation. The materials, environment, stresses, service conditions, operating experience, and other relevant information should be considered in identifying applicable aging effects. The effects of aging on the structure and component intended function(s) should also be considered. The threshold for when an aging effect needs to be managed for the period of extended operation needs to be clearly defined and have a technical basis that supports the conclusion. The statement that an aging effect that needs to be managed is one that “potential could” is too vague and ambiguous and subject to too much judgement. The threshold 

effect needs period of extealways be cleexample of threactor vesseswelling has is no definite result in loss during the peoperation but it to cause stdegradation. such as this, that aging maare to be impdegradations 
NUREG-1739 B.2.14-2 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.1-2 (cont.) This paragraph should be revised to read as follows: The determination of aging effects that require management during the period of extended operation is based degradations that have actually occurred and those that would result in loss of component function during the period of extended operation if left unmanaged. The materials, environment, stresses, service conditions, operating experience, and other relevant information should be considered in identifying applicable aging effects. The effects of aging on the structure and component intended function(s) should also be considered. and for those 

cause structudegradation. aging effects effects such requires aginThe SRP-LR address this 

SA.1-3 SRP-LR App A.1 Section A1.2.3.2 Preventive Actions, paragraph 2 currently states: “However, in many instances, more than one type of aging management programs should be implemented to ensure that effects are managed.” In many instances, reasonable assurance has been provided by programs that prevent or mitigate the effects of aging during the current term of the operating license. Only if there is a recognized deficiency in the existing program should there be a need to augment the program with an inspection program. See dispositi

SA.1-1 in this Table B.2.14The GALL rerecognized dprograms anwith an inspethis is the wawhere the proeffective in loareas, the praugmented wverify the effechemistry coabsence of a
April 2001 B.2.14-3 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.1-3 (cont.) aging effect i

are evaluated appropriate cThe SRP-LR address this 

SA.1-4 SRP-LR App A.1 Section A.1.2.3.4 Detection of Aging Effects This section should focus on what is needed to do the aging management program or activity. This section should be revised to discuss the method by which the aging effect will be detected; how often the activity will be performed, and how large the sample size should be. In addition, for new activities, the timing of when the new activity will be implemented. Appropriate industry codes and standards may be included to support the program. The “Detection of Aging Effects” attribute should be revised to read as follows: This program element describes “when”, “where” and “how” program data is collected; i.e., all aspects of activities to collect data as part of the program. This includes aspects such as method or technique (e.g., This section does not currently provide enough guidance to the applicant or the reviewer relative to the information that should be discussed within this attribute. The guidance needs to address the expectations for the ‘Detection of Aging Effects’ attribute for all four types of aging management programs and activities: prevention, mitigation, condition monitoring, and performance monitoring. The propose

provide detaireviewer and describing hobe detected. provide experelevant to thmanagement The SRP-LR this commenadding three in Section A.Aging Effect: “1. Detection occur before structure and function(s). Tmonitored or appropriate tstructure and function(s) wmaintained founder all CLB This includes method or tevolumetric, sfrequency, sacollection and time inspectio
NUREG-1739 B.2.14-4 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA. 1-4 (cont.) visual, volumetric, surface inspection), frequency, sample size, and timing of new/one-time inspections. Provide information that links the parameters to be monitored or inspected to the aging effects being managed. The method or technique and frequency may be linked to plant specific or industry wide operating experience. Provide justification, including codes and standards referenced, that the technique and frequency are adequate to detect the aging effects prior to a loss of SC intended function. The NRC staff position is that a program based solely on detecting SC failures is not considered an effective aging management program. When sampling is used to inspect a group of SCs, provide the basis for the inspection population and sample size. The inspection population should be based on aspects of the SCs such as a similarity of materials of construction, fabrication, procurement, design, installation, operating environments or aging effects. The sample size should be based on aspects of the SCs such as the specific aging effect, location, existing technical information, detection of a

information thto be monitoraging effects 3. This progr“when,” “whedata is collecactivities to cthe program)4. The methofrequency maspecific or indexperience. Pincluding codreferenced, tfrequency are the aging effeSC intended based solely failures is noeffective aginprogram. 5. When sama group of SCfor the inspecsample size. population shaspects of thsimilarity of mconstruction, procurementoperating enveffects. The sbased on aspas the specifexisting tech
April 2001 B.2.14-5 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA. 1-4 (cont.) system and structure design, materials of construction, service environment or previous failure history. The samples should be biased towards locations most susceptible to the specific aging effect of concern in the period of extended operation. Provisions should also be included on expanding the sample size when degradation is detected in the initial sample. system and s

materials of cenvironment history. The sbiased towarsusceptible to effect of concextended opeshould also bexpanding thdegradation sample.” To be consisprogram deschanges werGALL. A sentence wsentence in telement “Detin both SRP-GALL Volumincludes aspetechnique (i.esurface inspesample size, timing of newto ensure timeffects.” To be consischanges, the SRP-LR sectMonitoring anwas deleted. 
NUREG-1739 B.2.14-6 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.1-4 (cont.) sentence in t

element “Moin the SRP-LGALL Volumdeleted. The read, “The mtesting frequeshould be apdetection of a

SA.1-5 SRP App A.1 Section A.1.2.3.5 Monitoring and Trending This section should focus on what evaluations are performed after the results from performing the aging management program or activity are obtained. This section could be re-titled to be ‘Evaluation and Trending.” The use of the term ‘monitoring’ is ambiguous and confusing, because it relates to actually doing the aging management activity. This section should focus on the review or evaluation of the data obtained from the aging management program or activity described in the previous section. Quantitative results can be trended if appropriate. Past inspection results can be reviewed in preparation for a forthcoming inspection. This section does not currently provide enough guidance to the applicant or the reviewer relative to the information that should be discussed within this attribute. The guidance needs to address the expectations for the ‘Monitoring and Trending’ attribute for all four types of aging management programs and activities: prevention, mitigation, condition monitoring, and performance monitoring. Changing the 

Trending” waThe proposecontained unTrending” proto both the apreviewer deswith data colof Aging elemalso provide relevant to thmanagement The SRP-LR this commenelement #2 in page A-1.4 a “2. This prog“how” the datevaluated antrending for a includes an eagainst the aa prediction rdegradation timing of the 
April 2001 B.2.14-7 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.1-5 (cont.) The evaluation confirms that the structure or component will continue to meet its acceptance criteria through the next planned inspection. The “Evaluation and Trending” attribute should be revised to read as follows: This program element describes “how” the data collected is evaluated and may also include trending if a forward look is required. This includes an evaluation of the results against the acceptance criteria and a prediction regarding the rate of degradation in order to confirm that timing of the next scheduled inspection will occur prior to a loss of SC intended function. Although aging indicators may be quantitative or qualitative, aging indicators should be quantified, to the extent possible, to allow trending. Explain how the parameter or indicator will be trended. If not straightforward, describe the methodology for analyzing the inspection or test results against the acceptance criteria. This attribute is used for condition or performance monitoring programs that trend the results of the monitoring activities. Trending is a comparison of the current inspection wi

of SC intendeaging indicator qualitativeshould be qupossible, to aparameter or should be demethodology inspection or acceptance cdescribed. Trof the currenprevious monto make pred
NUREG-1739 B.2.14-8 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.1-5 (cont.) monitoring results with previous monitoring results in order to make predictions for the future. SA.1-6 SRP-LR A.1 Section A.1.2.3.6 The statement in the first paragraph that reads: “The program should include a methodology for analyzing the results against applicable acceptance criteria.” May be deleted if the changes noted in the previous section are made. Acceptance criteria can also be qualitative such as that used during a visual inspection. The specific feature of analyzing results is more appropriately included within the “Evaluation and Trending” attribute. Acceptance criteria can be both quantitative and qualitative and expectations for both need to be addressed. Analyzing res

acceptance cboth the “Moand the “Accelements. Acceptance cqualitative sua visual inspeThe SRP-LR this commenitem to Sectio“4. Qualitativperformed to criteria as quby personnel ASME Code site specific p

SA.1-7 SRP-LR A.1 Revise A.1.2.3.10, paragraph 1 to add the following statement: By providing the objective evidence, the demonstration required by §54.21(a)(3) is satisfied. In the checklist provided in SRP-LR Chapter 1, the staff is required to determine if the demonstration requirements of §54.21(a)(3) have been met. This additional statement is recommended in order to clearly establish what is meant by demonstration. The propose

operating expbe sufficient effects of agimanaged and applicant neeelements 1-9 aging managThe SRP-LR address this 
April 2001 B.2.14-9 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

S-A.1-8 A.1.2.1 Applicable and potential aging effects needs to be defined if it is determined that these are the correct terms to use. NEI 95-10 uses the term “aging effects requiring management.” Suggest using this term to be consistent with industry guidance. During the N

31 January 2was that the effect does nthreshold for requires manNEI agreed tcertainty wheeffect becomaging managdetermination engineering jThe SRP-LR address this 

S-A.1-9 A.1.2.1 Item No. 3 should be deleted. The rule only requires an applicant to demonstrate that the aging effects are managed. The applicant does not have to identify aging effects that it does not have to manage or justify why it does not have to manage those effects. NRC agrees 

not have to idthat it does njustify why it manage thosThe SRP-LRrevised to adrewriting the provide the rein questioninconcerning athe applicatio“If operating information inaging effect man applicant applicable to may question aging effect uprovided the 
NUREG-1739 B.2.14-10 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

S-A.1-9 (cont.) determination 

application. Hthe absence reference anprovides releapplicant in ashould be prothe question application recommunicatijudgment, reinformation, oexperience aquestion. Simaging effect ireport is not a example, the applicable to but the applicand does not component. Ithe GALL repchecklist is n

S-A.1-10 A.1.2.3.2 The second sentence under Item 2 states that “However, in many instances, more than one type of aging management programs are implemented to ensure that aging effects are managed.” This should be changed to: However, more than one type of aging management program may be implemented to ensure that aging effects are managed. This is not true and has not been the case with the first two approved licenses. See NRC dis

comment for Appendix B, 
April 2001 B.2.14-11 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

S-A.1-11 A.1.2.3.6 Delete the second sentence under Item 3 that discusses CLB design loads. Acceptance criteria, which do permit degradation, are based on maintaining the intended function under all CLB design loads. Therefore, this comment is irrelevant. Section A.1.2

Criteria, item reviewer guidcriteria for CLAcceptance cdegradation, maintaining tunder all CLB The SRP-LRItem 3, was rcomment as “3. It is not neacceptance cfrom the desthat is includebecause that Also, it is not CLB design lcriteria do nobecause a stwithout degrato function as Acceptance cdegradation, maintaining tunder all CLB 
NUREG-1739 B.2.14-12 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.2-1 SRP-LR App A.2 SRP-LR Appendix A.2, Section A.2.2, Item 2 contains that following statement that should be deleted: “The applicant should document such a commitment in the final safety analysis report (FSAR) supplement in accordance with 10 CFR 54.21(d).” In general, the SRP-LR contains guidance for the staff reviewers. Including a specific applicant requirement such as this should not be in the SRP-LR. The specific content of the FSAR supplement is already provided by examples contained in all appropriate sections of the SRP-LR. This issue of documenting this commitment should be contained in each example FSAR summary description. If necessary, it can be placed in brackets to indicate that whether or not to include the statement is a plant specific decision. The intent of 

Section A.2.2guidance to Nperforming saapplications aapplicant reqThe SRP-LR FSAR summthe decision statements is decision. Revtables to inclthat this is a would complThe SRP-LR were not updThe SRP-LRNo.2, was revcomment by sentence from document sufinal safety asupplement i10 CFR 54.2should verify documented the FSAR suaccordance w

SA.3-1 SRP-LR App A.3 SRP-LR Appendix A.3, Section A.3.2.1, Item 2, states that “the version of NUREG-0933 that is current on the date 6 months before the date of the license renewal There is routinely several weeks delay from the time the revision is finished until the time it is published and available to the public. Updates of N

planned apprmonths and, is a more curinformation th
April 2001 B.2.14-13 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.3-1 (cont.) application...” Revise this review process to include as a viable alternative an applicant’s review of the annual staff report to the Commission of the activities related to Generic Safety Issues. An approach needs to be developed to address any new issues that reveal themselves over the course of the review of license renewal applications. In SECY-98-030, the Commission directed the staff to provide an annual summary of activities related to open reactor and non-reactor GSIs. These annual summaries of activities have been recently provided in SECY-98-166, July 6, 1998; SECY-99-185, dated July 16, 1999; and most recently in SECY- 00-0149, dated June 30, 2000. It appears that these annual reports from the staff and to the Commission may be a reliable alternative to the actual release of supplements to NUREG-0933 and more useful to applicants in determining the current status of open GSIs. the Commiss

NUREG-093discussion of would still nethe annual reapplicant is prenewal applNUREG-093period, the Ncontacted for status. The approacdetermine the applicant to ageneric issue between the Renewal Stethe NEI LicenGroup on Deissue is identevaluated by management ability of the reasonable aactions have manage the ethe period of the functionacomponents review. If thamade, the apthe issue befcan be issueThe SRP-LR
NUREG-1739 B.2.14-14 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.3-1 (cont.) Item 2, was r

comment reg0933.by addisentence: “Pany new issuversions of Nreviewed and to be applicaplant.” SA.3-2 SRP-LR App A.3 SRP-LR Appendix A.3, Section A.3.2.1, Item 3, states that “the amendment to the license renewal application identifying current licensing basis (CLB) changes, as required by 10 CFR 54.21(b), should address any additional USI, HIGH-, or MEDIUM- priority issues designated after the application has been submitted...” §54.21(b) requires an applicant to submit an amendment to the application that addresses and changes to the CLB that materially affect the contents of the application. Changes to NUREG-0933 are not considered to be changes to the plant CLB. Therefore, it is inappropriate to include them within the §54.21(b) amendment to the application. An approach needs to be developed to address any new issues that reveal themselves over the course of the review of license renewal applications. New GSIs ide

review of a licapplication aThis is consisCommission’Statements o10 CFR Part 1995 (60 FR identified invoor a time-limineeds to be ebe submitted application. The approacdetermine the applicant to ageneric issue between the Renewal Stethe NEI LicenGroup on Deissue is identevaluated by management ability of the reasonable a
April 2001 B.2.14-15 NUREG-1739 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.3-2 (cont.) actions have 

manage the ethe period of the functionacomponents review. If thamade, the apthe issue befcan be issueThe SRP-LR 3, was revisecomment by read “New gedesignated aMEDIUM- priapplication hinvolve aging and componemanagement be submitted the applicatio

SA.3-4 SRP-LR App A.3 SRP-LR Appendix A.3, Section A.3.2.1, Item 4, states that “During the preparation and review of a license renewal application, an applicant or the NRC may become aware of an aging management or TLAA issue that may be generically applicable to other nuclear units. If issues may have generic applicability (but are not yet part of the formal generic safety issues resolution process as identified in NUREG-0933), an applicant should still address the issue to In general, the SRP-LR contains guidance for the staff reviewers. Including a specific applicant requirement such as this should not be in the SRP-LR. An approach needs to be developed to address any new issues that reveal themselves over the course of the review of license renewal applications. The threshold of when an issue becomes of concern during the license renewal application review needs to be clearly defined. See NRC dis

comment SATable B.2.14approach useidentifying nethe variety of may arise, boprocess, it is establish spepossible issuconcern for liissue will be and managemdiscussed in 
NUREG-1739 B.2.14-16 April 2001 Table B.2.14: Disposition of NEI Comments on Appendix A of SRP-LR (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

SA.3-4 (cont.) demonstrate that the effects of aging are or will be adequately managed or that TLAAs have been evaluated for the period of extended operation.” referred to in 

The SRP-LR address this 

SA.3-5 SRP-LR App A.3 SRP-LR Appendix A.3.3 References indicates that the current version of NUREG-0933 is Supplement 23, April 1999. The SRP-LR should be revised to reflect the actual current version - Supplement 24, June 2000. Table A.3-1 should be updated to include issues are not in NUREG- 0933 but have been identified to be addressed during the initial applicant reviews. As of September 19, 2000, the NRC web site also lists Supplement 23 as the current version of NUREG-0933. The SRP-LR may not be updated as often as NUREG-0933 is revised. Specification of a specific supplement of NUREG-0933 in the SRP-LR may be counterproductive. In addition, the NRC web site needs to also be kept current with respect to NURG-0933, and its most recent supplement issued. As an aid to both applicants and staff reviewers, Table A.3-1 should be updated annually to reflect the emerging issues that need to be reviewed during license renewal. See NRC dis

comment SATable B.2.14The Office of Regulation wOffice of Regregarding upNUREG-093NRC’s Web sTable A.3-1 iillustration of used to deterneeds to be arenewal applintended to bapplicable issapplicant. Thissues that aaddress can NUREG-093renewal appldiscussions wThe SRP-LRReference 1 this commensupplement (NUREG-093
APPENDIX B, TABLE B.2.15

DISPOSITION OF WRITTEN

GENERIC NEI COMMENTS
B.2.15-ii

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April 2001 B.2.15-1 NUREG-1739 Table B.2.15: Disposition of Written Generic NEI Comments Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NEI-1 B.3.2 Based on the lessons learned from the review of the first few renewal applications, the GALL provides sufficient credit for existing programs. As renewal applications continue to be submitted and reviewed, the NRC should consider future revisions to GALL to capture any additional lessons learned. The GALL report is somewhat limited in that the existing programs must be generic. Obviously, renewal applicants will credit existing programs that are plant specific but at this time it seems that the focusing GALL on the generic programs is appropriate. See NRC dis

ACRS-2 in T

NEI-2 B.3.2 The GALL report does not provide too much credit for existing programs. The programs credited in GALL are a reflection of the programs credited in the first few renewal applications. The technical detail is sufficient. The GALL evaluates the existing programs against ten attributes that are typically found in adequate aging management programs. The commen

the GALL repprograms. The GALL readdress this 
NUREG-1739 B.2.15-2 April 2001

Table B.2.15: Disposition of Written Generic NEI Comments (continued)

Comment

Number

Item

Number Comment/Proposed Change Basis For Comment NR

NEI-3 B.3.2 While we do not agree that all ten

elements need to exist for aprogram to be found adequate, thefact that GALL uses all them is atestament to the robustness of thetechnical evaluation.

The GALL rerequirement, document; thproposed wildetermine whrequirements renewal rule. evaluation apwell in the GAreview of the applications.See NRC disNMC-3 in Tafor a discusswill use the Sto evaluate pThe GALL readdress this 

NEI-4 B.3.2 If a specific revision of a code - say

those published by the AmericanConcrete Institute (ACI), isreferenced and evaluated in GALL arenewal applicant can indicate thatthey use the same program at theirfacility and rely on the GALLevaluation. If the ACI standard usedby an applicant is different from thatin the GALL then the applicant mustdemonstrate that its program isadequate in the areas which differbetween the standard revisioncontained in GALL and the revisionof the standard which the applicantuses.

See NRC disACRS-2 in T
April 2001 B.2.15-3 NUREG-1739 Table B.2.15: Disposition of Written Generic NEI Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NEI-5 B.3.2 This question addresses the staffs desire for an applicant to discuss, in its application, any aging effects identified in the draft GALL report for a particular structure or component that the applicant has determined to be not applicable to its plant. It appears that the GALL identified aging effects are to be used by the staff as a checklist of those that require management. This implies that it would be acceptable for an applicant to use the GALL to determine which aging effects require management. Is this the staffs intent? Is it acceptable for an applicant to refer to the GALL for a particular system or structure with the same materials and environments as those identified in the GALL, and use it as a basis for conclusions regarding the aging effects requiring management? If the GALL is intended to provide guidance regarding the need to manage certain aging effects as well as guidance on the adequacy of existing plant programs, then this appears to be an acceptable approach. See NRC dis

NMC-8 in Ta
NUREG-1739 B.2.15-4 April 2001

Table B.2.15: Disposition of Written Generic NEI Comments (continued)

Comment

Number

Item

Number Comment/Proposed Change Basis For Comment NR

NEI-6 B.3.3 It is not clear what type of

certification is acceptable nor is itclear what the NRC staff will look forif they examine the on-siteverification documents.

Some insight into the certificationquestion is found in the StandardReview Plan. We believe thelanguage in Subsection 3.1.3.1 isthe appropriate language if anapplicant is relying in a programevaluated in the GALL report. Werecommend the other sections andsubsections in the SRP-LR berevised to be consistent withsubsection 3.1.3.1.

See NRC disNMC-2 in Ta

NEI-7 B.3.3 When a program evaluation in GALL

concludes that no further evaluationis necessary, there should be astatement that the program isadequate and demonstrablyeffective in managing aging in theperiod of extended operation.

See NRC disNMC-2 in Ta

NEI-8 B.3.3 We would appreciate the

opportunity to discuss with NRCstaff the possibility of a programevaluation for IWB-2500 with theNRC staff. We are willing to providedraft evaluations for the NRC staffreview but believe it’s important toreach agreement with the NRC staffon how that evaluation will bepartitioned.

The GALL reevaluates agprogram XI.MInservice InsIWB-2500, IW2500.”The GALL readdress this an evaluation AMP XI.M1.

NEI-9 B.3.4

Reg. Guide

Does the Reg. Guide need toaddress the issue of electronicsubmittal.

None Provided See NRC dis

DG-1104-2 in NUREG.
April 2001 B.2.15-5 NUREG-1739 Table B.2.15: Disposition of Written Generic NEI Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NEI-10 B.3.5 NEI 95-10 Make changes to NEI 95-10 None Provided Appropriate c

incorporated The GALL readdress this 

NEI-11 B.3.5 NEI 95-10 Incorporating guidance on the use of GALL None Provided See NRC dis

NMC-2 in Ta

NEI-12 B.3.5 NEI 95-10 Updating Appendix B consistent with the comments provided on GALL None Provided Appropriate c

incorporated The GALL readdress this 

NEI-13 B.3.5 NEI 95-10 Refinements to the standard applicant format guidance in chapter 6 None Provided Appropriate c

incorporated The GALL readdress this 

1 B.3.9 NEI 95-10 Sect. 1.5 NEI 95-10, Section 1.5 discusses resolution of current safety issues. SRP-LR Appendix A.2 provides a similar discussion. The current descriptions are not consistent and the threshold for addressing new issues may be too low. An approach needs to be developed to address any new issues that reveal themselves over the course of the review of license renewal applications. See NRC dis

this Appendix The SRP-LR this commenspecific guidaresolving curissues. 2 B.3.9 NEI 95-10 Sect. 5.1.3 NEI 95-10, Section 5.1.3 should be revised to delete the following statement: “ For example, poisons in the high density spent fuel racks have coupons that are periodically removed and tested to verify that the rack continues to be capable of performing its intended function.” Aging of neutron absorber in the spent fuel rack is no longer considered to be a generic TLAA. Note that Section X of the SRP-LR contains several TLAA program descriptions NEI 95-10, Rchanges as aconsistent wiguidance doc
NUREG-1739 B.2.15-6 April 2001

Table B.2.15: Disposition of Written Generic NEI Comments (continued)

Comment

Number

Item

Number Comment/Proposed Change Basis For Comment NR

3 B.3.9

NEI 95-10Sect. 6.2

NEI 95-10, Section 6.2, Table 6.2-1should be revised to deleteSection 3.1 of the Application Tableof Contents and renumber theremaining Chapter 3 sections toalign with equivalent sections of theSRP-LR.

Alignment of the documents. NRCSRP-LR no longer has a section 3.1describing common agingmanagement programs

NEI 95-10, Rchanges as aconsistent wiguidance doc

4 B.3.9

NEI 95-10Sect. 6.2

NEI 95-10, Section 6.2, Table 6.2-1should be revised to deleteSection 4.7 of the Application Tableof Contents and renumber theremaining Chapter 4 section to alignwith equivalent sections of theSRP-LR.

Alignment of the documents – Asnoted above, aging of neutronabsorber in the spent fuel rack is nolonger considered to be a genericTLAA.

NEI 95-10, Rchanges as aconsistent wiguidance doc

5 B.3.9

NEI 95-10Sect. 6.2

NEI 95-10, Section 6.2, Table 6.2-2should be revised to deleteSection 4.7 of the Application Tableof Contents and renumber theremaining Chapter 4 section to alignwith equivalent sections of theSRP-LR.

Alignment of the documents – Asnoted above, aging of neutronabsorber in the spent fuel rack is nolonger considered to be a genericTLAA.

NEI 95-10, Rchanges as aconsistent wiguidance doc

6 B.3.9

NEI 95-10Sect. 6.2

NEI 95-10, Section 6.2, Table 6.2-2should be revised to deleteSection 3.7 of the Application Tableof Contents and renumber theremaining Chapter 3 section to alignwith equivalent sections of theSRP-LR.

Alignment of the documents. NRCSRP-LR no longer has a section 3.1describing common agingmanagement programs

NEI 95-10, Rchanges as aconsistent wiguidance doc

7 B.3.9

NEI 95-10Sect. 6.2

NEI 95-10, Section 6.2, Table 6.2-2should be revised to offer guidanceto applicants for using the GALLreport as part of the agingmanagement review.

TBD See NRC dis

comment 1 in Table B.2.15
APPENDIX B, TABLE B.2.16

DISPOSITION OF NEI COMMENTS

SUBMITTED AT MEETING BETWEEN NEI

AND NRC ON NOVEMBER 8, 2000
B.2.16-ii

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April 2001 B.2.16-1 NUREG-1739 Table B.2.16: Disposition of NEI Comments Submitted at Meeting between NEI and NRC on November 8, 2000 Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

NEI-14 B.3.10 Chapters V and VII The Refueling Water System is in Auxiliary Systems in NUREG-0800 and in Engineered Safety Features in GALL/SRP-LR. GALL/SRP-LR states that it is consistent with NUREG-0800 in the placement of items in systems. The refueling 

located in ESF because its msupply water tThe RWST is connected to b(NUREG-0800 and ESF 6.3 (Engineered SaThe SRP-LR, was revised to comment by sthese SRP-LR NUREG-0800 consistent excsystems. NEI-15 B.3.10 Chapters V and VII The Control Area Ventilation and Chilled Water are in Engineered Safety Features in NUREG-0800 and in Auxiliary Systems in GALL/SRP-LR. GALL/SRP-LR states that it is consistent with NUREG-0800 in the placement of items in systems. The control rois located in E0800. Howevesystems are lo0800 Auxiliary Chapter 9. Se9.4.5 cover ve9.4.1 is for the ventilation syssystems were Chapter VII (AThe SRP-LR, was revised to comment by sthese SRP-LR NUREG-0800 consistent excsystems.
NUREG-1739 B.2.16-2 April 2001 Table B.2.16: Disposition of NEI Comments Submitted at Meeting between NEI and NRC on November 8, 2000 (co

Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

NEI-16 B.3.10 Chapters V and VII Residual Heat Removal is in Engineered Safety Features in NUREG-0800 and in Auxiliary Systems and Engineered Safety Features in GALL/SRP-LR. GALL/SRP-LR states that it is consistent with NUREG-0800 in the placement of items in systems. The residual h

system is in ENUREG-0800 cooling system no ESF functioauxiliary wateper NUREG-0The SRP-LR, was revised to comment by sthese SRP-LR NUREG-0800 consistent excsystems. NEI-17 B.3.10 Chapters VII and VIII Condenser Circulating Water is in Steam and Power Conversion System in NUREG-0800 and in Auxiliary Systems in GALL/SRP-LR. GALL/SRP-LR states that it is consistent with NUREG-0800 in the placement of items in systems. The circulating located in 10.4steam and powsystems). The systems are lo(NUREG-0800 The raw water together in ChGALL. The SRP-LR, was revised to comment by sthese SRP-LR NUREG-0800 consistent excsystems.
April 2001 B.2.16-3 NUREG-1739 Table B.2.16: Disposition of NEI Comments Submitted at Meeting between NEI and NRC on November 8, 2000 (co

Comment Number Item Number Comment/Proposed Change Basis for Comment NRC 

NEI-18 B.3.10 Chapters VII and VIII Condensate Storage System is in the Auxiliary System in NUREG- 0800 and in Steam and Power Conversion System in GALL/SRP- LR. GALL/SRP-LR states that it is consistent with NUREG-0800 in the placement of items in systems. The condensa

are located in Auxiliary Systefeedwater sys10.4.9 (NUREPower ConverAFWS takes scondensate stlocated in AUX condensate syGALL is locateCondensate aof NUREG-08The SRP-LR, was revised to comment by sthese SRP-LR NUREG-0800 consistent excsystems. NEI-19 B.3.10 Chapter VII The Spent Fuel Racks, the Spent Fuel Pool and the Fire Barriers are located in Auxiliary Systems in NUREG-0800 and in GALL/SRP- LR. However, these systems are structural and have been put in the structures and component supports in the license renewal application. These systems require structure and component support review. The fire barrieother fire proteAuxiliary Systespent fuel rackpool were keppool cooling aBWR) in Auxilas in NUREG-The SRP-LR waddress this c
NUREG-1739 B.2.16-4 DRAFT- March 1, 2001 This Page Intentionally Left Blank
APPENDIX C

DISPOSITION OF WRITTEN

PUBLIC COMMENTS
C-ii

This Page Intentionally Left Blank
April 2001 C-1 NUREG-1739

C.1. INTRODUCTION

On August 31, 2000, four documents comprising the draft license renewal guidance documents

for implementation of 10 CFR Part 54 were made available for public comment on the Web site

page http://www.nrc.gov/NRC/REACTOR/LR/guidance.html.

The public was requested to submit comments on the Draft Regulatory Guide DG-1104, the

draft SRP-LR, the draft GALL report, and NEI 95-10 (Revision 2), by October 16, 2000. In

addition, the NRC invited public comments on all information contained in these draft

documents, but particularly solicited responses to the four questions described fully in the

Federal Register Notice of August 31, 2000 (65 FR 53047).

Table C, at the end of Appendix C, contains the written comments or a summary of the written

comments received. This Appendix C includes 226 written comments, with 153 from individuals

representing public interest groups, 70 from individuals representing industry groups, and 3 from

the ACRS.
NUREG-1739 C-2 April 2001

C.2. EVALUATION AND DISPOSITION OF COMMENTS

Table C, at end of Appendix C, contains comments received from various public interest groups,

industry groups, the Advisory Committee on Reactor Safeguards, and individuals.

The column heading, “Comment Number,” is primarily intended to identify the source of the

comment (i.e., the organization or individual that submitted the comment). For example, DP-3

indicates that the comment was made by Duke Power Company, and the “3” distinguishes this

comment from all other Duke Power Company comments. The exceptions are the comments

from Indiana and Michigan Power (DG-1104-1 through DG-1104-2, GALL-1 through GALL-17,

and SRP-LR-1 through SRP-LR-2); the comment from Omaha Public Power District

(H. Kenneth-1); and those from the 113 individuals, which were numbered as originally

submitted. The abbreviations used in this appendix are listed in the front matter of this NUREG.

The numbers on the first line for each line item under the column heading, “Item Number,”

indicate the listing number of a particular group of comments identified in Section C.3. The items

on the second or subsequent lines for each line item under this column heading concern the

applicable section of a license renewal guidance document on which a comment was made.

References for all comments listed in Section C.3 are provided in Section C.4.

All comments are in alphanumerical order. These comments were not always dispositioned in

the order in which they appear. For example, the disposition for comment “CAN-1” may refer to

the disposition for comment “CAN-3” for its resolution, which means “CAN-1” was dispositioned

after “CAN-3” even though it precedes “CAN-3” in the alphanumerical order presented.
April 2001 C-3 NUREG-1739

C.3. ORIGIN OF COMMENTS

1. ACRS-2 through ACRS-4 See Section C.4, Reference No. 1

2. CAN-1 through CAN-11 See Section C.4, Reference No. 2

3. C&PL-1 See Section C.4, Reference No. 3

4. COMED-1through COMED-4 See Section C.4, Reference No. 4

5. DG-1104-1 through DG-1104-2 See Section C.4, Reference No. 5

6. DP-1 through DP-10 See Section C.4, Reference No. 6

7. GALL-1 through GALL-17 See Section C.4, Reference No. 7

8. General Public Comments See Section C.4, Reference No. 8

9. HKenneth-1 See Section C.4, Reference No. 9

10. I&M-1 through I&M-17 See Section C.4, Reference No. 10

11. KDrey-1 through KDrey-13 See Section C.4, Reference No. 11

12. KOPEC-1 See Section C.4, Reference No. 12

13. NIRS-1 through NIRS-8 See Section C.4, Reference No. 13

14. NMC-1 through NMC-8 See Section C.4, Reference No. 14

15. PECO-1 See Section C.4, Reference No. 15

16. SRP-LR-1 through SRP-LR-2 See Section C.4, Reference No. 16

17. UCS-1 through UCS-5 See Section C.4, Reference No. 17

18. UCS-6 through UCS-9 See Section C.4, Reference No. 18

19. VP-1 See Section C.4, Reference No. 19

20. WESCO-1 See Section C.4, Reference No. 20

21. W&S-1 through W&S-4 See Section C.4, Reference No. 21
NUREG-1739 C-4 April 2001

C.4. REFERENCES

Letter to Chairman Meserve, NRC, from Dana Powers, ACRS, dated November 15, 2000.

Letter to David Meyers, NRC, from Citizens Awareness Network, dated October 16, 2000.

Letter to Secretary of the Commission, NRC, from Terry C. Morton, Carolina Power and Light

Company, dated October 16, 2000.

Letter to Chief, Rules and Directives Branch, NRC, from R.M. Krich, Commonwealth Edison

Company, dated October 16, 2000.

Letter to Chief of Rules and Directives, NRC, from M.W. Rencheck, Indiana Michigan Power,

dated October 14, 2000.

Letter to David Meyers, NRC, from M. S. Tuckman, Duke Power Company, dated October 16,

2000.

Letter to Chief of Rules and Directives, NRC, from M.W. Rencheck, Indiana Michigan Power,

dated October 14, 2000.

Letters emailed or submitted by 104 individuals.

Email from Henry Kenneth, dated October 4, 2000.

Letter to Chief of Rules and Directives, NRC, from M.W. Rencheck, Indiana Michigan Power,

dated October 14, 2000.

Letter to David Meyers, NRC, from Kay Drey, University City, Missouri, dated October 16, 2000.

Letter (emailed) to David Meyers, NRC, from Hagki Youm, Korea Power Engineering Company,

dated December 20, 2000.

Letter to David Meyers, NRC, from Paul Gunter, Nuclear Information and Resource Service,

dated October 16, 2000.

Letter (emailed) to David Meyers, NRC, from Douglas F. Johnson, Nuclear Management

Company, dated October 26, 2000.

Letter to Secretary, Rulemaking and Adjudications Staff, NRC, from James A Hutton, PECO

Nuclear, dated October 16, 2000.

Letter to Chief of Rules and Directives, NRC, from M.W. Rencheck, Indiana Michigan Power,

dated October 14, 2000.

Letter to Chief of Rules and Directives, NRC, from David A. Lochbaum, Union of Concerned

Scientists, dated October 6, 2000.

Letter to Chief of Rules and Directives, NRC, from David A. Lochbaum, Union of Concerned

Scientists, dated December 4, 2000.
April 2001 C-5 NUREG-1739

Letter to Chief, Rules and Directives Branch, NRC, from William F. Renz, Virginia Power, dated

October 16, 2000.

Letter to Sam Lee, NRC, from Arnold. H. Fero, Westinghouse Electric Company LLC, dated

December 22, 2000.

Letter to David Meyers, NRC, from Kathryn M. Sutton, Winston & Strawn, dated October 16,

2000.
NUREG-1739 C-6 April 2001 Table C: Disposition of Written Public Comments Comment Number Item Number Comment/Proposed Change Basis For Comment NR

ACRS-2 C.3.1 The staff should update the Generic Aging Lessons Learned (GALL) report as lessons are learned from reviewing future license renewal applications and as the staff approves new editions of codes and standards. Since the preparation and review of future applications are likely to result in a significant number of new lessons learned, the staff should update the GALL report to incorporate the lessons learned. The provisions of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code have been codified in 10 CFR 50.55a. The staff has been amending 10 CFR 50.55a periodically to incorporate later editions of the ASME code. During periodic revision of 10 CFR 50.55a, the staff plans to evaluate the adequacy of these later editions for license renewal using the criteria described in the SRP-LR. We believe this process is appropriate for the period of extended operation. The staff should update the GALL report to incorporate new editions of codes and standards for which a similar process does not exist. After resoluti

comments in will be periodlessons are lsubsequent lreviews. The frequency by made. In an August Register NotNRC solicited update the coreferenced in process to peupdated versinto the reguwith 10 CFR the GALL repremain valid the ASME Cointo the NRC 10 CFR 50.5will evaluate later editions However, thecodes and stsubject to the process in 10 The most flexspecify in GAcodes and/or required to pmanagementreferencing t
April 2001 C-7 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

ACRS-2 (cont.) providing an 

management references a providing an management could compastandards anapplication hthe code or sequivalent agprogram. Another apprbeen recommof the public Federal Regibe to call out standards as acceptable aprogram and review revisiostandards refthey are pubGALL, as necrequire licensdescribe comversions if threvised GALL versions. Botacceptable. The GALL renot revised to comment.
NUREG-1739 C-8 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

ACRS-3 C.3.1 The staff should validate that the artificially aged cables used in the studies conducted to address GSI-168 issues are representative of 30-40 year old cables. Until GSI-168, which deals with environmental qualification of low- voltage instrumentation and control cables, is resolved, aging management of such cables will continue to be addressed through plant-specific programs. It does not appear that condition monitoring is a reliable predictor of future performance of cables under accident conditions. Testing of cables, which have undergone accelerated aging, identified severe degradation. The staff should validate that the artificially aged cables used in the accelerated aging studies conducted to address the issues of GSI-168 are representative of 30-40 year old cables. We plan to review this issue during our review of the proposed resolution of GSI-168. The intent of 

recommendaaddressed in research actisupport of the on EnvironmLow-Voltage Control (I&C) included direbetween artifaged cables, aged cables service were decommissioplants. The operatinenvironment cables was drecords. Six saccident (LOto validate thcables are reyear-old cablwere conducgroups of cabcables artific20, 40, and 6service life, acables retrievdecommissio24 years of sThe results sexception of Moore cables
April 2001 C-9 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

ACRS-3 (cont.) cables passe

equivalent of service life. Fthe Okonite acables are cuaddressed thresolution proshowed that cables, when equivalent yeconditions in radiation envbetter in termwithstand LOartificially ageTherefore, adfurther validacables represyear-old cablThe GALL renot revised to comment. ACRS-4 C.3.1 The staff and the industry should provide consistent guidance of the use of emergency operating procedures (EOPs) and severe accident management guidelines (SAMGs) as possible information sources to verify that equipment important to safety has not been inadvertently left out by the license renewal rule scoping process. The SRP-LR provides guidance to review the adequacy of the scoping and screening processes used by the licensees to identify structures and components that are subject to an aging management review. As the first two applications demonstrated, the scoping process for older plants is a challenging task that does not lend itself to a standard procedure. Systems and components in scope are identified EOPs and SA

information sthe structurescomponents license renewEOPs are list2.1-1, “SampInformation SIn a public m2000, the sta
NUREG-1739 C-10 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

ACRS-4 (cont.) based on a review of accident analyses that are part of the current licensing basis (CLB) of the plant. The accident analyses, especially those of older plants, provide abbreviated descriptions of events and seldom identify all of the equipment required to achieve safe shutdown. More detailed information is contained in the emergency operating procedures (EOPs) that are referenced in the Final Safety Analysis Report and, thus, are part of the CLB of the plant. However, the scoping process defined by the license renewal rule does not explicitly include the EOPs as a source of information to identify equipment in scope. In contrast, the maintenance rule explicitly includes the EOPs as a source of information to identify equipment in scope. As a result, there may be equipment whose active components are within the scope of the maintenance rule but its passive long-lived components are not within the scope of the license renewal rule. We recognize that most of the equipment used in the EOPs will be identified by the license renewal rule scoping process. The EOPs are already listed in Table 2.1-1 of the SRP-LR as a possible information source. However, they are not listed these docum

Table 3.1-1, Potential Infopotential info95-10 was siaccordingly. SRP-LR was comment by Table 2.1-1 brevised.
April 2001 C-11 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

ACRS-4 (cont.) as a possible information source in the corresponding Table 3.1-1 of NEI 95-10. We recognize that the EOPs are not within the scope of the license renewal rule. However, we believe that it would be prudent for the industry and the staff to include the EOPs in the guidance documents as a possible information source. This would confirm that equipment important to safety has not been omitted inadvertently in the scoping process, rather than leaving it to the individual reviewers to deal with this issue. Severe Accident Management (SAM) guidelines are currently implemented at all plants, are part of the CLB, and are tied to the EOPs. Operators are routinely trained on their use. However, SAM guidelines were developed as a voluntary industry initiative. The equipment used to support these guidelines is not necessarily within the scope of the license renewal rule. The SAM guidelines should be identified as a potential source of information in Table 2.1-1 of the SRP-LR and Table 3.1-1 of NEI 95- 10 to confirm that equipment important to safety has not been omitted inadvertently in the scoping process.
NUREG-1739 C-12 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-1 C.3.2 Based on industry experience with aging reactor degradation and embrittlement, and the ongoing erosion of hearing rights and democratic safeguards afforded the public in the Atomic Energy Act, CAN opposes a generic relicensing program. This easing of regulatory burden has truncated the ability for public to participate in matters of vital importance to their communities None Provided. See NRC dis

KDrey-1 and Table C. CAN-2 C.3.2 CAN believes that the NRC’s proposal for a generic relicensing process will jeopardize the health and safety of workers and the public. The absence of effective regulatory oversight has in fact compromised the health and safety in numerous communities in the Northeast. The process of evaluating whether a reactor should win approval from the NRC to relicense is complex and should be determined on a case by case basis, since most reactors in the U.S. have individual designs, management processes, and associated problems. We do not believe that the regulatory burden on licensees should be eased. In fact, CAN believes as reactors age and deteriorate more regulatory oversight is required to protect the worker and public health and safety and the environment. This move None Provided. See NRC disKDrey-1 and Table C. The review oapplication is case basis. Also see NRC comments Nthis Table C.
April 2001 C-13 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-2 (cont.) increasingly toward industry self- regulation and the curtailing of NRC’s regulatory authority to intervene is also undermining the democratic safeguards provided for by the Atomic Energy Act. CAN-3 C.3.2 In fact, had effective oversight occurred through vigilant routine inspection, Yankee Rowe may not have received its original relicensing approval. None Provided. Yankee Row

renewed opeRowe did not extension in 10 CFR Part owner was othat initially erenewal, but part because with resolving the Yankee RThe GALL renot revised to comment. CAN-4 C.3.2 After Yankee Rowe and problems at other stations became know, NRC began requiring inspection of age- related degradations at reactors across the U.S. Through the program, NRC and industry discovered that components which were not included in original safety analyses and licensing bases were becoming dangerously embrittled. None Provided. In 1992, the Letter 92-01, Structural Intprogram to eintegrity and if needed, to and permit howith 10 CFR were fulfilling response to aGL88-11. Rebetter reflect the staff regaPower Statiointegrity, and 
NUREG-1739 C-14 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-4 (cont.) concerns rais

of reactor vesYankee Nuclwhat lead to licensees subrequested by In December issued its doclicensee respNUREG-151Vessel Statuits review the licensees to abut as a resurelevant to sethermal shocseveral plantconcluded thhave considethe responseRevision 1. Therefore, in GL 92-01, ReSupplement licensees reqreactor pressfall of 1996, tcloseout letteRevision 1, Sstated that no issues were astructural inteU.S. light-waissuance of GSupplement 
April 2001 C-15 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-4 (cont.) groups have 

initiative to coalloying chemproperty data plate, and wefabrication of vessels. In adrequirements result of the rThe GALL renot revised to comment. CAN-5 C.3.2 Nevertheless, a 1999 NRC report on the core shroud at Nine Mile Point Unit 1 – the oldest reactor still operating in the U.S., and the worst example of age-related degradation among BWRs noted that the chances of catastrophic failure of the core shroud in the case of a design basis earthquake were 1:100,000. NMP’s companion reactor, Nine Mile Point Unit 2, is 10 years younger, but showed similar signs of significant core shroud cracking after only 10 years of operation, with no history of poor water chemistry: 25% through-wall cracks, spanning 80% of the horizontal beltline weld. Cracking of the core shroud can lead to a loss of coolant accident, as can be embrittled reactor vessel. See previous column. In a letter dat

1999, from BDirector OfficRegulation, tSyracuse PeBurnet Avenu(ADAMS docNumber ML9forwarded the Decision Und(ADAMS docNumber ML9these matters Point Unit 1. The GALL renot revised to comment.
NUREG-1739 C-16 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-6 C.3.2 The basis for a generic environmental impact statement on license renewal is nonexistent, since existing material conditions monitoring programs are unable to keep pace with aging-related degradation at current reactor sites. None Provided. The generic e

statement is 10 CFR Part Protection ReLicensing anFunctions.” Astructures, sycomponents license renewby 10 CFR P10 CFR Part See NRC disKDrey-1 in thThe GALL renot revised to comment. CAN-7 C.3.2 The NRC has only managed to effectively regulate aging reactors such as Yankee Rowe, Main Yankee, Connecticut Yankee, and Millstone Units 1, 2 and 3, and Vermont Yankee through intensive oversight necessitated by site- specific review of plant operations and material condition and the pressure of the public and public interest groups intent on protecting their communities from nuclear devastation. None Provided. In accordancRevised Rea(RROP), the inspection rewith licensee Licensee’s thproblems recattention. Foof the RROP address http://www.nr

HT/index.htmThe GALL renot revised to comment.
April 2001 C-17 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-8 C.3.2 Furthermore, NRC’s existing methods for mitigating the safety significance of material degradation problems have already proven to be inadequate, because of the pace of embrittlement and the changing conditions of nuclear power operations. The steam generator tube rupture at Indian Point Unit 2 in February 2000 is an excellent example of the present lack of adequate NRC oversight at nuclear stations and the need for more stringent NRC oversight of material condition problems. See NRC dis

KDrey-12 anNIRS-8 in thi

CAN-9 C.3.2 Leak-before-break standard for mitigating accident scenarios have proved unrealistic, endangering workers as well as the public. None Provided. Previously ad

described in comment CA

CAN-10 C.3.2 The issuance of a generic environmental impact statement on license renewal also impacts decommissioning and the ultimate disposition of reactor sites. Industry officials have stated that licensees may only be interested in operating reactors for a portion of the twenty years of extended license life, allowing Decommissioning trust funds to accrue in order to ensure adequate funding before beginning cleanup. However this option is still available under the existing license through the NRC approved SAFSTOR method, since license termination is not mandated until 60 years after licensed operation has ceased. Yet NRC regulations have changed to permit a wide range of decommissioning activities to occur under the normal operating license, which creates a potential for licensees constructing new None Provided. Licensees wh

in accordancand (ii) are prestarting. If a construct a nof a currently reactor they wa new operataccordance w10 CFR Part The GALL renot revised to comment.
NUREG-1739 C-18 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

CAN-10 (cont.) generating stations on-site before decommissioning and site cleanup have even been completed. This regulatory morass has the potential to allow the construction of new reactors on the old sites under the extended license – without the necessity of applying for the new license – and therefore effectively block the democratic participation of affected communities mandated under the Atomic Energy Act section 189a. CAN-11 C.3.2 Setting aside the licensed authority set forth in the Atomic Energy Act would undermine the Commission’s ability to oversee the construction and operation of new nuclear reactors, prohibit the proper decommissioning on of the originally licensed facilities, and thereby endanger the worker and public health and safety and the environment. None Provided. See NRC dis

KDrey-1 and Table C. In addition, th10 CFR Part automatically requirement reactor at the license. The GALL renot revised to comment. COMED-1 C.3.4 Com Ed has been actively involved with the Nuclear Energy Institute NEI) on this issue and endorses the industry comments submitted by the NEI. None Provided. See NRC discomments in NUREG.
April 2001 C-19 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

COMED-2 C.3.4 ComEd is concerned about how the GALL Report and the associated guidance for its use will treat plants that are not subject to the GDC of 10 CFR Part 50, Appendix C A, or the Standard Review Plan (NUREG- 0800 SRP-LR). It is very likely that an applicant will reference, in whole or part, the report in its license renewal application. Thus, it is important that the GALL Report and its associated guidance recognize that differences exist in licensees’ current licensing basis and provide flexibility to accommodate these differences. See NRC dis

NMC-1, NMCTable C. COMED-3 C.3.4 As it stands now, the GALL Report and its associated guidance more frequently reference the most current version of codes, standards and other guidance. This may limit the usefulness of the GALL Report and its associated guidance for older plants, such as Dresden and Quad Cities. This is because some programs for these older plants do not incorporate all of the features subsequently required by the NRC for newer plants and may not fully meet all ten of the criteria in the SRP- LR. See NRC disARCS-2, NMNMC-3 in this 

COMED-4 C.3.4 Consequently, ComEd believes that the GALL Report and its associated guidance should clarify that aging management programs based on earlier versions of codes, standards and other guidance document are not excluded from use by these older plants. This flexibility could be incorporated by expanding the scope of the GALL Report to either include previously approved programs or to modify the acceptance criteria by which plants can certify that their programs are adequate for purposes of the GALL Report. See NRC dis

ARCS-2 in th

CP&L-1 C.3.3 CP&L endorses NEI comments transmitted by NEI letter dated October 13, 2000. None Provided. See NRC dis

comments in NUREG. DG-1104-1 (I&M) C.3.

5

Paragraph C.1

Contents of an Application:Consider adding a section thatwould refer to the more detailedguidance on use of the GALL report.

DG-1104 is the instruction topotential license renewal applicants.It should contain instructions on theproper use of the GALL report.

See NRC disNMC-2 in this 
NUREG-1739 C-20 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

DG-1104-2 (I&M) C.3.

5

Paragraph C3.2

Physical Specifications: Pleaseconsider adding specifications forelectronic submittal of applications(e.g. CDROM).

Electronic transmittal of submittalssuch as the UFSAR is nowaccepted. It is much more efficientto submit a large document such asa License Renewal Application onCDROM.

DG-1104 has RG 1.188, anprovides guidformats for eRG 1.188 adthe GALL repnot revised to comment.

DP-1 C.3.6 Duke agrees with NEI’s comments

on these draft license renewalimplementation documents.

None Provided. See NRC dis

comments in NUREG.

DP-2 C.3.6 What actions are required to be

taken in order to certify that anexisting, plant-specific programmatches the corresponding programdescribed in the GALL report. Whatstatement should be included in theapplication itself?

As currently drafted in both theGALL report and in the SRP-LR, theexpectations are not clear on thismost important point.

See NRC disNMC-2 in this 

DP-3 C.3.6 The Methodology discussed in the

SRP-LR, Section 2.1 does notcurrently acknowledge the use of abroader, more comprehensivescoping approach. SRP-LRSection 2.1 should clearly state thata system scoping is not required inconjunction with a commodityapproach or plant spaces approachto the integrated plant assessment.

Experience with Oconee licenserenewal indicates a need to makethis understanding clear toreviewers of renewal applications.

The SRP-LR require systeconjunction wapproach or in the integraThe GALL renot revised to comment.
April 2001 C-21 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

DP-4 C.3.6 SRP-LR, A.1 The process to identify those aging effects that require aging management during the period of extended operation is described in SRP-LR Appendix C A.1. Currently, this process does not discuss the necessary distinction between “aging effects that cause degradation” and “aging effects that cause degradation that could result in loss of structure or component intended function(s). The discussion in SRP-LR Appendix C A.1.1 needs to be revised to clearly state the expectations for identification of aging effects that require management during the period of extended operation; i.e., those that cause degradation that could result in loss of structure or component intended function. This revised discussion in Appendix C A.1.1 should then be applied to all listings in the GALL report to confirm that identified aging effects could result in a loss or intended function if left unmanaged during the period of extended operation. The criteria contained in SRP-LR Appendix C A.1 are overly broad, and are not linked to intended function, which could result in the implementation of new aging management programs and activities prematurely. The effects o

intended funccomponents. Appendix A, item 1, the laeffects of agifunctions of scomponents considered.” The GALL renot revised to comment.
NUREG-1739 C-22 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

DP-5 C.3.6 SRP-LR, A.1.2 The process to describe and demonstrate the effectiveness of aging management programs is contained in SRP-LR Appendix C A.1.2. The guidance in this Appendix C needs to be clarified. Specifically, the guidance for “Detection of Aging Effects” and “Monitoring and Trending” needs to be revised to clearly state the expectations for each of the four types of aging management programs. Duke’s experience during the Oconee license renewal effort indicates the importance of having a clear understanding of the intent of each program attribute prior to describing the aging management programs. See NRC dis

comments SAAppendix B, 

DP-6 C.3.6 SRP-LR, A.1.2 The GALL report program descriptions need to be re-written to better reflect the attributes contained in SPR Appendix C A.1.2. Currently, there are program descriptions in the GALL report that do not fully address each attribute. For example, the operating experience provided in the GALL program descriptions typically states that the effect has occurred and, thus, that the program is needed. However, the guidance in Appendix C A.1.2 provides that operating experience should provide objective evidence of program effectiveness. The “Detection of Aging Effects” and “Monitoring and Trending” portions of many program descriptions are unclear. The aging ma

evaluations wclarified as aaddress the aSPR AppendSee NRC discomments SAAppendix B, The GALL readdress this SRP-LR.
April 2001 C-23 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

DP-7 C.3.6 SRP-LR, A.1.2 Technical references providing the foundation for additional requirements need to be provided. Technical references providing the foundation for additional requirements need to be provided. The evaluatio

guidance in trequirements rule as stated determination aging will be so that the inmaintained cfor the period The GALL rematerial, envextensive comexperience to aging effectsreport, NUREwas based o500 documenprogram repoReports, LERgeneric letterstaff has also information cprovided by t2000, letter. The GALL renot revised to comment.
NUREG-1739 C-24 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

DP-8 C.3.6 SRP-LR, A.1.2 Duke suggests that each program in the GALL report contains two distinct discussions. The first would be a clear description of “what” the program is; the second would be “why” the program is effective. The Oconee license renewal safety evaluation report (NUREG-1723) presents the credited aging management programs and activities in this manner. Clear program descriptions in the GALL report are one essential requirement for a future applicant to utilize the GALL report as part of its application. Each aging m

the GALL reptitled Program section descprogram is. TDescription sand revised wclarify “what” The 10 elemein each progrprogram is efelements pro“why” the proThe program reviewed and appropriate tprograms are See NRC disDP-6 in this TThe GALL readdress this SRP-LR.
April 2001 C-25 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

DP-9 C.3.6 A better explanation of how license renewal applicants are expected to use and cross-reference the GALL report in plant-specific license renewal applications needs to be provided. A clear statement of the process to compare its plant-specific programs to those in the GALL report is a second essential requirement for a future applicant to utilize the GALL report as part of its application. As currently drafted in both the GALL report and in the SRP-LR, the expectations are not clear on this most important point. Duke is unsure of exactly what actions are required to be taken in order to certify that an existing, plant-specific program matches the corresponding program described in the GALL report, and what statement should be included in the application itself. See NRC dis

NMC-2 and N

DP-10 C.3.6 The current contents of Chapter 3 of the application include a listing of the credited aging management programs. In order to identify those programs that fit into each of the four types of program reviews described clear guidance must be provided. Clear guidance needs to be provided for all possible situations where a program may fit under multiple headings. Clarifying the expectations for this portion of Chapter 3 of the application is a third essential requirement for a future applicant to utilize the GALL report as part of its application. The guidance should cover situations where a single program may fit under heading (3) and (4), and where the QA requirements for non safety-related components must be reviewed, as well as requirements for new components or aging effects. As an alternative, it may be appropriate to simply have two headings: (1) ‘Aging Management Programs Evaluated in the GALL Report that are Relied on for License Renewal,’ and (2)”Further Evaluation of Aging Management Programs Recommended required,” and not attempt to subdivide those programs that require further staff review evaluation any further. This alternative would simplify the process for both the applicant as well as the staff reviewer. See NRC dis

NMC-2 in this 
NUREG-1739 C-26 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-1 (I & M) C.3.7 Page 3 The section “Application of GALL Report” should be expanded include additional licensing guidance for: 1. Referencing portions of the GALL report. 2. Demonstrating that existing programs, previously approved by NRC in an SER, a TER, or Inspection Report, are adequate for aging management. 3. In taking credit for a program as described in the GALL report. “ the conditions at the plant must be bounded by the conditions for which the GALL program was evaluated.” This needs more specific explanation for each program. Older pre-SRP-LR plants do not have programs that are consistent with all those described in the GALL report. The referenced codes and standards in the GALL report are in many cases, the most recent and therefore go beyond the CLB of these older plants. See NRC dis

NMC-1, NMCI&M-9 in this 
April 2001 C-27 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-2 (I & M) C.3.7 Page 4 The Section “Summary and Recommendations” states that the report “ .. also contains recommendations on specific areas for which generic existing programs should be augmented for license renewal.” These recommendations are based on an assumed scope and content of existing programs that may go well beyond the programs presently incorporated in the CLB. For such cases, additional licensing guidance is needed to ensure that applicants identify and properly augment existing programs. Criteria for determining if a specific program requires augmentation should be provided. See NRC dis

DP-7 in this TCriteria for deprogram requprovided in ethrough XIII ieach table th“Further Evato indicate if is necessaryEvaluation PSummary in complete expThe GALL renot revised to comment. GALL-3 (I & M) C.3.7 Table 3, “Summary of AMPs for Auxiliary Systems Evaluated in Chapter V11 of the GALL Report” Clarify the methodology for addressing unanticipated cyclic loading when calculating the Cumulative Fatigue Damage for the various Heat-Exchanger components in CVCS (Tube/Tube Sheet, Channel/Cover, Channel/Welds, Shell, and Closure bolting). Aging Effects/Mechanism for CVCS heat exchanger includes unanticipated cyclic loading with no reference guidance regarding acceptable detection or evaluation methods. Unanticipated valid aging m“unanticipatebecause if a anticipated, tmanaged in aa TLAA and based on cycthe plant's CLThe GALL readdress this SRP-LR.
NUREG-1739 C-28 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-4 (I & M) C.3.7 Section X.M1 This program description does not address unanticipated cyclic loading yet. Table 1, “Summary of AMPs for RCS Evaluated in Chapter IV of the GALL Report,” includes a requirement to address unanticipated cyclic loading. Please provide additional guidance on methodology and criteria to be used. None Provided. Cyclic loadin

Chapter X as AMP for cyclASME Sectioguidance is pthough Chapcyclic loadingnot found to bguidance on criteria was pManagement these chapteThe GALL readdress this SRP-LR. GALL-5 (I & M) C.3.7 Section X1.M2 Thermal Aging & Neutron Irradiation Embrittlement of CASS (RV Internals) See WOG comments. I&M participates in the WOG/NEI integrated inspection program. Please refer to the June II 1999 response letter to the NRC’s RAI with respect to CL 97-01. I&M considers the WOG/NEI recent comments as continuation of the integrated inspection effort. WOG did not comments. Wincorporated NEI also did comments on The GALL renot revised to comment.
April 2001 C-29 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-6 (I & M) C.3.7 Section XI. M4 CCCW System Modify item (4) “Detection of Aging effects” to omit monitoring the flow, inlet and outlet temperatures, differential pressure for heat exchangers. Heat exchanger thermal monitoring, results may be inconclusive. The monitoring of heat exchangers should follow GL 89-13 requirements. The aging ma

relies on prevminimize corinhibitors and chemistry moinspection anevaluations bof EPRI-TR-1cooling wateinspections fothan chemistcollection and the potential of structural iheat transfer and/or deposwill ensure thand componeCCCW systefunction accerequirement functional tesPart 2 was de“Closed-Cycl(XI.M21 in NThe GALL readdress this 

GALL-7 (I & M) C.3.7 Section XI.M8 Outer Surface of Buried Piping and Components Modify item (4) “Detection of Aging effects” to state: Inspection of a sample of buried components is one way to provide for detection of aging effects. Another way is to conduct a system leakage test in accordance with ASME Section XI requirements. Provides flexibility in selection of methods for detection of aging effects. System leaka

complementanecessarily a test is positivneeds to be pThe GALL readdress this 
NUREG-1739 C-30 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-8 (I & M) C.3.7 Section XI.M9 Fuel Oil Chemistry Modify item (4), “ Detection of aging Effects” to state: Specify that UT thickness measurements of tank bottom is a one time inspection. Thickness measurement of tank bottom may result in equipment out- of-service duration exceeding allowed outage time in Technical Specification LCO. This will potentially increase EDG unavailability. The AMP pro

“One-Time Inrequired. A sthe AMP progChemistry” to thickness mebottoms is a The GALL readdress this SRP-LR. GALL-9 (I & M) C.3.7 Section X1.M14 Inspection of Class 1 Pump Casing & Valve Bodies Propose to combine with Section G-XI.MI. as appropriate. Defect inspection requirements are very similar to inspection requirements in for thermal aging embrittlement of CASS addressed in Section G-X1.M1. Appropriate rincorporated Aging EmbritXI.M12, “ASMInspection,” aXI.M14, “InspPump Casingwas deleted. The GALL readdress this SRP-LR. GALL-10 (I & M) C.3.7 Section X1.S2 ASME Section XI, Subsection IWL Modify item (1), “Scope of Program,” to: Clarify the sentence beginning with NUREG 1611 concerning accessibility inaccessibility requirements. Similarly, modify SRP-LR, Page 3.5-7, Paragraph 3.5.3.2.1.1, to provide the same clarification (last 2 sentences in the paragraph). GALL requirements go beyond the requirements in 10 CFR 50.55a(b)(2)(viii), greatly expand the required work scope by the licensee. See NRC discomment G.XTable B.2.9-3SRP-LR, pagaddress this clarification b
April 2001 C-31 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-11 (I & M) C.3.7 Section X1.S6 Structural Monitoring Please provide an alternate set of references for pre-SRP-LR plants instead of recent Codes and Standards. CNP is not committed to RG 1.54 Rev. 1(07/00) or ACI 349.3R-96 and it is unlikely that other pre-SRP-LR plants would have committed to this revision of the RG either. See NRC dis

NMC-1 in this 

GALL-12 (I & M) C.3.7 Section XI.S7 RG 1.127 Inspection of Water-Control Structures Please allow risk significance to be considered in defining this program. Inspection of structures below the surface water level on a 5 year frequency may impose excessive burden without commensurate safety improvement. See NRC dis

NMC-3 in this 

GALL-13 (I & M) C.3.7 Section XI. S8 (Coating) This program references RG 1.54, Revision1 as a technical basis, yet this standard was issued in July 2000. Also, Table 2, “Summary of AMPs for Engineered Safety features Evaluated in Chapter V of the GALL Report,” references atmospheric corrosion monitoring. Both are expansions of existing approved programs for which there is no technical basis. None provided. No one curre

Rev 1. RG 1.ANSI 101.2 areferences. Tback to the eThe GALL readdress this SRP-LR.
NUREG-1739 C-32 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-14 (I & M) C.3.7 Section XI.E1 Non-EQ Electrical Cables and Connections Please provide the technical bases for the requirements for future discussion. None provided. Aging manag

cables and cto the environrequirements identified as reviews, anainspections pprevious liceapplications. management proposed by renewal applsubsequently accepted by managementwas needed applicants, thincluded in Gapproved agprogram for uapplicants, if requirement implement alprograms increport. The GALL renot revised to comment.
April 2001 C-33 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-15 (I & M) C.3.7 Section XI.E2 Non-EQ Electrical Cables in Instrumentation Circuits Please provide the technical bases for the requirements for future discussion. None Provided. See NRC dis

GALL-14 in t

GALL-16 (I & M) C.3.7 Section XI.E3 Non-EQ Inaccessible Medium Voltage Cables Please provide the technical bases for the requirements for future discussion. None Provided. See NRC dis

GALL-14 in t
NUREG-1739 C-34 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

GALL-17 (I & M) C.3.7 Section XI.E4 Borated Water Leakage Surveillance for Non-EQ Electrical Connectors Please provide the technical bases for the requirements for future discussion. Propose to add Section G-XI.E4 as an augmentation to the BA Corrosion Program in Section XI.M5. NUREG/CR-5643, “ Insights Gained from aging research, “ March, 1992. Is this intended to be back-fit to Section G- XI. M5? None Provided. None Provided. None Provided. See NRC dis

GALL-14 in tThe GALL readdress this Section XI.E4 Section XI.Mthe Boric Acithe aging maelectrical conborated wateother commeinspection of for exposure leakage is alBoric Acid Cothere is no neseparate procomponents. The GALL readdress this reference to sections XI.Esection XI.E4 response to tThe referencis not intendeSection G-XIThe referencrelevant techguidance probeen consideof this aging 
April 2001 C-35 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments C.3.8 A large number of comments received in response to the August 31, 2000, Federal Register notice solicitation (65FR53047) on license renewal misinterpreted the purpose of the comment period in that it was the only opportunity to comment on the “generic” relicensing of nuclear power reactors. The comments ranged from requesting an extension to the public comment period to not allowing for extension to the operating licenses. The specific comments can be viewed by accessing the NRC document management system, ADAMS, using advance search and specify Property= “Case/Reference Number” and Value=“*65FR53047*” To dispositio

113 individuaindividuals reinterest groudirectly to eadescription oprocess and additional infis the comperesponses to Thank you fothe renewal ooperating liceNRC Web sitThe Atomic Ea 40-year licereactors, but licenses coulcomment waregulations wand 1995 to renewal in PaCode of Fede“RequiremenOperating LicPower Plantsalso sought wenvironmentain Part 51, “EProtection ReLicensing anFunctions,” wlicense renew
NUREG-1739 C-36 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) The license r

provide for a determination be adequateperiod of exteNRC is currecomment on the evaluatioapplications fincluding a relessons learnmedia reportdescribed thiopportunity folicense renewrequested coupdated reneOctober 16, 2a meeting of Commission December 5, discuss the einspection anactivities neelicense renewIn addition, eapplicant muto the environcontains an aimpact on the allowed to cobeyond the inperforms plaenvironmentalife extension 
April 2001 C-37 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) National Env

(NEPA) and 10 CFR Part Comments oguidance subwill be considpractical up tfinal guidancCommission scheduled foThe license rprovides for ipublic meetinpublic commeach plant threnewal applAdditional inflicense renewevaluation guthe NRC Wehttp://www.nr

LR/index.htmSpecific inforsurrounding waste is avaisite at <http:/OPA/gmo/tipTechnical IssLevel RadioaWith respect NRC regulati
NUREG-1739 C-38 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) to have efflue

monitoring prreleases and environment) impacts from minimized. Tprograms are available to tpermitted effvery small dopublic living afractions of thRegional NRinspect these to ensure conregulatory reare required interlaboratowhich providecheck on the of the environmeasuremenNational Canrequest of Costudy (Cance

Near Nucleaal., National C1990. [NIH PMary Ruth CDr., Charlestnuclear poweDepartment ostudy concludincrease in ccommunities nuclear powe
April 2001 C-39 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) In addition to 

protecting puunder the AtoU.S. Nuclear Commission protection of use of nuclealicense renewinclude a supenvironmentacontains an aimpact on the allowed to cobeyond the inperforms plaenvironmentalife extension National Env(NEPA) and 10 CFR Part Protection ReLicensing anFunctions.” Ton a separate reviews of thEnvironmentrenewal of policenses are regulations, 1environmentain 10 CFR PaDecember 18regulatory effenvironmentarenewal and 
NUREG-1739 C-40 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) documented 

EnvironmentLicense Rene(NUREG-143The Generic Statement (Gpossible envcould occur aany commerclicense, and, establishes tsignificance oimpacts. For environmentaattempts to efindings covepossible. Whspecific infordeveloping afindings, the for the GEIS individual plaimpact statemreport may bapplicant, intapplication eThe GEIS maenvironmentadocumentatiolicensing proinformation frregulatory agutility industryoperating expprofessional 
April 2001 C-41 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) applicant to c

impacts that plant-specific provided on twill either disnot applicablanalysis of thspecific inforalternatives timpacts musThis approacenvironmentawith a plant-simproves the licensing prothe NRC. A scoping prodefine the prodetermine the identify the sanalyzed in dmeeting is heplant seeking Based on this staff’s indepewill issue a precommendaacceptability action with reimpact. A drasupplement tfor public commeeting is thfindings. Afteaddressed, th
NUREG-1739 C-42 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

General Public Comments (cont.) final plant-sp

GEIS and prorecommendalicense renewCommission. environmentaand public msupplements renewal are aNRC Public DThe GALL renot revised to comment. HKenneth1(OPPD) C.3.9 Item C2.6.1 in Chapter V11 of the August Draft of the GALL (Page V11 C2-4) identifies an Aging Effect for Lube Oil Coolers. However, there is no program information on the next page (C2-5) as there is for the other items on page C2-4) It appears the last row of the table on page C2-5 related to item C2.6.1 was inadvertently omitted. See NRC discomment G-VTable B.2.6 o

I&M-1 C.3.10 NRC incorporate additional licensing guidance into Draft Regulatory Guide DG-1104, the SRP-LR, and the GALL report to clarify how the GALL report will be used in the license renewal process for plants designed and licensed in accordance with regulations, codes, and standards different from those cited in the SRP-LR and the GALL report. None Provided. See NRC dis

ARCS-2, NMNMC-3 in this 
April 2001 C-43 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

I&M-2 C.3.10 I&M also endorses the comments being submitted by the NEI and the Westinghouse Owners Group. None Provided. See Appendi

NRC dispositcomments. I&M-3 C.3.10 In general, the GALL report provides sufficiently detailed information regarding program attributes. The report also identifies program areas that require augmenting, and discusses the aspects to be augmented. The referenced codes, standards, and regulatory guidance are frequently the most recent version and the basis for requiring a program to be augmented is not always clear or sufficiently linked to aging management. As such, the report may be of limited value to older plants such as CNP. This vintage plant, with an operating license based on pre-GDC, simply may not have all the programs as described, or they may be defined by other equally valid versions of the codes and standards. See NRC disARCS-2, NMNMC-3 in this 

I&M-4 C.3.10 The introductory section to the GALL report is expanded to provide additional licensing guidance on how the report will be applied in the license renewal process. This guidance on the use of the GALL report should also be included in the SRP-LR and DG-1104. The licensing guidance should address several issues that are important to ensuring that the GALL report is useful for the greatest number of prospective applicants. See NRC dis

NMC-2 in this 
NUREG-1739 C-44 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

I&M-5 C.3.10 The GALL report should provide recognition of the fact that plants have CLB that differ significantly. For example, CNP and a number of other plants, due to their vintage, are not subject to the GDC of 10 CFR Part 50, Appendix A, or the Standard Review Plan (NRREG- 0800). As noted in SECY-92-223, “Resolution of Deviations Identified During the Systematic Evaluation Program,” the GDC do not apply to plants with construction permits issued prior to May 21, 1971. See NRC dis

NMC-1 in this 

I&M-6 C.3.10 I&M supports the Staff’s plan to revise and expand the GALL report as additional experience is gained through review and approval of other applicants’ AMPs. In this way, the GALL report will be expanded over time to encompass additional programs, activities, codes, and standards that the Staff finds acceptable for plants of different designs and vintages. See NRC dis

NMC-1 and A

I&M-7 C.3.10 Second, the GALL report should not be treated as, in effect, the only set of regulatory requirements and guidance for adequate aging management programs. Thus, guidance should be added to the SRP-LR, the GALL report, and DG- 1104 to clarify. If this were the case, any variation from a program as described in the GALL report, or any area where an applicant is not utilizing all the aging management programs or activities listed in the GALL report for a given structure or component, could result in a need to augment existing programs or add new programs. See NRC dis

NMC-2 in this 
April 2001 C-45 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

I&M-8 C.3.10 While the report does reference a set of regulatory requirements and guidance for aging management programs applicants are free to use alternative approaches (e.g., different programs or different combinations of programs and activities) from those described in the report. Staff should consider adding a methodology and criteria to allow an applicant to demonstrate equivalency with the GALL report by showing that the primary objective of managing the effects of aging is being met by an alternative program or activity. I&M also recommends that the criteria for demonstrating equivalency of AMPs should include the use of risk insights. See NRC dis

NMC-2 and N

I&M-9 C.3.10 At CNP many of these existing programs required by the NRC effectively manage aging and maintain the CLB, whether this purpose is explicit in the requirement or not. For example, the ISI program is credited for monitoring certain components and is designed to inspect for and address the effects of aging so that the CLB is maintained. The NRC through a Safety Evaluation Report, a Technical Evaluation Report or in an Inspection Report has accepted existing CLB programs. An applicant should be able to rely on these programs as appropriate for managing the effects of aging. See NRC dis

NMC-2 in this The SRP-LR Procedures,” an applicant reference) ... contained in for licenses, statements owith NRC proare clear and 
NUREG-1739 C-46 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

I&M-10 C.3.10 Third, the GALL report suggests that certain existing programs, including some programs mandated by binding regulatory requirements (e.g., Inservice Inspection and Inservice Testing programs under 10 CFR 50.55a and containment inspection programs under Subsections IWE and IWL of the ASME Code Section XI), may not be adequate aging management programs for Part 54 purposes without some augmentation. Programs mandated by regulatory requirements or Technical Specifications should be adequate for Part 54 purposes. Where the NRC believes that some augmentation of an existing program is necessary, the GALL report should clearly explain the technical basis for this position and the relation to aging management. As an example the GALL report goes beyond the requirements in 10 CFR 50.55a(b)(2) and requires inspection of inaccessible areas of concrete containments and buried pipe without a detailed technical basis. See NRC dis

DP-7 in this TThe staff fouexperience thwhere degradinaccessible evident from accessible arinaccessible these situatiothat inspectioareas is warrapplicant has the staff with why an inspenecessary. The GALL renot revised to comment. I&M-11 C.3.10 To clarify the NRC should incorporate into DG-1104, the SRP- LR, and the GALL report an augmented section providing licensing guidance for how the GALL report will be applied. The guidance should provide the following clarifications: The applicability of the GALL report should be adjusted based on the plant-specific CLB. Pre-GDC and pre-SRP-LR plants are not expected to demonstrate all program attributes assumed in the GALL report. For a particular plant, a program can be an acceptable aging management program even without meeting all 10 criteria specified in the SRP-LR, provided the applicant demonstrates that the existing program meets the fundamental objectives and has appropriate acceptance criteria. In this regard programs that have been previously approved by NRC (e.g. in an SER or IR), and which manage the effects of aging should be accepted for the renewal period. See NRC disNMC-1, NMCARCS-2 in th
April 2001 C-47 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

I&M-12 C.3.10 The GALL report does not represent a single binding set of regulatory requirements and guidance for aging management programs. Applicants have flexibility to use alternative approaches from those described in the GALL report. For any particular structure or component. Aging can be adequately managed through use of a program or combination of programs and activities that are different from those listed in the GALL report. See NRC dis

NMC-2 in this 

I&M-13 C.3.10 Applicants have the flexibility to reference the GALL report or to demonstrate that their programs and activities are equivalent to the reference programs described in the GALL report. For some plants, programs and activities not described in the GALL report may be credited for aging management purposes. For example, activities such as plant restart reviews, design basis reviews, system readiness reviews. And system walkdowns are valid assessment methods. The NRC should also include the methodology and criteria by which an applicant can demonstrate the equivalency of its AMPs and activities and credit those versions of codes and standards that are part of the CLB for their respective plant. See NRC dis

NMC-1, NMCACRS-2 in th

I&M-14 C.3.10 The NRC should provide clarification as to how an applicant is to make the judgment as presently stated on page 3 of the GALL report, that “the conditions at its plant are bounded by all conditions assumed in the GALL report for a particular program. None Provided. See NRC dis

NMC-2, NMCTable C.
NUREG-1739 C-48 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

I&M-15 C.3.10 I&M suggests that the GALL report be enhanced to provide more focus on programs rather than specific structures and components. As stated purpose of the GALL report is to assess the adequacy of existing programs for purposes of managing aging, and provide the Staff’s generic conclusion as to which programs are deemed adequate for license renewal purposes. Given this purpose, it would be appropriate to add tables to the GALL report that focus on programs, as opposed to a component-by- component format. If Table 3 data were reformatted as a list of programs with the other data displayed for each program one could see the aging mechanisms and applicable components encompassed by each program. This would give the GALL report greater utility for the applicant’s reviews and expedite preparation of a license renewal application. The review of specific structures and components in the GALL report would still be useful to confirm that the programs have adequate breadth and depth in managing the effects of aging. See NRC dis

NIRS-1 and N

I&M-16 C.3.10 The NRC should clarify the schedule for initial implementation of the GALL report to make clear when applicants are expected to begin referencing the report in their applications. The Staff should recognize that there is considerable lead-time required to develop an application. Work on a renewal application generally must begin two to three years prior to the expected submittal date. For licensees that are in the process of developing an application at the time the GALL report is finalized (expected in 2001), it may not be realistic for them to “retrofit” their applications to address the GALL report. An applicant 

GALL report approves it foThe GALL renot revised to comment. I&M-17 C.3.10 The Statement of Considerations to the 1995 license renewal rule recognized that PRA techniques “may assist in developing an approach for aging management adequacy” published in 60 Fed. Reg. at 22468. I&M believes that the use of PRA techniques has advanced to the point where licensees should be able to employ risk insights in aging management reviews and in the detailed evaluation of TLAA. See NRC disUCS-3 and N
April 2001 C-49 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-1 C.3.11 If the NRC and the nuclear industry are successful in finalizing the proposed expedited license renewal procedures, and thus are able to discount generically the effects of aging on a wide range of SSC, the NRC’s approval of LRs would become standardized. And the safety of complex, fallible components could be ruled to be immune to public review and challenges. None Provided. Also see NRC 

comment NIRThe Atomic Ea 40-year licereactors, but licenses coulcomment waregulations wand 1995 to license renewof the Code o“RequiremenOperating LicPower Plantsrequirements plant-specific aging effects managed duextended operenewal appldemonstrate within the scowill be achievwas also souassociated erequirements “EnvironmenRegulations fand Related were amendein 1996. The NRC req(August 31, 2Notice 65FR5guidance for 
NUREG-1739 C-50 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-1 (cont.) plant-specific 

license renewGALL. GALL the NRC stafreviewing liceapplications that their aginprograms meGALL. Howeto propose amanagement staff would recase basis. Rerroneously das the only ocomment for NRC requestupdated reneOctober 16, 2a meeting of Commission 2000, to specextent to whiand maintenabe augmenteAlso see NRC comment NIRNUREG for dprocess applrenewal applIn addition, eapplicant muto the environcontains an aimpact on the 
April 2001 C-51 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-1 (cont.) allowed to co

beyond the inperforms plaenvironmentalife extension National Env(NEPA) and 10 CFR Part The GALL renot revised to comment. KDrey-2 C.3.11 Surely, sound fiscal reasons exist that may explain why NRC is seeking ways to streamline its oversight and regulation of the 103 reactors that are still operating in the U.S. But can anybody point to sound safety reasons? None Provided. See NRC dis

KDrey-1 in thThe NRC did GALL report would providapproved methat aging coHowever, the its aging manbounded by tGALL. It was applicant couAMPS were edescribed in could be reduThe GALL renot revised to comment.
NUREG-1739 C-52 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-3 C.3.11 The NRC should demand from Congress and should receive funding for an augmented oversight staff and stricter regulatory authority – not contrive ways to simplify and cut back. In order to cope with the increasing levels of complexity; the pervasive presence of corrosion, thinning, cracking and other forms of materials aging; and the decreasing supply of training and experienced nuclear engineers and workers (both at the NRC and at power plants). The purpose 

establishmenGALL is to gareview of futuapplications resources moEffectiveness work necessamissions and disciplined, aresult, the NRchallenge the programs anhow they conachievement implementing Budgeting, aManagement NRC preparefocuses on dprovides visibmeasures. Woutcomes anmeasure and performance use performaplanning procwork necessadesired outcocommitments timely mannefuture numbeapplications ecapacity to imand/or timely request addit
April 2001 C-53 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-3 (cont.) Congress. In 

NRC’s Strate1614), “We wmaintained aby ensuring tadequately mlicensing baspresent plant will be maintalicense renewdetermined tbeen and are managed. Wlicensing baspresent plant will be maintaperiod of extewill perform ithe review of applications bacceptability management The GALL renot revised to comment. Also see NRC comment KD
NUREG-1739 C-54 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-4 C.3.11 The basic purpose of the proposed regulatory changes seems to be to enable the NRC staff to expedite the approval of the extended duration of each of the operating U.S. reactors with few, if any, requirements for site-specific aging management review of each reactor’s individual SSC. An NRC licensee’s promise of being able to operate his plant safely for another 20 years is clearly ingenuous, at best. None Provided. See NRC dis

KDrey-1 and Table C. KDrey-5 C.3.11 The NRC should sharpen its focus on defects and toughen its safety requirements. Now that the plants have already operated longer than they should have, rigorous NRC oversight is more important, not less. Before licensoption, plants for 40 years ounder the prerequirements their licensed The NRC has renewal procrenewal rule, been establisreview on agplant structurthe period of The GALL renot revised to comment. Also see NRC comments Kthis Table C.
April 2001 C-55 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-6 C.3.11 No safe site or technology has been found any place on or off the plant Earth to isolate the high-level radioactive waste (the irradiated fuel rods) to the highly radioactive “low- level” waste (everything else) of the current generation of operating and decommissioned nuclear power plants – or of the wastes generated at the uranium mines and mills and at the conversion, enrichment, and fuel fabrication plants; that is, the wastes from the rest of the uranium fuel cycle. And no safe way or people-less route has been found to transport the wastes to their non- existent burial grounds. Nuclear workers are exposed to levels of radiation that may be permissible, but are not safe. None Provided. Specific infor

surrounding htransportation on the NRC Whttp://www.nr

issues.htm. The GALL renot revised to comment. Also see NRC comment KDregarding radworkers. KDrey-7 C.3.11 Should the NRC be allowed to write a regulatory blank check or issue use-as-is permission for its licensees to continue to operate their nuclear power plants beyond the design life of the plant and its components? None Provided. See NRC dis

KDrey-1 and Table C. KDrey-8 C.3.11 A few Additional questions: (1) Is the real driver of these proposed regulatory changes the NRC’s effort to improve its licensee’s ability to compete in the new deregulated market. None Provided. See NRC disKDrey-1 in T
NUREG-1739 C-56 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-9 C.3.11 A few Additional questions:. . . (2) . . But speaking of multinational corporations, can anyone explain how a consortium of corporations with headquarters in various countries would be allowed to apply for and obtain a license renewal for a reactor in the United States? According to 10 CFR 54.17 (b); “Any person who is a citizen, national, or agent of a foreign country, or any operations, or other entity which the Commission knows or has reason to know is owned, controlled, or dominated by an alien, foreign corporation, or a foreign government is ineligible to apply for an obtain a renewed license.” The Atomic E

1954, as amefor regulatory promulgated Section 103d specifically pmay be issuecorporation odominated by corporation, oThe Standard Foreign OwnDomination, that is used bapplications fthat may invoforeign intereconditions by foreign owneapplicant maAEA (See Fe

Vol. 64. No. 1September 2of the conditiforeign ownelicensee wouit would not bcommon defeCopies of this the detailed econditions foinvolvement) the NRC’s elmanagement 
April 2001 C-57 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-9 (cont.) www.nrc.gov 

Public Docum11555 RockvMaryland 208301-415-700The GALL renot revised to comment. KDrey-10 C.3.11 Some specific concerns about extending the duration of the operating licenses – 1. Steam generators: Major, controversial, unresolved, safety issues remain about the design, fabrication, operation, repair, and safe shutdown of the steam generators – one of the most essential pieces of equipment in pressurized reactors. In spite of concerns submitted by NRC staff member, Joram Hopenfeld (Ph.D. in Engineering, UCLA), dating back as early as 1991, the potential for multiple steam generator tube ruptures and/or leaks is basically being ignored. According to Dr. Hopenfeld’s Differing Professional Opinion on steam tube integrity, presented on October 11 to an ad- hoc review panel of the NRC’s Advisory Committee on Reactor Safeguards: as of July 1999 the NRC was permitting 17 reactors to operate with severely degraded steam generators, using NRC Generic Letter 95-05 guidelines. See NRC dis

NIRS-7, NIRSTable C. The staff has learned from failure into its activities. The to licensees a summary (20Stemming froof Recent DifMaintaining SIntegrity avaihttp://www.nr

GC/RI/2000/the NRC docADAMS). Thcontinued to with select licsimilar opera(although no have the samgenerators adiscuss their now requests any steps tha
NUREG-1739 C-58 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-10 (cont.) plant to take, 

industry lessoIndian Point 2 document acML00376527In addition, in November 1, Executive DiWilliam TraveCommissioneaccession No Travers stateof the lessonhave concludsafety conceidentified thaaction with reWhile the GAwere not revicomment the aging managreviewed by lessons learn

KDrey-11 C.3.11 Some specific concerns about extending the duration of the operating licenses – 2. Radioactive corrosion products: I am enclosing a copy of a letter I sent to the NRC on July 16, 1980 --- twenty years ago! - -- about the proposed use of chelating-agent solvents for the chemical decontamination of Dresden Unit One in Illinois. As you know, the continuing buildup of radioactive corrosion products – which emit highly penetrating gamma rays – causes the radiation fields within which workers must inspect, repair and replace equipment to become higher and therefore potentially more harmful to the workers. As a nuclear plant ages, and as the corrosion products (crud and the green grunge) In response t

Kay Drey and Better Enviroprepared an statement to impacts from Dresden Unit high residual licensee, ComCompany, hadated Decem
April 2001 C-59 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-11 (cont.) increase – sometimes in inaccessible location – the only way a licensee is often able to reduce the resulting high radiation fields is to flush solvents through the piping or other corroded components. The result is dissolved radioactive wastes (bonded to the solvents) that are difficult, if not impossible, to isolate from the biosphere for the requisite millennia. to chemically 

primary cooliNuclear PowThe “Final Enrelated to PriChemical DeDresden NucUnit No. 1” wNUREG-068final environm0686) addresMrs. Drey’s in ,letter. Therepreviously beThe GALL renot revised to comment. KDrey-12 C.3.11 Some specific concerns about extending the duration of the operating licenses – 3. Reactor Pressure Vessel: . . . The steel of the pressure vessel is subject to radiation effects due to its location near the reactor core. Neutron radiation causes the brittle- to-ductile transition temperature to increase significant, leading to the increased possibility of fracture, for example during a refueling operation. In fact, the extension of reactor life beyond the traditional 40 years (and perhaps even sooner) depends critically on knowledge of the embrittlement characteristic of the pressure vessel and on the ability to offset the embrittlement by an annealing process. Neutron Rad

the Reactor Vthe GALL repreactor vesseprogram musmaterial data monitor irradthe end of the operation, anneed for opethe inlet tempspectrum, ansurveillance cwithdrawn duextended operestrictions mensure that tunder the co
NUREG-1739 C-60 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-12 (cont.) surveillance c

exposed. Reactor vessprograms are depending on composition availability of and projected accordance w10 CFR Part submit its proschedule for implementatievaluation of is required foThe reactor vprogram (XI.GALL report revised but ncomment. KDrey-13 C.3.11 Some specific concerns about extending the duration of the operating licenses: Release of radioactive gases and liquids to the environment: As a nuclear power plant gets older, its filtering and monitoring mechanisms, reactor coolant systems, piping, cooling water intake structures, and other systems inevitably wear out. Some can be maintained, refurbished, or replaced; some cannot. The gaseous and liquid radioactive waste detection and processing None Provided. With respect 

NRC regulatito have effluemonitoring prreleases and environment) impacts from minimized. Tprograms are available to tpermitted effvery small dopublic living afractions of th
April 2001 C-61 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-13 (cont.) mechanisms become less effective, increasing the amounts of unfiltered and unmonitored gases, liquids and particulate materials released to the air and to the plant’s cooling water source (the lake, ocean or river) during the routine operating of the plant. And even more critically, during an accident. Regional NR

inspect these to ensure conregulatory reare required inter-laboratoprogram, whindependent and precision measuremenNational Canrequest of Costudy of 52 nand 10 Depafacilities (“CaLiving Near NJablon, et al.Institute, July No. 90-874])that there wacancers in thsurrounding tplants. Regareleases durihas promulgaPreparedneslicensees muactions will bpublic from a accident. Licedrill on their pauthorities aninspects licenpreparednes
NUREG-1739 C-62 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KDrey-13 (cont.) The GALL r

were not revcomment. KOPEC-1 Hagki Youm C.3.12 On the GALL report (pp IV C2-28, Item C2.5.10), the SCC and PWSCC aging mechanism are used for Austenite SS and Alloy 600, respectively. Could you explain the reason and background why other AMP shall be applied? I know PWSCC is a SCC aging mechanism. Thus, it seems that same AMP can be used. GALL recom

management austenitic stasheaths and Section XI InSubsection IWChemistry. AInservice InsIWB and Warecommendeand sleeves However for sheaths, slee182 welds reThe reason frecommendacomponents experience. Texperience is Information Nand Generic susceptibility PWSCC has addressed by and chemistrrecommends should perforof all Ni-alloy the most susto determine inspection prThe applican
April 2001 C-63 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

KOPEC-1 (cont.) scope and sc

including leakto assure detthe loss of inpenetrations. either provide that justifies tprogram or dlong-term properiodic inspsusceptible looccurrence ofrequency of inspections sfinding of the crack growth alloys. The ainformation ogrowth modevalidate thesadequacy of and acceptanThe GALL renot revised to comment. NIRS-1 C.3.13 While reading over the transcript of the License Renewal Workshop Public Meeting dated September 28, 2000, I noted with concern that Mr. Yung Liu of the Argonne National Laboratory (ANL) indicates that his lab has been contracted by the NRC to reformat the Draft GALL Report. ANL is proposing to accomplish this task by modifying, compressing and This raises a significant concern that the public is being asked to provide comments on material that is already dated by NRC for which the agency has no intention of issuing. Considering the density and complexity of the material presented by the GALL Report, it is grossly unfair to ask the public to comment The NRC ref

the GALL repunderstand athe informatiocomment has commented ochanged subevaluate whewould be perinformation a
NUREG-1739 C-64 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-1 (cont.) eliminating existing columns and information from various tables. on a roughly hewn document for the sake of meeting NRC timelines, knowing that agency does not intend on issuing the document in this format. As Mr. Grimes states in the transcript, “I had originally envisioned that the reformatting would be intended to make it easier for people to follow the material rather than to confuse them.” However, it is not reasonable for NRC to solicit public comments on a document that it already views as confusing and in need of reformatting. If NRC were sincere in this endeavor, it clearly would have waited to provide the public with final draft of the report for comment. evaluation w

of these docuaddress publon the AugusGALL report, Regulatory Gand Content Renew NucleOperating Licbecause the changes and change in thiThe staff’s cochanged the Mr. Liu indicapreviously in Component” Interest” has one column tComponent.” “Aging EffectMechanism” into one coluEffect/Mechastaff relocatecolumns “Re“Evaluation ainto Chapter aging managare still listed various aging manage. The Aging Managbeen simplifiecorrespondin
April 2001 C-65 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-1 (cont.) XI. One may 

table that idemanagement and then go tup the “Referof Technical The informatrelocated in oeasier to use the technical affected. As a result, tstakeholdersthe technical generically cmanagement renewal woubecause thersubstantive cinformation in The GALL renot revised to comment. NIRS-2 C.3.13 The agency’s stated goal is to make the re-licensing process more predictable and streamlined. This is, without mistake, a process that is designed to facilitate a more predictable for re-licensing applicants. Central to making the re- licensing process predictable to licensees is the need to remove what is viewed by industry and regulator as time and cost NIRS rejects the generic approach to age-related degradation issues for reactor licensing extension as a construct to solely benefit the nuclear industry economically while undermining public health and safety. This approach effectively eliminates site specific public participation and intervention in the re-licensing proceedings on aging issues. In turn, this approach The GALL re

public’s abilitspecific concoperation of a undergoing a by the NRC. Public commthe regulation1991 and 199for renewal in 
NUREG-1739 C-66 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-2 (cont.) consuming impediments or licensing burdens raised through site specific re-licensing proceedings brought forward by the affected public regarding age-related degradation of systems, structures and components (SSC). The re- categorization of site-specific contestable issues to generic non- contestable issues is the central advantage gained by the agency and the licensees to make the re- licensing process predictable through the Generic Aging Lessons Learned or GALL approach. eliminates independent experts and public review of the potential impact of age-related degradation issues from the license extension process. It is fundamentally undemocratic to remove the affected public’s discovery process and their ability to scrutinize and cross-exam industry and regulatory assumptions pertaining to aging safety components and public safety within the context of an adjudicatory proceeding. By removing age- related degradation issues from the independent scrutiny of a site- specific proceeding, the GALL approach strengthens and perpetuates the historically cozy industry/regulatory relationship and systematically obfuscates safety issues through a host of mechanisms including corporate proprietary non-disclosures tactics. the Code of F

Public commwhen the assimpact requiramended for 1996. The puto provide sitregarding a lapplication in of opportunity pursuant to 1of opportunity published in accordance wperson whosaffected by tha request for for leave to innotices have regarding paapplications treceived thus be posted as applications aaddition, any request to inspursuant to 1suspend, or rany other actThe request requested anthat constitutrequest. In suguidance docaffect opportspecific conc
April 2001 C-67 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-2 (cont.) renewal. GALL does n

for a licensee the effects of 54(a)(3)] for Slicense renewduring the rerenewal rule specific deteeffects can bfor the renewintends to refGALL it must a minimum maging effectspublished so opportunity to aging managdescribed in Appendix A, SRP-LR provdescription oreview each program conrenewal appldisposition of this Table C The GALL renot revised to comment.
NUREG-1739 C-68 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-3 C.3.13 The GALL approach provides for far too much credit and confidence to be given to the regulator and industry towards the “generic” nature of age-related degradation the licensing basis. In fact U.S. reactors have incorporated many design and component features that are unique within their pressurized and boiling water reactor licensing basis. As one NRC official told the McGraw Hill publication, Inside NRC (October 9, 2000, p.10), “You are talking about a licensing basis as if it were one thing,” said David Weiss, “when, in fact, nuclear power plants are like snowflakes. Each one is different. It makes the job very difficult. If you pick on one particular issue at a plant and you throw enough resources at it you can figure out what the licensing basis is.” It is the NIRS contention that the GALL approach significantly limits the overall effort to ascertain the real effects of aging on the over all licensing basis as it pertains to license extension. As a consequent, this generic approach constitutes a non-conservative approach to the re-licensing process and further undermines public health and safety. While design 

differ, the agplant equipmmany plants. report is only programs, whfind acceptabapplicable agapplicable SSand aging madescribed in reflection of tfirst few renetherefore, the see them addGALL does nto demonstrarequired by 1Applicants capreviously apGALL or they AMP. Also scomment NIRNUREG. The GALL renot revised to comment.
April 2001 C-69 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-4 C.3.13 Additionally, the NRC and industry have provided no “lessons learned” in their GALL approach for assessing demonstrated short falls, failures and differing professional opinions in the current process to evaluate aging for the current licensing basis. These failures and shortfalls can compound to adversely impact the scope and accuracy of generic evaluations within the context of license renewal when overlooked in the evaluation program of the adequacy of generic age management programs. The GALL, S

have the benthe staff memthe current paging for the and also conthe initial liceapplications. learned from and from an effectiveness addressing ulicense renewreviews have these documThe GALL, Shave been reissue but not comment. NIRS-5 C.3.13 The GALL process is therefore fundamentally flawed in assuming that the NRC staff and industry have assembled and are practicing from an adequate and accurate body of knowledge and experience to evaluate the adequacy of each generic aging management program from aging effects for SSC. NIRS cites several of the “l0 program attributes,” used to generically categorize the SSC for GALL as fundamentally flawed. These program attributes include but are not limited to: For example, it is generally recognized that within a single operational cycle, steam generator tube cracking can increase from tens to hundreds to thousands of cracks as a result of intergranular stress corrosion cracking without any degree of certainty that can predict this jump in crack growth. With regard to age-related degradation, NIRS contends that the industry and regulatory are placing an undue amount of confidence and credit in unproven and theoretical assumptions espousing that you can know where you are going by This commenadequacy of respect to agprograms, pagenerators. Tdeveloped banuclear plant body of knowincluded infonuclear plant program and from licensee The 10 elemeprogram evathe effectiven
NUREG-1739 C-70 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-5 (cont.) #5 Monitoring and Trending. There is a distinct lack of assessment within the context of GALL for “lessons learned” from the apparent and significant degree of uncertainty for predicting degradation mechanisms (i.e. crack growth rates, embrittlement) over operational cycles of 15, 18 and 24 month operational cycles, let alone 20 year license extensions. looking at where you have been. This is a lot like driving your car through the rear view mirror, which does not instill confidence for either the passengers of the vehicle or communities living downwind of nuclear power stations. Those of us who are being taken for a ride with the industry and regulator are increasingly alarmed by this practice as a continued justification for operational exemptions, as most recently exemplified by reduced inspection schedules leading up to Indian Point Unit 2 steam generator tube accident in February, 2000. NIRS now sees this same practice to be used generically applied to justify 20-year license extension without an avenue for public challenge. management 

attributes inctrending. Parinspected, anprovide direcrelevant aginimpact on intor more of thdetects the athere is a loscomponent’s Monitoring anan adequate provide for timmitagative acevaluation opthe program/corrective acprogram enhconsidered. Ievidence thahave and wiladequately mIn the case osteam generaof knowledge generator tubwas found to the staff concimplementatinot effective Steam GeneLessons-LeaOctober 23, 2information.) 
April 2001 C-71 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-5 (cont.) implementati

oversight by appropriate, assessed. Tpractice is exthe license reThe GALL renot revised to comment. NIRS-6 C.3.13 Additionally, NIRS notes with alarm that the NRC and industry are interested in expanding the number of SSC that would be approved for one time inspections” as an acceptable alternate to periodic inspections to assess age-related degradation. NIRS is astounded by the NRC premise that a one time inspection will be sufficient to verify that age-related degradation of various SSC is sufficient to satisfy the license renewal basis, particularly when these inspection verifications are to occur a decade or more in advance of the license renewal date. None Provided. It is not nece

restriction on inspections cWhen the Cothe license redetermined tapplications cearly as 20 yof the currenbecause that operating expplant-specificdegradation. effect is occuthe inspectiooperation but current term aging effect. inspections athat aging effFor exampleconcerns regaging effect wCalvert Cliff Nwhether a onsufficient, the 
NUREG-1739 C-72 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-6 (cont.) originally pro

Gas and Elecconverted intAdditionally, reveals an emwhether befoinspection is licensee musany required accordance wAppendix B tThe GALL renot revised to comment. NIRS-7 C.3.13 The GALL process is therefore fundamentally flawed in assuming that the NRC staff and industry have assembled and are practicing from an adequate and accurate body of knowledge and experience to evaluate the adequacy of each generic aging management program from aging effects for SSC. NIRS cites several of the “l0 program attributes,” used to generically categorize the SSC for GALL as fundamentally flawed. These program attributes include but are not limited to: #6 Corrective Actions. The existing 40% plugging criteria (40% PC) for steam generators in pressurized water reactors has imposed a heavy financial burden on the industry As a result, despite a lack of technical justification, the industry insisted and the regulator acquiesced to a position that it is safe to operate steam generators with defective tubes. This flawed policy effectively allowed the steam generator tube rupture to occur at Indian Point Unit 2. The affected public views this as one of many examples of a collapsed and ineffective corrective action program. Again, NIRS sees this same practice to be incorporated generically to justify 20-year license extensions without an avenue for public challenge. The 1997 ins

Point 2 SG tuthe tube in Scrack, that leFebruary 200looking at the inspections (signal to noishas subsequthe crack wathrough wall plugged if it hrequired in R“Bases for PlSteam Generesult of not dduring the 19has initiated those performassociated wrecognizing a
April 2001 C-73 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-7 (cont.) much to their dissatisfaction. In view of this dissatisfaction, NRC has made many attempts over the past decade and failed to formulate a meaningful alternative to the 40%PC. Despite this effort, the industry does not want to be constrained by the 40% PC and is requiring unlimited flexibility in making decisions regarding steam generator fitness for service. corrective ac

conditions adaffected the S(see ADAMS number ML0The NRC and proactive in agenerator tubof industry inrevision to Nguidance for generator tubdocument is staff review. addressing sas a generic ADAMS acceML00376224Point 2 steam incident, a taand a lessonissued (ADAML00376242public confideintegrity areasteam generathe NRC Wethis action plaupdated to prcurrent informachievement further increaand confidentube public ware planned.
NUREG-1739 C-74 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-7 (cont.) In the curren

provides reguinspection, aor increased steam generaWhen events are performecorrective acimplementedguidance proimprove the rplants. The stakes in this cprocess are pNRC home p

ADAMS) and challenge. Tcontinue in thperiod. The GALL anmodified spethis commenIndian Point 2 integrity task GALL report were incorpo

NIRS-8 C.3.13 The GALL process is therefore fundamentally flawed in assuming that the NRC staff and industry have assembled and are practicing from an adequate and accurate body of knowledge and experience to evaluate the adequacy of each generic aging management program from aging effects for SSC. NIRS One recent example is contained within the NRC Office of the Inspector General Event Inquiry “NRC’s Response to the February 15, 2000, Steam Generator Tube Rupture At Indian Point Unit 2 Power Plant,” August 29, 2000. Despite long standing industry and regulatory concerns regarding the The NRC sta

report findingfindings and some of the finaccurate pisurrounding tcontained in 1997 inspectstaff’s review 
April 2001 C-75 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-8 (cont.) cites several of the “l0 program attributes,” used to generically categorize the SSC for GALL as fundamentally flawed. These program attributes include but are not limited to: #9 Administrative Controls. There is a demonstrated lack of adherence to administrative controls on the part of the industry and enforcement by NRC with regard to age-related degradation issues. loss of steam generator tube integrity, the report identified a number of missed opportunities by NRC to catch degradation of a steam generator tube. The report concluded that NRC staff could have flagged the problem tube if it had conducted a technical review of Consolidated Edison’s 1997 inspection report and that staff missed another opportunity when it reviewed Con Ed license amendment request for a one-year extension of the steam generator inspection, which was deferred in the summer of 1999. Additional, NRC engineering staff were hampered by senior management in following up with additional questions to Con Ed regarding the inspection extension which resulted in the February, 2000 tube rupture. NIRS has no confidence that current administrative controls in neither industry nor NRC enforcement of administrative controls are adequate and can be generically categorized to place age management issues beyond public scrutiny and intervention within the context of license extension. amendment 

preceded the leak in Februthe NRC stafthe OIG’s findinspection reamendment in a NovembNRC’s ExecuOperations, WCommissioneOIG Report oto the Steam Failure at IndRelated IssueADAMS acceML00375306On page 4 of Travers statelicensee’s 19inspection wein an inspectfrom the licen1997, and as did not review reasons discHowever, this not provide inthe flaw in thcolumn 5 tublicensee’s insidentify this sThe existencto the tube fadiscovered a
NUREG-1739 C-76 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-8 (cont.) tube failure w

of the 1997 ewhich was noto the NRC, wlocation at woccurred. Thinspection reU-bend defecSG 24 and thHowever, in not aware of tube failure ahave identifieU-bend of the in SG 24 basprovided by tThe Novembletter (ML003additional infNRC’s activitIndian Point 2technical sperequire licenssummarizing steam genera12 months fothe NRC stafconference cthey are condinspections to information to inspections. Tcontained in does not inclcurrent inspe
April 2001 C-77 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-8 (cont.) analyzed to d

flaws in SG tnot possible NRC staff to licensee migNRC does prreview and incurrent data tinvolved in stactivities and contractor suHowever, beNRC conducSG inspectiolessons learnPoint 2 failurereassess the applying NRC area. Regardmore real-timPoint 2 SG inthey were bestaff held foudiscuss the 1The NRC staduring any of informed the been found in result of this outlined in AtNovember 3, plans to reassummary insconference cto determine approach for 
NUREG-1739 C-78 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-8 (cont.) oversight of S

February 200The basis for disagreemenamendment of ML003753NRC review thorough, we review was inscope and deconformed to was commentechnical comsignificance orequest. The amendment the licensee upcoming SG date to take cthe plant had extended per(approximatethat shut dowbeen placed Under this “laatmosphere inerted (i.e., fso the tubes oxygen) and were at a low Operating exand it is well that the SG tunder these cto crediting th
April 2001 C-79 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-8 (cont.) the plant was 

inspection sclicensee also the actual pepower by abothe tube ruptthe extended granted by thvery complex factors that lemakes it uncstaff might haexistence of looked furthethe SG review improvementRegarding wengineering sNRC managequestions to inspection exDirector of Nadditional steguidance in tgoverning licnot absolutelround of queprocedure onfocus questioreasonably lirounds of quesame office pguidance to sobtain neceslicensees wh
NUREG-1739 C-80 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NIRS-8 (cont.) first round of 

responsive. Tincludes, conmeetings witmanagementsecond round The GALL renot specificathis commeninvolved with learned from reviewed the program for S

NMC-1 C.3.14 The license renewal applicants must know how to use the guidance and what the NRC will expect to see in the applications relative to the guidance. In addition, the supporting bases referred to in these documents should be constructed in a way that allows both plants which were licensed prior to the present GDCs and SRP-LR and those licensed under the GDCs and SRP- LR to benefit from the work done in the Generic Aging Lessons Learned and Standard Review Plan for License Renewal. None Provided. GALL was dr

management environments vintage of a previewed AMGALL report apply to both licensed plancoating progrChapter XI, Srevised to incnewer versioregulatory guThe GALL rerevised to adspecifically fo

NMC-2 C.3.14 Despite the interactions between NEI and the NRC, we do not fully understand how a license renewal applicant would use the GALL and the SRP-LR; nor are we certain how On Novembe

representativinterested indthe Nuclear R(NRC) staff in 
April 2001 C-81 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-2 (cont.) the NRC would use the documents in the review of a renewal application. We have noted that there is language in the August version of the GALL and SRP-LR, which discusses the purpose, and use of these documents. However, we believe uncertainty still exists. to discuss us

SRP-LR. NEpurpose of thclarify the NRthe applicatioand the SRPsubmitting licapplications use the GALinformation scomponents, mechanismsconsidered in application. IGALL report presentation license renewbasis to resoitems. For 20Commission may use GALtopical report applicable. Trepresentativwanted the Nboth how an GALL report of a license rhow the NRC facilitate the application. Trepresentativthe GALL repReview Plan how to approGALL report 
NUREG-1739 C-82 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-2 (cont.) advantage. T

representativconcerned abexpectation fassociated wan applicant’to the prograand how excreport would application. Tapplicant who license renewbe expected programs relstructures or bounded by tin GALL, in oreference for in the same ware used as rprograms. Thintend to use areas where recommendeaging managproposed. By the staff expewould decreaapplication arequired for treferences athe GALL repfootnotes to tsection in the application. Tthat is include
April 2001 C-83 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-2 (cont.) needs to refle

description omanagement take the form components management GALL as desthe SRP-LR. representativNEI 95-10 wohow to use thSRP-LR. As January 31, 2NEI committedemonstratioexamples to implementatiexpectationsagreed that trenewal guidnot be modifiand that currthe applicatioSRP-LR and adequate. Boagreed to cofrom the demmight provide regarding the The lessons factored back NEI 95-10. The GALL renot revised to comment.
NUREG-1739 C-84 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-3 C.3.14 The flexibility to provide for acceptance of functionality equivalent programs does not appear to be written into the SRP- LR. The NRC has 

evaluations oin Appendix Athe SRP-LR, summarized acceptable aprogram sho10 elements Table A.1-1, These prograare discussePosition A.1.and activities managing a ca specific strshould be demanagement may be evalu10 elements Table A.1-1 (appropriate. a structure oconsidered in robustness omanagement arguments mdeveloping amanagement use of probabis not an accconcluding thand componemanagement aging will be the period of Thus, risk sig
April 2001 C-85 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-3 (cont.) considered in 

of an aging mfor the structlicense renewused to concmanagement for license reThe GALL renot revised to comment. NMC-4 C.3.14 The supporting basis should avoid using references to the GDCs and SRP-LR so that plants that were licensed prior to the GDCs and SRP-LR being established can more fully utilize the GALL. Many of the underlying discussion in the GALL are tied to the GDCs and SRP-LR. See NRC dis

NMC-1 in this 

NMC-5 C.3.14 We like the use of Chapter XI because it provides a repository for one-time evaluations of aging management programs. We have noticed that there are programs discussed in the body of the GALL report that are not listed in Chapter XI. We suggest that those programs not now listed in Chapter XI be included. See previous column. The NRC has 

and describe AMPs in Chalocation of thprograms proreference anand potential The GALL rerevised to adspecifically fo
NUREG-1739 C-86 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-6 C.3.14 Licensees that are of pre-GDC and SRP-LR vintage should support the attributes of programs contained in GALL independently of reference to the GDC or SRP-LR to allow use. Flexibility must be provided to allow some differences for those plants that do not fit the generic definition. See previous column. See NRC dis

NMC-1, NMCTable C. NMC-7 C.3.14 We agree with the NEI response that, if a specific revision of a code; say those published by the American Concrete Institute (ACI), is referenced and evaluated in GALL, a renewal applicant can indicate that they use the same program at their facility and rely on the GALL evaluation for NRC acceptance of the code. If the ACI standard used by an applicant is different from that in the GALL, then the applicant must demonstrate that its program is adequate in the areas, which differ between the standard revisions, contained in GALL and the revision of the standard, which the applicant uses. Additionally we believe that the applicant should be able to use the edition of the ASME code that is applicable to the licensee in its current licensing basis or a more recent edition of the code. A more See NRC dis

ACRS-2 in th
April 2001 C-87 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-7 (cont.) recent edition of the code would be applicable if the licensee plans to use it in the future. NMC-8 C.3.14 Nuclear Management Company, LLC, agrees with the NEI suggestion as discussed in the question. Given a robust process for identification of aging affects, the justification of any aging effect not requiring management would be part of the process documentation and is not required to be separately documented in the application. It appears that the GALL identified aging effects are to be used by the staff as a checklist of those that require management. This implies that it would be possible for an applicant to use the GALL to determine which aging effects require management. We do not believe it should be acceptable for an applicant to use the GALL to determine which aging effects require management. The applicant must make use of the licensee’s engineering analyses to determine which aging effects do and do not require management. The licensee will need to document in the application the applicable aging effects requiring management. Those that do not require management will be documented in the supporting documentation kept on site. Pursuant to 1

license renewto demonstraaging on strusubject to an review will be so that their ibe maintainecurrent licensperiod of exteThe SRP-LR page A.1-2, pclarification tinterested in based on expprovide furthestaff has mod“If operating information inaging effects an applicant absence of thapplication, it question its aquestioning taging effect, basis, which aid the applicquestion, shaexample, the previous appgeneric comm
NUREG-1739 C-88 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

NMC-8 (cont.) engineering j

research infoindustry expethe question. aging effect isufficient basaging effect icomponent, bis a BWR and component. Ithe GALL replist is not releThe SRP-LR this commen

PECO-1 C.3.15 PECO Energy appreciates the opportunity to comment on this petition for rulemaking. We endorse the comments provided by the Nuclear Energy Institute. None Provided. See Appendi

NRC dispositcomments. SRP-LR-1 (I&M) C.3.16 Section 3 Add a section on references explaining that the SRP-LR and GALL report both have adopted current references in many cases and this is not intended to exclude earlier versions or other codes, standards, or guidance documents that are currently part of the CLB. A procedure for review and comparison with the GALL requirements would be an option that would preserve the utility of the GALL. See GALL-1 and GALL-2 comments. See NRC dis

NMC-2 and A
April 2001 C-89 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

SRP-LR-1 (I&M) C.3.16 Paragraph 3.5.2.3 This section references the BTP RLSB-l in Appendix A.I of the SRP- LR for the acceptance criteria for programs that are different from those described in the GALL report. Appendix A.I describes a means to review and demonstrate that a program meets the general requirements for AMPs. Please consider adding a methodology that would allow a licensee to demonstrate equivalency with the GALL by showing that a primary objective is met or that alternative codes and standards to those referenced in the GALL report are met. See GALL-1 and GALL-2 comments. See NRC dis

NMC-1, NMCTable C. UCS-1 C.3.17 UCS attended the public workshop conducted by the NRC staff on September 25, 2000. After the preliminary opening remarks, Mr. Yung Liu of the ANL made the first formal presentation. Apparently, ANL had been contracted by NRC to evaluate reformatting the Generic Aging Lessons Learned (GALL) report. Mr. Liu outlined the results of ANL’s evaluation. Mr. Liu displayed -- but did not provide copies of -- proposed revamped table for the GALL report. The revamped table purportedly saves paper by eliminating many of the existing columns in the table. Combining information with information in other columns eliminates some of the While the format, style, and font size of the GALL report are clearly within the purview of the NRC staff; it is outrageous that the NRC staff would ask the public to review and comment on one draft GALL report (ADAMS as session number ML003742594) while concurrently contracting for a substantial revision of that document. This act amounts to ‘bait and switch.” The NRC staff has a self-imposed deadline of August 31, 2000 for seeking public comments. In order to meet that artificial deadline, the NRC staff apparently released for public comment a premature draft of the GALL report it intends to issue. Thus, the public will be reviewing a See NRC disNIRS-1 in thi
NUREG-1739 C-90 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-1 (cont.) columns. Other columns, such as references, are just eliminated. UCS finds references very useful and would not want to see this valuable information discarded or relocated. draft report that the NRC has no real intention of issuing. The NRC staff should not place schedule ahead of quality. The NRC staff should wait until it has developed a draft GALL report it can support and then publish that document for public comment. The public has a right to review and comment on the document the NRC intends to issue, not the document the NRC staff hurriedly puts out just to meet some silly deadline. UCS-2 C.3.17 Section 3.2 of Draft Regulatory Guide DG-l 104, “Standard Format and Content for Applications to Renew Nuclear Plant Operating Licenses,” needs to be more explicit. It specifies that the license renewal application documents may be mechanically or photographically reproduced. However reproduced, the documents ultimately end up on the NRC’s Agency wide Document Access and Management System (ADAMS). Members of the public can (with a certain amount of good karma) download the documents and print out copies for purposes of review/comment. A color printer is not standard equipment. Thus, this regulatory guide should specify that the original documents might be in color, but that no essential information shall be lost when the document is output to a black & white printer. In the interes

publicly availand documendistinguishabblack and whinformation is pursue with tInstitute addiNEI 95-10, “IImplementing 10 CFR Part Renewal Rul“Standard FoApplications Power Plant endorses. RG 1-188 (forevised to inc

UCS-3 C.3.17 The NRC is presently attempting to risk-inform various things. For example, there’s an initiative on risk informing special treatment The risk sign

or componenin evaluating aging manag
April 2001 C-91 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-3 (cont.) requirements. If adopted, this initiative would enable plant owners to classify components by safety significance and by safety class (i.e., safety related or non-safety related). It is not clear from the draft regulatory guide, the draft standard review plan, or the draft GALL report how the agency will reconcile a plant getting a non-risk informed license extension under GALL-like provisions with subsequent substantial changes to that plant’s licensing bases. Probabilistic 

used to assisapproach for adequacy. Hprobabilistic aan acceptablthat, for those components management aging will be the period of Thus, risk sigconsidered in of an aging mfor the structlicense renewused to concmanagement for license reCurrently 10 specifically avoluntarily chregulatory rerisk-informing requirements scope of 10 Crequirementsassumes the carries forwaapplicant had informing its with a voluntainitiative, theclassificationnew current l
NUREG-1739 C-92 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-3 (cont.) Therefore, th

applicant woPart 50.54 agSSCs. The GALL renot revised to comment. Threnewal guidclearly articushould be haevaluate whiclicense renewmight be appdocumenting comment. UCS-4 C.3.17 The Federal Register notice posed the question, “Did the NRC staff provide sufficient credit for existing [aging management] programs in the draft GALL report?” UCS believes that the evidence shows NRC is giving too much credit for existing aging management programs. For example, the NRC’s Office of the Inspector General released a report dated August 29, 2000, “NRC’s Response to the February 15, 2000, Steam Generator Tube Rupture at Indian Point Unit 2 Power Plant,” concluded: QIG determined that the NRC and nuclear industry had long-standing concerns about the loss of integrity of steam generator tubes used on PWRs due to a variety of degradation mechanisms. Degradation problems particular to Westinghouse Model 44 steam generators resulted in all plants with this model steam generator replacing their steam generators, except IP2. The NRC has also been long aware of steam generator tube See NRC dis

NIRS-5, NIRSNIRS-8 in thiThese commrelated to agprograms anissues. The sother exampdemonstrate having an agprogram and aging managbecause thesbeen provideThe NRC staassume withothat any applmanagement 
April 2001 C-93 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-4 (cont.) and other problems at IP2. Nevertheless, the NRC did not conduct a technical review of the July29, 1997, IP2 steam generator inspection report when it was submitted to NRR. This OIG report for IP2 and other examples clearly demonstrate the difference between having an aging management program and having an effective aging management program. The NRC staff should not simply assume that any applicant’s aging management programs are effective. effective. The 

(10 CFR Part applicants to aging manageffective. GAlicensee aginprograms are current indusdocuments windustry pracaging managapplicants wiNRC will find acceptable. Hfree to propomanagement listed in GALdemonstrate effective in mThe GALL renot revised to comment.
NUREG-1739 C-94 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-5 C.3.17 The draft GALL report specifies ten attributes or elements that are to be addressed for each aging management program. One of these elements, Monitoring and Trending, defines the inspection method, frequency, and sample size that provide reasonable assurance of timely detection of aging effects. During the September 25, 2000, workshop, Ms. Tammy Bloomer of the NRC staff made a formal presentation on the use of one time inspections as an acceptable surrogate for periodic inspections. The license renewal application submitted by the owner of the Hatch nuclear plant (which generally conformed with the concepts specified in the draft GALL report) specified one-time inspections for many components. The NRC staff is giving too much credit for one-time inspections. The first of the two license renewals granted by the NRC thus far does not enter the renewal period for over a decade. None, or at least very few, of the one-time inspections have yet been conducted. Thus, the NRC has little to no evidence to support its bold assumption that one-time inspections will verify lack of aging. If, on the other hand, the one-time inspections reveal far more aging than is expected or permissible, all of the license renewals granted in the meantime will have been upon invalid bases. The NRC staff must judiciously accept one-time inspections. In addition, the NRC staff must consider whether selective one-time inspections should be performed now rather than waiting more than a decade to confirm well-intended guesses. The purpose 

normally is to aging degradexpected for (because indnot provide saging would effect is expeslowly. Licenprograms wofinding evidethat the causfurther and if ongoing aginprogram for tinspection. In addition, 1“backfitting” pprocess for thnew requiremto maintain smechanisms at a later timeimpose new accordance wAlso see NRC comment NIR
April 2001 C-95 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-6 C.3.18 Is the GALL report rendered obsolete or invalid when a plant owner adopts a voluntary regulatory initiative (such as risk-informed special treatment requirements) before submitting the license renewal application? Voluntary init

current licensCLB is plant-into license ran applicant components initiative to pefunctions as renewal rule part of the CLwill be in the renewal and describe progfor license reThe GALL renot revised to comment.
NUREG-1739 C-96 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-7 C.3.18 Is a license renewal granted based upon the GALL report invalidated when that plant owner subsequently adopts a voluntary regulatory initiative? Subsequent 

license, if a livoluntary initadditional cointended funclicense renewrequires the the correspomanagement update. The working with details of how license renewinformed initistaff believes initiative wouof SSCs from previously wilicense renewperform a 10 to control chaThe GALL renot revised to comment. UCS-8 C.3.18 Is the regulatory endpoint for a plant adopting voluntary initiative X before submitting a GALL-based license renewal application equivalent to that for a plant submitting a GALL- based license renewal application before adopting voluntary initiative X? See NRC disUCS-6 and Uwhich indicat
April 2001 C-97 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

UCS-9 C.3.18 When the voluntary regulatory initiatives spawn a spectrum of regulatory schemes, as suggested by Figure 1, what does Generic mean? The License 

principles acplant’s CLB iwill continue stakeholders special treatmregarding liceimplications. The GALL renot revised to comment. VP-1 C.3.19 We have reviewed and concur with the comments submitted on behalf of the nuclear utility industry by the Nuclear Energy Institute (NEI). None Provided. See Appendi

NRC dispositcomments.
NUREG-1739 C-98 April 2001 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

WESCO-1 C.3.20 If an applicant has a surveillance program that consists of capsules with a projected fluence exceeding the 60-year fluence at the end of 40 years, the applicant withdraws one capsule at an outage in which the capsule receives a neutron fluence equivalent to 60-year fluence and tests the capsule in accordance with the requirements of ASTM E185. If available, one capsule should remain in the vessel at all times. Additional capsules should be removed and placed in storage, depending on whether the licensee is considering a second renewal period (i.e. 80 years of operation). Any changes in anticipation of additional renewals, should be discussed with the staff. A further clarification of the intent of this paragraph would be important to Westinghouse as well as to utilities that operate Westinghouse 3-loop and 4-loop reactors that have neutron pad style reactor internals structures. The key characteristic (from a reactor vessel surveillance viewpoint) of these reactor internals designs is that the surveillance capsule lead factor (for all capsule positions) is quite large, e.g. on the order of 3.5 to 5.0. Recall that the lead factor is the ratio of the fast neutron exposure rate seen by the surveillance capsules to that seen by the peak location at the inner surface of the reactor vessel. Two different interpretations of the above paragraph from the GALL report have been voiced. At issue is whether or not to leave a surveillance capsule in the reactor and whether or not to irradiate a surveillance capsule to an 80-year- equivalent fluence now. We would appreciate it very much if you would review these comments and provide clarification of the NRC’s intent. The GALL re

address this capsule remofor both high plants. It is rewith a lead fa80 years of eafter being in 20 years. The GALL rerevised to ad

W&S-1 C.3.21 We endorse those NEI comments. None Provided. See Append

NRC disposicomments.
April 2001 C-99 NUREG-1739 Table C: Disposition of Written Public Comments (continued) Comment Number Item Number Comment/Proposed Change Basis For Comment NR

W&S-2 C.3.21 License renewal applicants who elect to use the GALL Report should not be required to perform an actual or de facto certification of their aging management programs against the program descriptions and attributes set forth in the document. None Provided. See NRC dis

NMC-2 in thi

W&S-3 C.3.21 Nor should here be any required “mapping” between aging effects addressed in a license renewal application versus the GALL Report. Instead, the GALL Report should only be treated as a reference tool, both by applicants and the NRC Staff. See NRC dis

NMC-2 and N

W&S-4 C.3.21 We strongly urge the staff to better define, in the document, how it is to be used by license renewal applicants. We believe that it is most important to explain that a license renewal applicant’s aging management program need not be identical to that described in the GALL Report in order to take credit for the conclusions reached in the report. See NRC dis

NMC-2 in thi
NUREG-1739 C-100 April 2001 This Page Intentionally Left Blank
APPENDIX D

DISPOSITION OF FIVE UNION

OF CONCERNED SCIENTISTS REPORTS
D-ii

This Page Intentionally Left Blank
April 2001 D-1 NUREG-1739

D.1. Introduction

In a letter dated May 5, 2000, the Union of Concerned Scientists (UCS) provided five reports

(ADAMs accession number ML003713188) to be considered for the development of the

improved license renewal guidance documents. The titles of these documents are included in

Section D.3 of this appendix. The components and aging effects provided in these reports were

evaluated, and the results of this review are summarized in this appendix.
NUREG-1739 D-2 April 2001

D.2. EVALUATION AND DISPOSITION OF COMMENTS

Table D, at end of Appendix D, contain the evaluation and disposition for each of the UCS

reports. The column heading “Document Number” is primarily intended to provide the source of

the comment, meaning the report being reviewed; it provides a means of referring to each report

without having to use the title. For example, UCS-1 indicates that the report being reviewed is

from UCS, and the “1” segregates this report from all other UCS reports. The references in

Appendix D.3 provide the sources of all comments
April 2001 D-3 NUREG-1739

D.3 REFERENCES

The following references were included in the Union of Concerned Scientist’s letter (ADAMs

accession number ML003713188):

1. H. M. Thomas, Rolls-Royce & Associates, “Pipe and Vessel Failure Probability,” Reliability

Engineering, 1981.

2. Nicholas T. Saltos, Probabilistic Safety Assessment Branch, Nuclear Regulatory

Commission, “Risk Impact of Environmental Qualification Requirements for Electrical

Equipment at Operating Nuclear Power Plants,” March 30, 1993.

3. Robert Pollard, Union of Concerned Scientists, “US Nuclear Plants —- Showing Their Age /

Case Study: Core Shroud Cracking,” September 1995.

4. Robert Pollard, Union of Concerned Scientists, “US Nuclear Plants —Showing Their Age /

Case Study: Reactor Pressure Vessel Embrittlement,” December 1995.

5. Robert Pollard, Union of Concerned Scientists, “US Nuclear Plants —Showing Their Age /

Case Study: Steam Generator Corrosion,” December 1995.
NUREG-1739 D-4 April 2001 Table D: Disposition of Five Union of Concerned Scientists Reports Document No. Item Number Document Title Document Summary NRC Di

UCS-1 IV.C1.1.1- IV.C1.1.11, IV.C1.1.13, IV.C2.2.1- IV.C2.2.8, IV.D1.1.5, IV.D2.1.5, V.D2.1.1- V.D2.1.7, VII.E2.1.1 VII.E3.1.1. H. M. Thomas, Rolls-Royce & Associates, “Pipe and Vessel Failure Probability,” Reliability Engineering, 1981. This document presents a generalized approach to estimation of failure probabilities for leakage and ruptures of piping and vessels. Failure data includes stress corrosion cracking of boiling water reactor (BWR) piping and fatigue cracking of light water reactor (LWR) piping. Steam generator tube failures are also discussed in the paper. Most of the failure da

document are assocthe first few years of design and fabricatioaging management ivessel failures reportwere due to manufacany aging effects, anfossil power plants (Rdocument: WASH 13on analysis of pressufrom fossil-fuelled poassessment of reactonuclear power plant Report, 1974.) Steafailures are mentionewithout identifying thmechanisms. For theaging degradation in vessel failures and sfailures discussed in be evaluated. The Gcomprehensive evaluaging management preactor pressure vesgenerator tubes discdocument. The GALL comprehensive evalumanagement prograpiping and fatigue anpiping. The GALL report has address the review o
April 2001 D-5 NUREG-1739 Table D: Disposition of Five Union of Concerned Scientists Reports (continued) Document No. Item Number Document Title Document Summary NRC Di

UCS-2 IV.A1.2.7, IV.A1.5.5, IV.B1.1.1, IV.B1.1.2, IV.B1.1.4, IV.B1.2, IV.B1.3.1 IV.B1.3.2, IV.B1.4.1- IV.B1.4.9, IV.B1.5.1, IV.B1.5.2, IV.B1.6.1- IV.B1.6.4. Robert Pollard, Union of Concerned Scientists, “US Nuclear Plants – Showing Their Age / Case Study: Core Shroud Cracking,” September 1995. This document focuses on aging of BWR vessel internals: steam dryer, steam separator and its support ring, core shroud, shroud head, core plate, top guide, feedwater sparger, core spray line and sparger, jet pump assemblies including jet pump sensing line, fuel supports, incore neutron flux monitors (housings, dry tubes, and guide tubes), neutron source holder, control blade, and CRD housing. The document listed the following aging effects and mechanisms for the internals components: crack initiation and growth due to SCC and fatigue, loss of fracture toughness due to neutron irradiation and thermal aging embrittlement, loss of material due to erosion, and deformation due to thermal creep. Most of the internals 

mechanisms addressare included in GALL some are not. Six of mentioned in this docsteam separator and shroud head and bolsparger) are not incluthey have no license function (not safety rthe pressure boundafor steam separator sholddown beams, whvessel top head. Theare included in ChapControl blades are nothey are short-lived creplaced periodically Neutron source holdebecause most BWR them from the vesseinternals is not includtemperatures experieare well below the tecreep is a concern focomponents. Erosion assemblies is not inchas been no evidencpump throat area, whsusceptible location ferosion occurs in the impair the intended fpump, which is to refthirds core height duof fuel support pieces because they are ma
NUREG-1739 D-6 April 2001 Table D: Disposition of Five Union of Concerned Scientists Reports (continued) Document No. Item Number Document Title Document Summary NRC Di

UCS-2 (cont.) stainless steel and/o

stresses. The GALL report was the review of this docincore neutron flux ma jet pump sensing li

UCS-3 IV.A2.5.1, IV.A2.5.2. Robert Pollard, Union of Concerned Scientists, “US Nuclear Plants — Showing Their Age / Case Study: Reactor Pressure Vessel Embrittlement,” December 1995. This document reviews information pertaining to reactor pressure vessel embrittlement and the issues related to the safe operation of nuclear power plants. Aging management o

embrittlement of PWpressure vessels has respectively, in GALLIV-A2. The GALL report was address the review o

UCS-4 IV.D1.2.1, IV.D1.2.3, IV.D2.2.1, IV.D2.2.2. Robert Pollard, Union of Concerned Scientists, “US Nuclear Plants 

—

Showing Their Age / Case Study: SteamGenerator Corrosion,” December 1995.

This document reviewsaging degradation of PWRrecirculating steamgenerator tubes. Thedocument mentions thatthe tubes in once-throughsteam generators haveexperienced similar typesof aging degradation butdoes not provide anyspecific information.The document identifiestwo issues related toaging management ofsteam generator tubes:(1) Quality of current

inspection techniquesfor detecting steam

All but one degradatisteam generator tubeGALL; for recirculatintubes in Chapter IV Dthrough steam generChapter IV D2. Loss due to fretting (wear) steam generator tubeChapter IV D2 becaumaterial loss in these their structural integrRegarding the quality techniques for detecttube degradation, the been revised to recoevaluation of the effeproposed aging manduring license renewgenerator tubes.
April 2001 D-7 NUREG-1739 Table D: Disposition of Five Union of Concerned Scientists Reports (continued) Document No. Item Number Document Title Document Summary NRC Di

USC-4 (cont.) generator tube degradation, (2) Quality of current inspection techniques for detecting steam generator tube degradation, (3) Adequacy of the alternate repair criterion based on voltage rather than crack size. The second issue ma

specific case of ODSdrill-hole support platRepair criteria were dsubstantial database to demonstrate that umaintained the margburst that has always tubing and that leakaenough to ensure thalimits to the public arissue does not warrachanges in GALL thaabove. The GALL report has address the review o

UCS-5 IV.C1.1.13, IV.C2.1.5, IV.C2.2.8. Nicholas T. Saltos, Probabilistic Safety Assessment Branch, Nuclear Regulatory Commission, “Risk Impact of Environmental Qualification Requirements for Electrical Equipment at Operating Nuclear Power Plants,” March 30, 1993. This document used probabilistic risk assessment (PRA) techniques to quantify the risk impact of electrical equipment qualified under the “old” EQ requirements and compare to recent requirements. The document also identified equipment in the containment whose failure could impact risk important operations. Review of this docum

addressing aging of GALL. These lines asmall-bore piping in Cbeen a clarification obore piping and instrChapters V, VII, and report. The GALL report has address the review o
NUREG-1739 D-8 April 2001 This Page Intentionally Left Blank
APPENDIX E

DISPOSITION OF THE NRC ADVISORY COMMITTEE

ON REACTOR SAFEGUARDS (ACRS) CONSULTANTS’

ELECTRICAL AND STRUCTURAL COMMENTS
E-ii

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April 2001 E-1 NUREG-1739

E.1 INTRODUCTION

The NRC Advisory Committee on Reactor Safeguards (ACRS) consultants have reviewed the

August 2000 version of the draft Standard Review Plan (SRP) for License Renewal and GALL

report. Comments were provided in two consultant reports, which were included as attachments

to a November 1, 2001 memorandum (see References, Section E.3). The specific technical

areas reviewed by the ACRS consultants are electrical components (S. Carfagno) and

containment structures (C. Chen). Each of these comments has been evaluated, and the

guidance documents have been revised, as needed, based on the staff’s disposition of these

comments.
NUREG-1739 E-2 April 2001

E.2. EVALUATION AND DISPOSITION OF COMMENTS

Table E, at the end of Appendix E, provides the evaluation and disposition for each of the

ACRS consultants’ comments. The column heading “Comment Number” is primarily intended to

provide the source of the comment, meaning the organization or individual that submitted the

comment. For example, ACRS-CARFAGNO-1 indicates that the comment was made by the

ACRS electrical consultant Carfagno and the “1” segregates this comment from all other

electrical consultant comments. All comments are in alphanumeric order, based first on the

organization, which is the ACRS, and second on the consultant’s name. The references in

Appendix E.3. provide the sources of all comments.
April 2001 E-3 NUREG-1739

E.3 REFERENCES

NRC memorandum dated November 1, 2000, “Consultant Reports Concerning License

Renewal Guidance Documents,” James E. Lyons, ACRS to Christopher L. Grimes, NRC.
NUREG-1739 E-4 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -1 SRP Ch. 3.6, Table 3.6-1 and 3.6-2 Non-EQ electrical cables and connections It is suggested that consideration be given to adding moisture to heat and radiation as the causes of adverse environments. None provided. Moisture is 

aging degraand should of an adversproposed chhas been inThe SRP Seaddress this conforming GALL Chap

ACRS- CARFAGNO -2 SRP Ch. 3.6, Table 3.6-2 Non-EQ electrical cables and connections It is suggested that the inspection interval of “at least once every 10 years” be reduced after the age of the component reaches approximately 40 years, or after testing indicates that significant degradation has taken place. It is questioned whether visual inspection for surface anomalies is an adequate indicator of component degradation. None provided. Inspections 

years have license renebasis that oshows aging slow proceshave been sidentifying indegradation10 years wiin a 20-year to characterNeither the report was rcomment.
April 2001 E-5 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -3 SRP Ch. 3.6, Table 3.6-2 Non-EQ inaccessible medium-voltage cables A weakness in the aging management program for this category is that the testing is defined only as “to be determined prior to each test,” so that a reviewer has no specific guidance as to what constitutes an acceptable test. None provided. The test to 

voltage, inahave to be bis state-of-thtest is perfoapproved by performing The SRP SeChapter XI, address this the above re

ACRS- CARFAGNO -4 SRP Ch. 3.6, Table 3.6-2 Non-EQ inaccessible medium-voltage cables It is suggested that a testing interval shorter than “at least once every 10 years” would be more appropriate after the age of the component exceeds approximately 40 years, or after testing indicates that significant degradation has taken place. None provided. An interval o

accepted in applications operating exdegradation Using a freqprovide two period that ccharacterize Neither the report was rcomment.
NUREG-1739 E-6 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -5 SRP Ch. 3.6, Table 3.6-2 Non-EQ connectors subject to borated water leakage It is not obvious how visual inspection of connectors and enclosure external surfaces can provide a reliable determination of “the possible intrusion of borated water” into the components. None provided. Past operat

shown that to borated wwith a stain indicative of even after aacid are reminspections evidence of water leakathe surface indicate the examination determine if water occurconcern. Neither the report was rcomment. ACRS- CARFAGNO -6 SRP Ch. 3.6, General A flow chart guiding reviewers to the appropriate review category and checklists for each category could simplify the task of reviewers. None provided. Flowcharts useful; hownecessary. sufficient guunder “ReviHowever, floare options the SRP, baexperience. Neither the report was rcomment.
April 2001 E-7 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -7 SRP Ch. 4.1 4.1.3 [It is unclear] how a reviewer chooses a TLAA that was not listed by the applicant but which is likely to satisfy all six acceptance criteria. None provided. The review 

identification the updated and other CSERs. This Section 4.1guidance on TLAAs. Neither the report was rcomment. ACRS- CARFAGNO -8 SRP Ch. 4.1 4.1.1 The applicant’s listing [of TLAAs] is required to include sufficient detail to permit identification of the type of calculation, but there is evidently no requirement that the review covered by Chapter 4.1 include a technical review of the adequacy of the calculation. None provided. The review deals only wTLAAs. Tecdetermine tcalculations in other secwas clarified to the sectiotechnical reThe SRP, Caddress this 
NUREG-1739 E-8 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -9 SRP Ch. 4.4 4.4.1.1 Section 4.4.1.1 states “Compliance with 10 CFR 50.49 provides evidence that the component will perform its intended functions...” While the wording “provides evidence” is relatively less objectionable than “provides assurance”, it is suggested, as elsewhere in this [ACRS consultant] report, that “provides reasonable assurance” is preferable wording. Compliance with 10 CFR 50.49 does not provide absolute assurance that a component will perform its intended function. Rather, 10 CFR 50.49 provides reasonable assurance that a component can perform its intended function. The purpos

provide reascomponents intended funenvironmenproposed chhas been inThe SRP, CChapter X wthis comme

ACRS- CARFAGNO -10 SRP Ch. 4.4 4.4.1.1 Paragraph 4.4.1.1.1 states how the DOR Guidelines will be used for the review of equipment subject to significant degradation due to aging where a qualified life was previously established; it should also state how equipment for which a qualified life was not established will be reviewed. None provided. EQ equipme

susceptible degradation qualified life expected to Section 7 of addresses srequires thaimplementesurveillance records to athat is exhibdegradation replaced, as clarified by the DOR gurequiremenreviewing Equalified life The SRP, Cto address t
April 2001 E-9 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -11 SRP Ch. 4.4 4.4.1.1.2 (Paragraph 4.4.1.1.2, covering NUREG-0588 Category II components, states that the qualification programs for valve actuators and motors committed to conform with IEEE Standards 382- 72 and 334-71, respectively, will be reviewed against Category II requirements; it is not clear what is to be done with components other than valve actuators and motors that fall under Category II. None provided. Component

actuators anCategory II addressed. revising Parinclude a stParagraph componentsThe SRP Cto address t

ACRS- CARFAGNO -12 SRP Ch. 4.4 4.4.3.1.2 In paragraph 4.4.3.1.2, referring to aging analyses, the meaning of the last phrase, “...and the period of time prior to the end of qualified life” is not clear. It seems to mean that the applicant should identify how long before the end of qualified life the analyses will be completed. None provided. The intende

referenced that the reasufficient timcomponent’component refurbishmereanalysis ccomponent’to 10 CFR 5statement wThe SRP, Cto address t
NUREG-1739 E-10 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -13 SRP Ch. 4.4 4.4.3.3 Paragraph 4.4.3.3, on the FSAR supplement, allows applicants to make program changes in the supplement, without prior Commission approval, “provided that the applicant evaluates each such change pursuant to the criteria set forth in 10 CFR 50.49.” It is not clear at what point the staff is to review such changes. None provided. The require

program chare set forth stated in the Neither the report was rcomment. ACRS- CARFAGNO -14 SRP General Clearer language would be helpful in eliminating potential confusion as to the definition of components within the scope of license renewal. On the one hand, components with an active function are excluded and passive components are included, the rationale being that performance monitoring makes aging management easier for active components. Similarly, components whose replacement is based on a qualified life or a specific replacement interval are excluded. On the other hand, EQ components most of which have active functions and do have a qualified life, are included; but their evaluation is essentially limited to the review of TLAAs and any aging monitoring programs that may be used to justify operation beyond their qualified life. The languagcomponents license reneconsistent wrenewal rule Neither the report was rcomment.
April 2001 E-11 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -15 SRP General One critical area of review concerns condition monitoring (CM) programs that may be used for EQ components with a qualified life less than 60 years. While the documents reviewed contain a wealth of information on the criteria that must be met for CM programs to be acceptable, the fact remains that practical CM techniques probably do not exist that meet the key criterion (i.e., that the method be capable of predicting with reasonable assurance the remaining period during which the intended function can be performed.) The regulatory documents state specifically that simply verifying that equipment is functional in the normal service environment is not sufficient. While curre

techniques predicting wassurance tduring whiccan be perfoinformation make informthe acceptacontinued sadvances in made, and emonitoring tequipment ifuture perfomore practicurrent limitCM is an efaging and than aging mashould be aNeither the report was rcomment.
NUREG-1739 E-12 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -16 SRP General [An] area of review that may present difficulty concerns components designed and built prior to the existence of the present criteria and inspection programs. This area is also related to the question of whether equipment qualified in accordance with older regulations and IEEE standards are adequate for use during the period of continued operation. Earlier qualification standards did not require the establishment of a qualified life. Component

standards, aqualified liferare. In the componentsin a similar with a qualifperiod of exThe SRP, Cto address ta statement 

ACRS- CARFAGNO -17 SRP General [A] caution [related to the guidance for evaluating time-limited aging analyses] applies to the choice of activation energy. Activation energy is known to depend critically on the specific composition of materials analyzed – making the use of generic values of activation energy questionable. The use of 

energies waand is outsirenewal. In EQ equipmeactivation emonitored awith proper specific basstated in the aging manaChapter X. Neither the report was rcomment. ACRS- CARFAGNO -18 GALL Vol. 1 Summary It is recommended that elements 4 and 5 [of the aging management programs] be reworded to be consistent with existing technology. The description of element 4 states, “Detection of aging effects should occur before there is a loss of any...component intended function.” The description of element 5 states, in part, “Monitoring and trending The intent oencourage tdegradation time and to degradation decisions cacorrective a
April 2001 E-13 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -18 (cont.) should provide for prediction of the extent of the effects of aging and timely corrective or mitigating actions.” It must be kept in mind that the most important “intended function” is the one required when an accident occurs. For non-environmentally qualified electrical cables and connections this point is relatively less important than it is for environmentally qualified equipment, because the environment of non-EQ cables and connections is not likely to change from the normal environment when an accident occurs. However, for EQ equipment the environment will be more severe than normal when an accident occurs; therefore, it is difficult to determine whether the intended function can be performed based on inspection and testing conducted under normal service conditions. For EQ equipment, although components with a QL or specified replacement interval are excluded from license renewal review, EQ equipment is included because it involves TLAAs. This concern also applies if CM is depended upon to accommodate a QL (now usually 40 provide reas

a componenintended funAs worded, require that establishedactions be tdegradation component Similarly, elrequire that establishedDegradation trended, if aIn the case managemefor non-EQ none of thetrending to maging. Neither the report was rcomment.
NUREG-1739 E-14 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -18 (cont.) years) which is less than the desired life, e.g., 60 years. Consequently, while it is possible to detect aging effects, it is usually not feasible to determine when the aging effects have progressed to the level that there remains reasonable assurance that the intended function can be performed during the period before the next surveillance is scheduled to take place. This dilemma is described more fully in Section 4.3 of this [ACRS consultant] report on Condition Monitoring. Since decision criteria are generally not available, it is inconsistent to imply that the evaluation of aging programs has demonstrated that element 4 is satisfied. The comments concerning element 4 apply even more strongly here, because element 5 emphasizes the requirement for predicting future intended function capability. ACRS- CARFAGNO -19 GALL Vol. 1 Summary It is suggested that a checklist be prepared similar to the one (see Appendix B [of the ACRS consultant report]) for the review of equipment qualification programs. A checklist would facilitate the review process. See NRC d

ACRS-CARTable E.
April 2001 E-15 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -20 GALL Ch. X P. X-10 Reword references to 10 CFR 50.49 to state that “...compliance provides reasonable assurance that the component can perform its required functions.” On this page [of the GALL report], in items 9 and 10, it is stated that compliance with 10 CFR 50.49 demonstrates that “a component will perform required functions” and that

“Compliance with 10 CFR 50.49provides evidence that a componentwill perform its intended functions...”It is more accurate to state thatcompliance with 10 CFR 50.49provides reasonable assurancethat the component can perform itsrequired functions. This comment isbased on extensive past discussionsamong qualification standardswriting groups, but it is alsoconsistent with the statement in thefirst paragraph of Chapter XI.E1,“The purpose of the agingmanagement program describedherein is to provide reasonableassurance that the intendedfunctions of electrical equipment willbe maintained...,” where,unfortunately, the word “will” isrepeated.

The purposCFR 50.49 assurance tperform theharsh enviroproposed chhas been inGALL, Chapaddress this 
NUREG-1739 E-16 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CARFAGNO -21 GALL Ch. XI E1 and E2 Add moisture to heat and radiation as an environmental condition of interest. None provided. Moisture is 

aging degraand should of an adversproposed chhas been inGALL, Chapaddress this conforming the SRP, Se

ACRS- CARFAGNO -22 GALL Ch. XI E1 and E3 Particularly with increasing age, a shorter [inspection] interval [than once every 10 years] would be more appropriate. In Chapters XI.E1 and XI.E3, [it is stated that] an inspection interval of “at least once every 10 years is an adequate period to preclude failures of the conductor insulation.” With increasing age, a shorter interval would be more appropriate. An interval o

accepted in applications operating exdegradation Using a freqprovide two period that ccharacterize Neither the report was rcomment. ACRS- CHEN-1 SRP 3.5.1 Guidance is needed for sources of information for “non-recent vintage plants. SRP 2.4 on scoping and screening is a good source. SRP 3.5.1 does not address older plants. For older plapplicable inspecific bechave predatSection 3.5revised to a
April 2001 E-17 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-2 SRP 3.5.2.2.1 and 3.5.3.2.1 Mark I steel and concrete containments and Mark II steel containment should also be added to have a complete list. (GL 87-05 Table 1 lists Brunswick 1 & 2 as Mark I concrete containments.) For completeness. The SRP is 

GALL tables containmenare not idensteel contaicontainmen12/6/99 draAugust 200NEI Commebecause it oplant, BrunsNeither the report was rcomment. ACRS- CHEN-3 SRP Table 3.5- 1, p.3.5-18 Add “potential loose expansion anchor bolts due to vibration or waterhammer.” It can be managed by an in-service inspection program. Concern this was overlooked. “Potential lo

bolts due to waterhammChapter IIIB Supports. A program cathis. SRP, T“concrete suas the area the concrete in anchor caNeither the report was rcomment.
NUREG-1739 E-18 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-4 SRP 3.5.1, p. 3.5-1 The words “ASME Class MC piping and components” is unclear as to the meaning. Class MC is for metal containments. Improve clarity. See NRC d

comment GTable B.2.2The SRP wthis comme

ACRS- CHEN-5 SRP 3.5 SRP refers to GALL report at many places, but does not mention specific chapters. However, it is not too difficult to find the right chapters of GALL using the GALL report TOC. Response to ACRS Requirement 3.2 concerning guidance in SRP for referencing GALL chapters. The ACRS 

propose any Neither the report was rcomment. ACRS- CHEN-6 SRP 4.6.1 SRP states “If a plant’s code of record requires a fatigue analysis, then this fatigue analysis may be a TLAA.” No guidance if code of record does not require a fatigue analysis. Should the Backfit Rule be applied or is fatigue analysis not required for LR also? Concern there is no guidance provided for containments designed prior to present criteria and inspection program. The Backfit fatigue analLR unless it containmenentry in GALspecifically “Cracking dbeen identifanalysis doeNeither the report was rcomment. ACRS- CHEN-7 General comment GL 87-05 pointed out that details of the “sand cushion design” for Mark I drywells varies depending on the AE and may be significant in the occurrence of degradation. This should be added to SRP and highlighted for the reviewers. Same as directly above. In GALL Chpocket regioI and II steeof material dReference tto the “Opediscussion iThe GALL raddress this 
April 2001 E-19 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-8 GALL Vol. 1, Table 5 Same as ACRS-CHEN-3. Same as ACRS-CHEN-3. See NRC d

ACRS-CHE

ACRS- CHEN-9 GALL, p. II B2-3 Paragraph refers to Mark II steel containment as having both steel and concrete elements, which is inconsistent with ps. II B2-1 and II B2-6, which only address steel elements. Also Mark I steel and concrete containments not properly identified. Correct inconsistency. According to 

are no concand II steel require aginconcrete coincluded in 

See NRC dACRS-CHEThe GALL raddress this Page II B2-3 “concrete” icontainmen

ACRS- CHEN-10 GALL Item II A1.1 “leaching of calcium hydroxide, aggressive chemical attack, corrosion of embedded steel” and GALL Item IIA1.2 “corrosion” requiring evaluation of inaccessible areas Evaluation of inaccessible areas when conditions in accessible areas may not indicate the presence of or result in degradation to such inaccessible areas goes beyond the inaccessible area requirements of 10 CFR 50.55a(b)(2)(ix). It is more reasonable to require this in cases when the applicant cannot show that the environments in accessible and inaccessible areas are similar. GALL is too restrictive on “inaccessible areas.” See NRC d

comment GTable B.2.1
NUREG-1739 E-20 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-11 General comment It appears that adequate technical bases for the AMPs are provided in the referenced ASME codes, Reg. Guides and relevant NUREGs. Response to ACRS Requirement 3.5 concerning the technical bases for the AMPs. The consult

AMPs have bases in costandards. Neither the report was rcomment. ACRS- CHEN-12 GALL Section II.B1, “Mark I Contain- ments” See comments ACRS-CHEN-2, -7, - 9. Response to ACRS Requirement 3.6 that a more in-depth review of Mark I containments be conducted. See NRC dACRS-CHETable E. ACRS- CHEN-13 General Comment Adequate technical bases to support LR decisions are provided. Response to ACRS Guidance 4.1: Do LR documents provide adequate technical bases to support license renewal decisions? The consultadequate teprovided for Neither the report was rcomment. ACRS- CHEN-14 General Comment SRP-LR provides an adequate roadmap, with one (1) minor editorial difference. There is an inconsistency between NEI 95-10, Rev. 2 and SRP-LR in Table 6.2-1 of 95-10. Response to ACRS Guidance 4.2: Are LR documents effectively integrated to provide a consistent and understandable process? The consultSRP-LR proroadmap. TinconsistencRev. 2, and of 95-10. NEsubsequentinconsistencNeither the report was rcomment.
April 2001 E-21 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-15 General Comment Adequate scoping/screening criteria is applied to old plants because non- safety-related and regulated-events are included, in addition to safety- related, in the scoping. Response to ACRS Guidance 4.3: Is scoping/screening guidance adequate for old plants? The consult

adequate scguidance is plants. Neither the report was rcomment. ACRS- CHEN-16 General Comment Lessons learned from Calvert Cliffs and Oconee are listed in SRP Table 4.1-3 and described in detail in GALL Chapter X. To help future reviewers, SRP should include a more detailed description of lessons learned. Response to ACRS Guidance 4.3: Are lessons learned from Calvert Cliffs and Oconee adequately conveyed to future reviewers? The consultChapter X afor lessons lessons leaand Oconee implementethe SRP anincorporatinexpected to applications Neither the report was rcomment. ACRS- CHEN-17 General Comment SRP directs the staff to develop comprehensive understanding of technical issues concerning scooping/screening and identification of TLAAs. It also directs the staff to verify the existence of AMPs. Response to ACRS Guidance 4.4: Does SRP direct the staff to develop comprehensive understanding of technical issues and proposed technical solutions or to verify the existence of AMPs? The consultSRP providon technicaverify existeNeither the report was rcomment.
NUREG-1739 E-22 April 2001 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-18 General Comment Plant-specific operating experience is one of the ten attributes evaluated for AMPs, as shown in GALL Vol. 1, p. 2 and in GALL Vol. 2, Chapters X and XI. Response to ACRS Guidance 4.5: Is review of plant-specific operating experience adequately emphasized by the SRP? Is guidance adequate for evaluation of AMPs that address unique types of plant-specific aging degradation? The consult

SRP adequspecific opeunique plandegradationNeither the report was rcomment. ACRS- CHEN-19 General Comment Guidance could be more specific. The tendon access gallery is one example where more detailed guidance should be included. Suggest that increased inspection frequency where high moisture and humidity is present be added in GALL page IIA1-13 and SRP Table 2.4-1, p. 2.4-6. Response to ACRS Guidance 4.5: Is review of plant-specific operating experience adequately emphasized by the SRP? Is guidance adequate for evaluation of AMPs that address unique types of plant-specific aging degradation? See NRC d

comment GTable B.2.1

ACRS- CHEN-20 General Comment Recommend some examples of plant-specific operating experience be described under attribute 10 in GALL Chapters X and XI. Response to ACRS Guidance 4.5: Is review of plant-specific operating experience adequately emphasized by the SRP? Is guidance adequate for evaluation of AMPs that address unique types of plant-specific aging degradation? As appropri

specific IEBdocuments industry opeincluding plaOperating eapplicant’s paddressed iNeither the report was rcomment.
April 2001 E-23 NUREG-1739 Table E: Disposition of the NRC Advisory Committee on Reactor Safeguards (ACRS) Consultants’ Electrical and Structural Comments (continued) Comment Number Item Number Comment/Proposed Change Basis for Comment NR

ACRS- CHEN-21 General Comment The concerns of the public, and possibly the interveners, are taken into consideration. SRP Sections 2.1.2.1 and 2.1.2.2 refer specifically to NEI 95-10, Rev. 2 and GALL Vol. I page 1 refers to reports provided by UCS which the staff considered. Response to ACRS Guidance 4.6: Have the issues and concerns raised by all stakeholders been properly considered in the SRP and supporting documents? All public co

NRC have rconsideratioreview and Neither the report was rcomment. ACRS- CHEN-22 General Comment Generic issues as discussed in SRP Appendix A.3 are adequately resolved. Response to ACRS Guidance 4.7: Are LR generic issue resolutions adequately reflected in the guidance documents? The consultgeneric issureflected in documents. Neither the report was rcomment.
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